`
`Broadcom v. Wi-Fi One, LLC
`IPR2013-00601
`Exhibit 2023
`
`Broadcom v. Wi-Fi One, LLC
`IPR2013-00601
`Exhibit 2023
`
`
`
`Mary Ann Morgan
`
`From:
`Sent:
`To:
`
`Cc:
`Subject:
`Attachments:
`
`Please see attached.
`
`Mary Ann Morgan
`Tuesday, October 7, 2014 4:49 PM
`'dominic.massa@wilmerhale.com'; 'michael.diener@wilmerhale.com'
`
`Peter Ayers; John Shumaker
`Broadcom/Ericsson — |PR2013-00601 - Patent Owner's Objections to Petitioner's Exhibits
`Patent Owner's Objections to Petitioner's Exhibitspdf
`
`Mary Ann Morgan
`Litigation Paralegal
`MamannMgQLeel—Iayescoml www.LeeHayes.com
`
`P 512.605.0259 F 509.323.8979
`
`13809 Research Blvd., Suite 405
`Austin, Texas 78750
`
`Lee 8. Hayes | Advisors for the Knowledge Economy
`Follow us! Twitt_e_r II Linked In
`
`NOTE: This email and any attachments contain information from the law firm of Lee & Hayes, pllc, that is confidential and/or subject to the attorney-client privilege
`If you are not the intended recipient of this message, please do not read it or disclose it to others. Instead, please delete it and notify the sender immediately.
`
`1
`
`Broadcom v. Wi-Fi One, LLC
`|PR2013-00601
`Exhibit 2023
`
`Broadcom v. Wi-Fi One, LLC
`IPR2013-00601
`Exhibit 2023
`
`
`
`Paper No.
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`BROADCOM CORPORATION
`
`Petitioner
`
`V.
`
`WI-FI ONE, LLC
`Patent Owner
`
`
`Case IPR2013-00601
`
`Patent 6,772,215
`
`
`PATENT OWNER’S OBJECTIONS TO PETITIONER’S EXHIBITS
`
`PURSUANT TO 37 C.F.R. § 42.64(b)(1)
`
`Broadcom v. Wi-Fi One, LLC
`IPR2013-00601
`Exhibit 2023
`
`Broadcom v. Wi-Fi One, LLC
`IPR2013-00601
`Exhibit 2023
`
`
`
`Case IPR2013-00601
`
`Patent 6,772,215
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner submits the following
`
`objection to Petitioner’s Exhibit Nos. 1010 and 1013, which were served by
`
`Petitioner on October 1, 2014. This objection is timely, having been served within
`
`five business days. See id.
`
`Exhibit
`
`Federal
`
`No.
`
`1010
`
`Rule of
`Civil
`
`Procedure
`
`401, 402,
`403
`
`Objecti0n(s)
`
`. Not relevant, waste of time, not helpful to trier of
`fact, does not respond to argument raised in
`patent owner response, waived by not included in
`petition
`
`802
`
`Hearsay, offering out of court statement to prove
`truth of matter asserted
`
`1013, 11 7
`
`901
`401, 402,
`403, 702,
`703
`
`Document not authenticated
`Not relevant, waste of time, not helpful to trier of
`fact, does not respond to argument raised in
`patent owner response, waived by not included in
`petition
`
`802
`
`Hearsay, offering out of court statement to prove
`truth of matter asserted
`
`In view of the foregoing objections, Patent Owner also objects to any
`
`testimony or argument in Petitioner’s Reply to Patent Owner’s Response under 37
`
`C.F.R. § 42.120, Paper No. 49, purporting to rely on any of Petitioner’s Exhibit
`
`Broadcom v. Wi-Fi One, LLC
`IPR2013-00601
`Exhibit 2023
`
`Broadcom v. Wi-Fi One, LLC
`IPR2013-00601
`Exhibit 2023
`
`
`
`Case IPR2013-00601
`
`Patent 6,772,215
`
`No. 1010 and 11 7 of Petitioner’s Exhibit No. 1013. Patent Owner also objects to
`
`Petitioner’s Exhibit No. 1010 and 11 7 of Petitioner’s Exhibit No. 1013 as improper
`
`reply evidence. See 37 CPR. § 42.23(b).
`
`LEE & HAYES PLLC
`
`Mb
`
`Peter J. Ayers, Reg. No. 38,374
`John Shumaker, Reg. No. 52,223
`LEE & HAYES, PLLC
`’
`
`13809 Research Blvd., Suite 405
`
`Austin, TX 78750
`Phone: (512) 605-8162
`Fax: (509) 944-4693
`eter
`leeha esgm
`jshumaker@leehayes.com
`
`J. Christopher Lynch, Reg. No. 34,216
`LEE & HAYES, PLLC
`601 W. Riverside Ave., Suite 1400
`
`Spokane, WA 99201
`Telephone: 509.324.9256
`Fax: 509.323.8979
`
`chris@leehayes.com
`
`Counsel for Patent Owner
`
`Broadcom v. Wi-Fi One, LLC
`IPR2013-00601
`Exhibit 2023
`
`Broadcom v. Wi-Fi One, LLC
`IPR2013-00601
`Exhibit 2023
`
`
`
`Case IPR2013-00601
`
`Patent 6,772,215
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on October 7, 2014 the foregoing PATENT
`
`OWNER’S OBJECTIONS TO PETITIONER’S EXPHBITS was served on Lead
`
`and Back-up Counsel for Broadcom Corporation by sending the same Via
`
`electronic mail to the address provided by Broadcom:
`
`Dominic E. Massa, Lead Counsel
`
`Michael A. Diener, Back-up Counsel
`
`Wilmer Cutler Pickering Hale and Dorr, LLP
`
`60 State Street
`
`Boston, MA 02109
`
`LEE & HAYES PLLC
`
`/Peter J. Ayers/
`Peter J. Ayers
`Reg. No. 38,374
`
`Broadcom v. Wi-Fi One, LLC
`IPR2013-00601
`Exhibit 2023
`
`Broadcom v. Wi-Fi One, LLC
`IPR2013-00601
`Exhibit 2023
`
`
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