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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`Google Inc. and Motorola Mobility LLC,
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`Petitioners,
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`v.
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`Arendi S.A.R.L.,
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`Patent Owner.
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`____________
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`Case No. IPR2014-00452
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`Patent No. 6,323,853
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`____________
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`PATENT OWNER ARENDI S.A.R.L.’S OBJECTIONS TO EVIDENCE
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`PURSUANT TO 37 C.F.R. § 42.64
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`1
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`Pursuant to 37 C.F.R. §42.64(b)(1), the undersigned, on behalf of Patent
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`Owner Arendi S.A.R.L. (“Arendi” or “Patent Owner”) hereby submits the
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`following objections to Exhibit 1012 and Exhibit 1002, which were attached to the
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`Petition for Inter Partes Review.
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`Ex. 1012 is objected to as not having been authenticated as required by
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`Federal Rule of Evidence 901 or 902. Ex. 1012 is further objected to on the
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`grounds that it is irrelevant in the absence of an established publication date. Ex.
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`1012 is further objected to on the grounds of hearsay. Ex. 1012 is further objected
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`to for failure to establish that the document has ever been published.
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`In Ex. 1002, paragraph 32 (except for its first sentence) is objected to for
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`presenting inadmissible evidence after its first sentence. This paragraph seeks to
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`enter evidence from inadmissible Ex. 1012 without authenticating the exhibit,
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`without laying a proper foundation, without establishing a publication date and
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`thus without demonstrating relevance.
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`These objections are being timely served within 10 business days of the
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`institution of the present inter partes review trial.
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`
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`Date: September 2, 2014
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` Respectfully submitted,
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` /Robert Asher, #30,445 /
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` Robert Asher
`2
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`
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`Registration No. 30,445
`Bruce D. Sunstein
`Registration No. 27,234
`Sunstein Kann Murphy & Timbers LLP
`125 Summer Street
`Boston, MA 02110
`Tel: (617) 443-9292
`Fax: (617) 443-0004
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`
`
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`3
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`CERTIFICATE OF SERVICE
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` It is certified that on September 2, 2014, copies of the PATENT OWNER
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`ARENDI S.A. R.L.’s OBJECTIONS TO EVIDENCE PURSUANT TO 37 C.F.R.
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`§ 42.64 have been served on Petitioner as provided in 37 C.F.R. § 42.6(e) via
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`electronic mail transmission addressed to the persons at the following addresses:
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`transmission addressed to the persons at the following addresses:
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`LEAD COUNSEL FOR
`PETITIONERS MOTOROLA
`MOBILITY, LLC and GOOGLE, INC.
`
`MATTHEW A. SMITH
`smith@turnerboyd.com
`Registration No. 49,003
`TURNER BOYD LLP
`702 Marshall St., Ste. 640
`Redwood City, CA 94063
`Tel: (650) 265-6109
`Fax: (650) 521-5931
`
`
`BACK-UP COUNSEL FOR
`PETITIONERS MOTOROLA
`MOBILITY, LLC and GOOGLE, INC.
`
`ZHUANJIA GU
`gu@turnerboyd.com
`Registration No. 51,758
`TURNER BOYD LLP
`702 Marshall St., Ste. 640
`Redwood City, CA 94063
`Tel: (650) 529-4752
`Fax: (650) 521-5931
`and
`kent@turnerboyd.com
`docketing@turnerboyd.com
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`
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`Date: September 2, 2014
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` /Robert Asher, #30,445 /
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` Robert Asher
`Registration No. 30,445
`Sunstein Kann Murphy & Timbers LLP
`125 Summer Street
`Boston, MA 02110
`Tel: (617) 443-9292
`Fax: (617) 443-0004
`
`4
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