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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SYNOPSYS, INC.
`Petitioner
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`v.
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`Patent of MENTOR GRAPHICS CORPORATION
`Patent Owner
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`____________
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`Case IPR2012-00042 (SCM)
`Patent 6,240,376 B1
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`PETITIONER’S OBJECTIONS TO EXHIBITS IN PATENT OWNER’S
`REPLY IN SUPPORT OF ITS SUBSTITUTE MOTION TO AMEND
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`1
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`SYNOPSYS 1022 Synopsys v. Mentor, IPR2012-00042
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`PETITIONER’S OBJECTIONS TO EXHIBITS IN PATENT OWNER’S
`REPLY IN SUPPORT OF ITS SUBSTITUTE MOTION TO AMEND
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`Petitioner Synopsys, Inc. hereby objects pursuant to 37 C.F.R. § 42.64(b) to
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`Exhibits 2030, 2031, and 2033 submitted by Patent Owner in its Reply in Support of
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`its Substitute Motion to Amend (“Reply”). Patent Owner objects to these exhibits as
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`irrelevant to the issues before the Board.
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`Neither Ex. 2030 nor 2031 are even referenced in Patent Owner’s Reply.
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`Moreover, they pertain to paragraph 33 of Dr. Hutchings’ declaration which he
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`deleted of his own accord during his deposition. See Ex. 2032 at 27:24-28:11.
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`Patent Owner submitted Ex. 2033 to attempt to swear behind the Boubezari
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`reference. However, as noted in Petitioner’s Opposition (paper 35 at 9) “whether
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`Boubezari qualifies as prior art is irrelevant here because Petitioner is relying on
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`Boubezari to show the level of knowledge and skill in the art at the time of the
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`invention, not as a prior art reference to be combined with Gregory.” Thus whether
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`or not Patent Owner can “swear behind” Boubezari is irrelevant and so is Ex. 2033.
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`We believe the Board already addressed this issue when it denied Patent Owner’s
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`request for extra pages.
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`SYNOPSYS 1022 Synopsys v. Mentor, IPR2012-00042
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`Dated:
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`October 5, 2013
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`Respectfully submitted,
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`By: /Travis Jensen/
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`Travis Jensen
`CA Bar No. 259925
`Registration No. 60,087
`tjensen@orrick.com
`ORRICK, HERRINGTON, &
`SUTCLIFFE LLP
`1000 Marsh Road
`Menlo Park, CA 94025-1015
`Tel: 650-614-7400
`Fax: 650-614-7401
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`William H. Wright
`CA Bar No. 161580
`Registration No. 36,312
`wwright@orrick.com
`ORRICK, HERRINGTON, &
`SUTCLIFFE LLP
`777 South Figueroa Street, Suite 3200
`Los Angeles, California 90017
`Tel: 213-629-2020
`Fax: 213-612-2499
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`Attorneys for Petitioner,
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`Synopsys, Inc.
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`SYNOPSYS 1022 Synopsys v. Mentor, IPR2012-00042
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`CERTIFICATE OF SERVICE
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`The undersigned certifies e-mail service pursuant to 37 C.F.R. § 42.6(e) and
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`agreement of counsel of a true copy of the foregoing PETITIONER’S
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`OBJECTIONS TO EXHIBITS IN PATENT OWNER’S REPLY IN SUPPORT
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`OF ITS SUBSTITUTE MOTION TO AMEND to counsel of record for Patent
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`Owner as follows:
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`Christopher L. McKee and Michael S. Cuviello
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`cmckee@bannerwitcoff.com; mcuviello@bannerwitcoff.com
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`Mentoripr@bannerwitcoff.com
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`Dated: October 5, 2013
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`By: /s/ Travis Jensen
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` Travis Jensen
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`SYNOPSYS 1022 Synopsys v. Mentor, IPR2012-00042
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