Served January 21, 2015
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`—————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`—————
`
`WEBASTO ROOF SYSTEMS, INC.
`Petitioner,
`
`v.
`
`UUSI, LLC
`Patent Owner.
`
`—————
`
`Case IPR2014-00650
`Patent 7,579,802
`
`—————
`
`PETITIONER’S OBJECTIONS TO EVIDENCE SUBMITTED
`WITH PATENT OWNER’S RESPONSE TO THE PETITION
`
`Attorney Docket: 130163.231151
`
`
`
`1
`
`Webasto Exhibit 1037
`Webasto Roof Systems, Inc. v. UUSI, LLC, IPR 2014-00650
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`—————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`—————
`
`WEBASTO ROOF SYSTEMS, INC.
`Petitioner,
`
`v.
`
`UUSI, LLC
`Patent Owner.
`
`—————
`
`Case IPR2014-00650
`Patent 7,579,802
`
`—————
`
`PETITIONER’S OBJECTIONS TO EVIDENCE SUBMITTED
`WITH PATENT OWNER’S RESPONSE TO THE PETITION
`
`Attorney Docket: 130163.231151
`
`
`
`1
`
`Webasto Exhibit 1037
`Webasto Roof Systems, Inc. v. UUSI, LLC, IPR 2014-00650
`
`
`
`Served January 21, 2015
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner Webasto Roof Systems, Inc.
`
`(“WRSI”) objects to the evidence submitted by Patent Owner UUSI, LLC with
`
`Patent Owner’s Response to the Petition.
`
`Petitioner objects to paragraphs 6, 18–21, 23–26, 41–45, 47-50, 51-53, 55-
`
`59, 61-73, 75, 77-79, 81-255 of the Declaration of Dr. Mark Ehsani in Support of
`
`Patent Owner’s Response, Ex. 2001, because this testimony fails to meet the
`
`standards of admissibility under Fed. R. Evid. 702, Daubert v. Merrell Dow
`
`Pharm., Inc., 509 U.S. 579 (1993), and 37 C.F.R. § 42.65.
`
`Petitioner also objects to the following exhibits on the bases set forth below.
`
`Exhibit
`
`2004
`
`2005
`
`2006
`
`Objection(s)
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is not relied on in Patent Owner’s Response or in Patent
`Owner’s expert’s Declaration of Dr. Mark Ehsani in Support of Patent
`Owner’s Response and is therefore not a proper exhibit.
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is not relied on in Patent Owner’s Response or in Patent
`Owner’s expert’s Declaration of Dr. Mark Ehsani in Support of Patent
`Owner’s Response and is therefore not a proper exhibit.
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is not relied on in Patent Owner’s Response or in Patent
`Owner’s expert’s Declaration of Dr. Mark Ehsani in Support of Patent
`Owner’s Response and is therefore not a proper exhibit.
`
`1
`
`2
`
`Webasto Exhibit 1037
`Webasto Roof Systems, Inc. v. UUSI, LLC, IPR 2014-00650
`
`
`
`Served January 21, 2015
`
`Exhibit
`
`2007
`
`2008
`
`2009
`
`Objection(s)
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is not relied on in Patent Owner’s Response or in Patent
`Owner’s expert’s Declaration of Dr. Mark Ehsani in Support of Patent
`Owner’s Response and is therefore not a proper exhibit.
`Exhibit is inadmissible hearsay.
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is not relied on in Patent Owner’s Response or in Patent
`Owner’s expert’s Declaration of Dr. Mark Ehsani in Support of Patent
`Owner’s Response and is therefore not a proper exhibit.
`Exhibit is inadmissible hearsay.
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is not relied on in Patent Owner’s Response or in Patent
`Owner’s expert’s Declaration of Dr. Mark Ehsani in Support of Patent
`Owner’s Response and is therefore not a proper exhibit.
`
`2010
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2011
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit contains hearsay.
`
`2012
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2013
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is not authenticated or adequately described.
`Exhibit is not relied on in Patent Owner’s Response or in Patent
`Owner’s expert’s Declaration of Dr. Mark Ehsani in Support of Patent
`Owner’s Response and is therefore not a proper exhibit.
`
`2
`
`3
`
`Webasto Exhibit 1037
`Webasto Roof Systems, Inc. v. UUSI, LLC, IPR 2014-00650
`
`
`
`Served January 21, 2015
`
`Exhibit
`
`2014
`
`Objection(s)
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is not authenticated or adequately described.
`Exhibit is not relied on in Patent Owner’s Response or in Patent
`Owner’s expert’s Declaration of Dr. Mark Ehsani in Support of Patent
`Owner’s Response and is therefore not a proper exhibit.
`
`2015
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is inadmissible hearsay.
`
`2016
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2017
`
`2018
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is incomplete.
`
`Exhibit is not evidence and is therefore not a proper exhibit.
`Exhibit is not relied on in Patent Owner’s Response or in Patent
`Owner’s expert’s Declaration of Dr. Mark Ehsani in Support of Patent
`Owner’s Response and is therefore not a proper exhibit.
`
`2019
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2020
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2021
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2022
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2023
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2024
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2025
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2026
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2027
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`3
`
`4
`
`Webasto Exhibit 1037
`Webasto Roof Systems, Inc. v. UUSI, LLC, IPR 2014-00650
`
`
`
`Served January 21, 2015
`
`Exhibit
`
`Objection(s)
`
`2028
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2029
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2030
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`
`2032
`
`2033
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is not relied on in Patent Owner’s Response or in Patent
`Owner’s expert’s Declaration of Dr. Mark Ehsani in Support of Patent
`Owner’s Response and is therefore not a proper exhibit.
`
`Exhibit is irrelevant to the unpatentability of the claims at issue.
`Exhibit is not relied on in Patent Owner’s Response or in Patent
`Owner’s expert’s Declaration of Dr. Mark Ehsani in Support of Patent
`Owner’s Response and is therefore not a proper exhibit.
`
`
`
`Dated: January 21, 2015
`
`Respectfully submitted,
`
`
`
`/s/ Charles H. Sanders
`Charles H. Sanders
`Reg. No. 47,053
`
`Counsel for Petitioner
`Webasto Roof Systems, Inc.
`
`4
`
`5
`
`Webasto Exhibit 1037
`Webasto Roof Systems, Inc. v. UUSI, LLC, IPR 2014-00650
`
`
`
`Served January 21, 2015
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Objections to
`
`Evidence Submitted With Patent Owner’s Response to the Petition was served on
`
`January 21, 2015, by email directed to the attorneys of record for Patent Owner at
`
`the following addresses:
`
`Monte L. Falcoff (mlfalcoff@hdp.com)
`Hemant M. Keskar (hkeskar@hdp.com)
`HARNESS, DICKEY & PIERCE, P.L.C.
`
`Dated: January 21, 2015
`
`
`
`
`
`/s/ Charles H. Sanders
`Charles H. Sanders
`Reg. No. 47,053
`
`Counsel for Petitioner
`Webasto Roof Systems, Inc.
`
`5
`
`6
`
`Webasto Exhibit 1037
`Webasto Roof Systems, Inc. v. UUSI, LLC, IPR 2014-00650
`
`
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