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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`FORD MOTOR COMPANY, INC.
`Petitioner
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`v.
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`PAICE LLC & THE ABELL FOUNDATION, INC.
`Patent Owner
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`Case IPR2014-00904
`Patent 7,237,634
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`PATENT OWNER’S NOTICE OF OBJECTIONS TO EVIDENCE
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`Case IPR2014-00904
`Attorney Docket No: 36351-0015IP1
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner, Paice and The Abell
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`Foundation, Inc. (“Patent Owner”), hereby submits its notice of objections to
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`certain evidence that Petitioner, Ford Motor Company, Inc. (“Petitioner”),
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`submitted in connection with IPR2014-00904.
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`Testimony of Dr. Davis
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`Patent Owner objects to certain testimony of Dr. Davis submitted as part of
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`Exhibit FORD 1044 (Declaration of Dr. Gregory Davis). Specifically, Patent
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`Owner objects to paragraphs 8-17, 21-23, and 27-29 of Exhibit FORD 1044 to the
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`extent Dr. Davis offers factual observations without laying foundation or otherwise
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`demonstrating personal knowledge (FRE 602, 702, 703).
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`Patent Owner reserves its right to further challenge Dr. Davis’s testimony
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`based on a deposition of Dr. Davis.
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`Case IPR2014-00904
`Attorney Docket No: 36351-0015IP1
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`Patent Owner reserves the right to move to exclude the noted testimony and
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`exhibits.
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`Date: May 22, 2015
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`Respectfully submitted,
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` /Timothy W. Riffe/
`Timothy W. Riffe Reg. No. 43,881
`Kevin E. Greene Reg. No. 46,031
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`Case IPR2014-00904
`Attorney Docket No: 36351-0015IP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(4)(i) et seq. and 42.105(b), the undersigned
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`certifies that on May 22 2015, a complete and entire copy of this Patent Owner’s
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`Notice of Objections to Evidence was provided via electronic mail to Counsel for
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`Petitioner by serving the correspondence address of record as follows:
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`Frank A. Angileri
`Brooks Kushman P.C.
`1000 Town Center
`Twenty-Second Floor
`Southfield, Michigan 48075
`Email: FPGP0104IPR1@brookskushman.com
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`Lissi Mojica
`Kevin Greenleaf
`Dentons US LLP
`1530 Page Mill Road
`Suite 200
`Palo Alto, California 94304-11251
`Email: lissi.mojica@dentons.com
`Email: kevin.greenleaf@dentons.com
`Email: iptdocketchi@dentons.com
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`/Susan C. Johnson/
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`Susan C. Johnson
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(214) 292-4086
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