`IPR2014-00898
`110900-0004-657
`U.S. Patent No. 7,151,027
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`MACRONIX INTERNATIONAL CO., LTD., MACRONIX ASIA LIMITED,
`MACRONIX (HONG KONG) CO., LTD., and MACRONIX AMERICA, INC.
`Petitioner
`
`v.
`
`SPANSION LLC
`Patent Owner
`______________
`
`Case IPR2014-00898
`Patent 7,151,027 B1
`______________
`
`Before the Honorable DEBRA K. STEPHENS, JUSTIN T. ARBES, and RICHARD
`E. RICE, Administrative Patent Judges.
`
`PATENT OWNER SPANSION LLC’S SECOND SET OF OBJECTIONS
`TO PETITIONERS’ EXHIBITS
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), the undersigned, on behalf of and acting in
`
`
`
`a representative capacity for Patent Owner, Spansion LLC (“Patent Owner”), hereby
`
`submits the following objections to Petitioners Macronix International Co., Ltd.’s,
`
`Macronix Asia Limited’s, Macronix (Hong Kong) Co., Ltd.’s, and Macronix America,
`
`Inc.’s (collectively “Petitioners”) Exhibit MX027II-1002, Exhibit MX027II-1007,
`
`Exhibit MX027II-1008, and any reference to/reliance on the foregoing. As required
`
`by 37 C.F.R § 42.62, Patent Owner’s objections below apply the Federal Rules of
`
`Evidence (“F.R.E.”).
`
`
`
`Spansion Exhibit 2015
`Macronix et al v. Spansion
`IPR2014-00898
`Page 00001
`
`
`
`IPR2014-00898
`U.S. Patent No. 7,151,027
`
`
`Attorney Docket No
`110900-0004-657
`
`I.
`
`All Previous Objections to Exhibits Maintained
`
`Petitioner maintains and asserts all previous objections stated in Patent Owner
`
`Spansion LLC’s First Set of Objections to Petitioners’ Exhibits, as Petitioners’ newly
`
`served document does not cure, and is itself subject to, those objections.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`September 15, 2014
`
`By:/J. Steven Baughman/
`J. Steven Baughman (Lead Counsel)
`Gabrielle E. Higgins (Backup Counsel)
`Reg. No. 47,414
`Reg. No. 38,916
`ROPES & GRAY LLP
`ROPES & GRAY LLP
`One Metro Center, 700 12th St. – Ste. 900
`1900 University Avenue – Suite 600
`East Palo Alto, CA 94303
`Washington, DC 20005-3948
`P: 650-617-4000 /F: 650-617-4090
`P: 202-508-4606 / F: 202-383-8371
`steven.baughman@ropesgray.com
`gabrielle.higgins@ropesgray.com
`
`Mailing address for all PTAB correspondence: ROPES & GRAY LLP
`IPRM – Floor 43, Prudential Tower, 800 Boylston Street, Boston, MA 02199-3600
`
`Attorneys for Patent Owner, Spansion LLC
`
`
`
`
`
`
`
`
`
`2
`
`Page 00002
`
`
`
`IPR2014-00898
`U.S. Patent No. 7,151,027
`CERTIFICATE OF SERVICE
`
`
`
`Attorney Docket No
`110900-0004-657
`
`
`
`The undersigned hereby certifies that a copy of PATENT OWNER
`
`SPANSION LLC’S SECOND SET OF OBJECTIONS TO PETITIONERS’
`
`EXHIBITS has been served in its entirety by causing the aforementioned document
`
`to be electronically mailed, pursuant to the Petitioner and Patent Owner’s agreement,
`
`to the following attorneys of record for the Petitioner listed below:
`
`
`Petitioner’s Counsel
`of Record:
`
`
`Michael M. Murray (mmurray@winston.com)
`Michael J. Scheer (mscheer@winston.com)
`WINSTON & STRAWN LLP
`200 Park Ave.
`New York, NY 10166
`
`Andrew R. Sommer (ASommer@winston.com)
`Vivian S. Kuo (VKuo@winston.com)
`WINSTON & STRAWN LLP
`1700 K Street, N.W.
`Washington, DC 20006-3817
`
`
`Dated:
`
`September 15, 2014
`
`/Jordan M. Rossen/
`
`
`
`
`
`
`ROPES & GRAY LLP
`
`3
`
`Page 00003
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`
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