`By:
`George E. Quillin
`Paul S. Hunter
`FOLEY & LARDNER LLP
`3000 K Street, N.W., Suite
`600 Washington, D.C. 20007
`Tel: (202) 672-5300 Fax:
`(202) 672-5399
`gquillin@foley.com
`
`Paper No.
`Date Filed: September 18, 2013
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`XILINX, INC.
`Petitioner
`
`v.
`
`INTELLECTUAL VENTURES I LLC
`Patent Owner
`
`Case IPR2013-00029
`Patent 5,632,545
`
`PATENT OWNER’S SECOND OBJECTION TO EVIDENCE
`
`4842-2813-6213.1
`
`
`
`IPR2013-00029
`Patent Owner’s Second Objection to Evidence
`
`PATENT OWNER’S SECOND OBJECTION TO EVIDENCE
`
`In accordance with Bd. R. 42.64, patent owner objects to Exhibit 1012 (Declaration of
`
`A. Bruce Buckman, Ph.D. … Directed to the Proposed Substitute Claims) and Exhibit 1013
`
`(Reply Report of Dr. A. Bruce Buckman), because they are incomplete. Each declaration
`
`purports to rely on figures said to be included in the body of the declaration when in fact the
`
`figures are missing, contrary to Fed. R. Evid. 106, 705; Bd. R. 42.61-62, 42.65.
`
`As filed and served on September 12, 2013, Xilinx Ex. 1012 is missing twenty-one
`
`figures on pp. 19, 21, 23, 24, 25, 26, 27, 29, 31, 32, 34, 42, 43, 45, 46, 48, 49, 51, 53, 54, and
`
`56.
`
`16.
`
`Xilinx Ex. 1013, as filed and served on September 12, 2013, is missing a figure on page
`
`This objection is being timely served within five business days of service of evidence to
`
`which the objection is directed, in accordance with Bd. R. 42.64(b)(1). That is, the Xilinx
`
`evidence was filed and served on Thursday, September 12, 2013. This objection is being filed
`
`and served four business days afterwards, that is, on Wednesday, September 18, 2013.
`
`/George E. Quillin/
`George E. Quillin
`Registration No. 32,792
`Counsel for Patent Owner
`
`4842-2813-6213.1
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing PATENT OWNER’S
`
`SECOND OBJECTION TO EVIDENCE is being served on counsel of record on September 18,
`
`2013, by filing this document through the Patent Review Processing System as well as
`
`delivering a copy via commercial overnight courier directed to the counsel of record for the
`
`Petitioner at the following address:
`
`David L. McCombs, Esq.
`Haynes and Boone, LLP
`2323 Victory Avenue, Suite 700
`Dallas, TX 75219
`
`Dated: September 18, 2013
`
`Respectfully submitted,
`
`/George E. Quillin/
`George E. Quillin
`Registration No. 32,792
`Counsel for Patent Owner
`
`4842-2813-6213.1
`
`