`Merchant & Gould P.C.
`3200 IDS Center
`80 South 8th Street
`Minneapolis, MN 55402
`Tel: (612) 332-5300
`Fax: (612) 332-9081
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CARDIOCOM, LLC
`Petitioner
`
`v.
`
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
`Patent Owner
`____________
`
`Case IPR2013-00468
`Patent 7,516,192
`____________
`
`JOINT OBJECTIONS TO DEMONSTRATIVES
`
`
`
`
`
`
`
`The parties hereby submit this joint disclosure of objections to
`
`demonstratives. The parties met and conferred and could not reach agreement.
`
`1) Petitioner objects to Patent Owner’s Demonstrative Nos. 3, 4, and 37 as
`
`containing new legal arguments related to the never-before cited
`
`Cyclobenziprine, Fritch, and Unigene cases, respectively.
`
`2) Petitioner objects to Patent Owner’s Demonstrative Nos. 51-52, 54-55, 57-58
`
`and 61-69 because these demonstratives rely on objected-to evidence.
`
`3) Petitioner objects to Patent Owner’s Demonstrative Nos. 54, 63, 66, 67 and 69
`
`as displaying exhibits not specifically discussed in any papers.
`
`4) Petitioner objects to Patent Owner’s Demonstratives, generally, as additional
`
`briefing because they are far too numerous for the limited oral argument.
`
`1) Patent Owner objects that Petitioner’s demonstrative nos. 25, 33, 40, and 45
`
`improperly raise new arguments not set forth in Petitioner’s Petition or Reply
`
`and nos. 38 and 42 improperly raise arguments not set forth in the Petition.
`
`2) Patent Owner further objects that demonstrative nos. 8, 22, 30, and 32
`
`improperly included new evidence in the form of citations that were not
`
`included in Petitioner’s Petition or Reply.
`
`3) Patent Owner further objects that demonstrative nos. 3, 12, and 17 misleadingly
`
`mischaracterize the parties’ positions or the evidence.
`
`4) Patent Owner reserves its objections pursuant to its pending motion to exclude.
`
`1
`
`
`
`Date: September 5, 2014
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`/Daniel W. McDonald/
`Daniel W. McDonald, Reg. No. 32,044
`Attorneys for Petitioner Cardiocom
`
`
`
`
`
`/Don Daybell/
`Don Daybell, Reg. No. 50,877
`Attorneys for Patent Owner Robert Bosch
`
`
`
`
`
`
`
`2
`
`
`
`Certification of Service
`
`The undersigned hereby certifies that a copy of the foregoing JOINT
`OBJECTIONS TO DEMONSTRATIVES was served on September 5, 2014 by
`filing the document(s) through the Patent Review Processing System and
`delivering by email on counsel of record for the patent owner at the following
`name and address:
`
`Don Daybell (ddaybell@orrick.com)
`Davin M. Stockwell (dstockwell@orrick.com)
`Bas de Blank (basdeblank@orrick.com)
`Lillian Mao (lmao@orrick.com)
`BoschvCardiocom-IPRServiceList@orrick.com
`D2DPTABDocket@orrick.com
`ORRICK, HERRINGTON, &
`SUTCLIFFE LLP
`2050 Main St., Suite 1100
`Irvine, CA 92614
`Tel: 949-567-6700
`Fax: 949-567-6710
`
`
`
`Respectfully submitted,
`
`
`Date: September 5, 2014
`
`
`
`/Daniel W. McDonald/
`Daniel W. McDonald (Lead Counsel)
`USPTO Registration No. 32,044
`
`
`
`
`
`3
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