UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`SONY CORPORATION
`Petitioner
`
`v.
`
`YISSUM RESEARCH DEVELOPMENT COMPANY OF THE
`HEBREW UNIVERSITY OF JERUSALEM
`Patent Owner
`
`Case No. IPR2013-00219 (SCM)1
`
`
`Patent No. 7,477,284
`Issue Date: Jan. 13, 2009
`Title: SYSTEM AND METHOD FOR CAPTURING AND VIEWING
`STEREOSCOPIC PANORAMIC IMAGES
`__________________________________________________________________
`
`PETITIONER’S OBJECTIONS TO EVIDENCE
`
`PURSUANT TO 37 C.F.R. § 42.64(b)(1)
`
`__________________________________________________________________
`
`
`
`
`
`
`
`
`1 The IPR2013-00327 proceeding has been joined with this proceeding.
`
`Petition for Inter Partes Review
`of U.S. Pat. No. 7,477,284
`IPR2013‐00219
`EXHIBIT
`Sony‐
`
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`SONY CORPORATION
`Petitioner
`
`v.
`
`YISSUM RESEARCH DEVELOPMENT COMPANY OF THE
`HEBREW UNIVERSITY OF JERUSALEM
`Patent Owner
`
`Case No. IPR2013-00219 (SCM)1
`
`
`Patent No. 7,477,284
`Issue Date: Jan. 13, 2009
`Title: SYSTEM AND METHOD FOR CAPTURING AND VIEWING
`STEREOSCOPIC PANORAMIC IMAGES
`__________________________________________________________________
`
`PETITIONER’S OBJECTIONS TO EVIDENCE
`
`PURSUANT TO 37 C.F.R. § 42.64(b)(1)
`
`__________________________________________________________________
`
`
`
`
`
`
`
`
`1 The IPR2013-00327 proceeding has been joined with this proceeding.
`
`Petition for Inter Partes Review
`of U.S. Pat. No. 7,477,284
`IPR2013‐00219
`EXHIBIT
`Sony‐
`
`
`
`IPR2013-00219, Inter Partes Review of U.S. Pat. No. 7,477,284
`Petitioner’s Objections to Evidence
`
`PETITIONER’S OBJECTIONS TO EVIDENCE
`
`
`
`On April 15, 2014, during the deposition of petitioner Sony Corporation’s
`
`(“Sony”) expert Trevor Darrell, Patent Owner served Exhibits YRD-2011, YRD-
`
`2012, YRD-2013 (1 page) and YRD-2013 (9 pages)2 on Sony.
`
`
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), and in addition to any objections stated on
`
`the record at the deposition of Prof. Darrell on April 15, 2014, Sony hereby objects to
`
`the admissibility of these exhibits as follows:
`
`(1)
`
`Sony objects to Exhibit YRD-2011 for lack authentication under FED. R. EVID.
`
`901, lack of relevance, as beyond the scope of the direct testimony set forth in the
`
`Second Declaration of Trevor Darrell (Sony-1044) contrary to 37 C.F.R. §
`
`42.53(d)(5)(ii), and as inadmissible hearsay under FED. R. EVID. 801 and 802.
`
`(2)
`
`Sony objects to Exhibit YRD-2012 for lack authentication under FED. R. EVID.
`
`901, as beyond the scope of the direct testimony set forth in the Second Declaration
`
`of Trevor Darrell (Sony-1044) contrary to 37 C.F.R. § 42.53(d)(5)(ii), and as failing to
`
`comply with 37 C.F.R. § 42.63(b). Sony further objects to Exhibit YRD-2012 as
`
`irrelevant in that the translation of the Asahi reference submitted as Exhibit Sony-
`
`1010 was submitted by Sony with the Petition on March 29, 2013, and Patent Owner
`
`has never objected to the accuracy of Sony-1010 despite Patent Owner’s long prior
`
`possession of a copy of the document that Patent Owner has marked as Exhibit
`
`YRD-2012. Pursuant to 37 C.F.R. § 42.64(b)(1), any objection to Exhibit Sony-1010
`
`2
`Patent Owner marked two documents YRD-2013.
`
`2
`
`
`
`
`IPR2013-00219, Inter Partes Review of U.S. Pat. No. 7,477,284
`Petitioner’s Objections to Evidence
`was due within ten days of institution of trial, i.e., by October 7, 2013. Therefore any
`
`objection to Exhibit Sony-1010 has been waived by Patent Owner.
`
`(3)
`
` Sony objects to Exhibit YRD-2013 (1 page) for lack authentication under FED.
`
`R. EVID. 901, lack of relevance, and as beyond the scope of the direct testimony set
`
`forth in the Second Declaration of Trevor Darrell (Sony-1044) contrary to 37 C.F.R. §
`
`42.53(d)(5)(ii).
`
`(4)
`
`Sony objects to Exhibit YRD-2013 (9 pages) for lack authentication under
`
`FED. R. EVID. 901, and as beyond the scope of the direct testimony set forth in the
`
`Second Declaration of Trevor Darrell (Sony-1044) contrary to 37 C.F.R. §
`
`42.53(d)(5)(ii). Sony further objects to Exhibit YRD-2013 (9 pages) as irrelevant in
`
`that the translation of the Kawakita reference included in Exhibit Sony-1003 was
`
`submitted by Sony with the Petition on March 29, 2013, and Patent Owner has never
`
`objected to the accuracy of Sony-1003 despite Patent Owner’s long prior possession
`
`of a copy of the document that Patent Owner has marked as Exhibit YRD-2013 (9
`
`pages). Pursuant to 37 C.F.R. § 42.64(b)(1), any objection to Exhibit Sony-1003 was
`
`due within ten days of institution of trial, i.e., by October 7, 2013. Therefore any
`
`objection to Exhibit Sony-1003 has been waived by Patent Owner.
`
`
`
`
`
`3
`
`
`
`
`IPR2013-00219, Inter Partes Review of U.S. Pat. No. 7,477,284
`Petitioner’s Objections to Evidence
`Dated: April 22, 2014
`
`
`
`
`
`
`
`
`_/s/ Walter Hanley__
`Walter Hanley, Lead Counsel, Reg. No 28,720
`whanley@kenyon.com
`Michelle Carniaux, Backup Counsel, Reg. No. 36,098
`mcarniaux@kenyon.com
`KENYON & KENYON LLP
`One Broadway, New York, NY 10004-1007
`
`4
`
`
`
`
`
`
`
`
`Certificate of Service Under 37 C.F.R. § 42.6(e)(4)
`
`I certify that I caused a true and correct copy of the forgoing to be served via
`
`Electronic Mail on the following:
`
`William Nelson and Robert Gerrity
`Robert.gerrity@tensegritylawgroup.com
`William.nelson@tensegritylawgroup.com
`Tensegrity Law Group LLP
`555 Twin Dolphin Dr., Suite 360
`Redwood Shores, CA 94065
`
`
`
`David McCombs and David O’Dell
`David.mccombs.ipr@haynesboone.com
`David.odell.ipr@haynesboone.com
`Haynes and Boone, LLP
`2323 Victory Avenue, Suite 700
`Dallas, Texas 75219
`
`
`
`
`
`
`
`
`
`Dated: _ April 22, 2014___
`
`
`
`
`
`
`
`
`
`_/s/ Michael E. Sander __
`Michael E. Sander
`Reg. No. 71,667
`msander@kenyon.com
`KENYON & KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel: 212-425-7200
`
`
`
`
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