`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`
`CISCO SYSTEMS, INC., CIENA CORPORATION,
`CORIANT OPERATIONS, INC., CORIANT (USA) INC., AND
`FUJITSU NETWORK COMMUNICATIONS, INC.
`Petitioner
`
`v.
`
`CAPELLA PHOTONICS, INC.
`Patent Owner
`
`___________________
`
`Cases IPR2014-011661 and IPR2014-012762
`Patents RE42,368 and RE42,678
`___________________
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`1 Case IPR2015-00816 has been joined with this proceeding.
`2 Case IPR2015-00894 has been joined with this proceeding.
`3 The word-for-word identical paper is filed in each proceeding identified in
`the heading.
`
`PATENT OWNER’S OBJECTIONS TO
`PETITIONER’S DEMONSTRATIVES3
`
`
`
`
`
`
`
`
`
`Case IPR2014-01166 of Patent RE42,368
`Case IPR2014-01276 of Patent RE42,678
`
`Objection to Slides 3-23
`
`Petitioner adds new argument in excess of the limited briefing the Board
`
`previously allowed in its September 18, 2015 Order (1166 Paper 28, 1276 Paper
`
`22) by adding, for example, new argument related to claim 28 and whether the
`
`relevant disclosure was carried forward.
`
`Pursuant to the Board’s Order of October 8, 2015, these objections are
`
`timely made at least two business days before the November 5, 2015 Oral Hearing.
`
`Date: November 3, 2015
`
`
`
` Respectfully submitted,
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`
`
`/Jason D. Eisenberg /
`
`Jason D. Eisenberg
`Registration No. 43,447
`Attorney for Patent Owner –
`Capella Photonics, Inc.
`
`
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
`
`
`
`- 1 -
`
`
`
`Case IPR2014-01166 of Patent RE42,368
`Case IPR2014-01276 of Patent RE42,678
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing PATENT OWNER’S
`
`OBJECTIONS TO PETITIONER’S DEMONSTRATIVES was served
`
`electronically via e-mail in its entirety on November 3, 2015 upon the following
`
`counsel for Petitioner:
`
`Wayne O. Stacy
`Matthew J. Leary
`Matthew J. Moore
`Robert Steinberg
`Christopher Chalsen
`Nathaniel Browand
`Lawrence T. Kass
`Suraj Balusu
`Thomas K. Pratt
`J. Pieter van Es
`Jordan N. Bodner
`Michael S. Cuviello
`
`wstacy@cooley.com
`CapellaCisco@cooley.com
`Matthew.Moore@lw.com
`Bob.Steinberg@lw.com
`CChalsen@milbank.com
`NBrowand@milbank.com
`LKass@milbank.com
`SBalusu@milbank.com
`TPratt@bannerwitcoff.com
`PvanEs@bannerwitcoff.com
`JBodner@bannerwitcoff.com
`MCuviello@bannerwitcoff.com
`
`
`
`Date: November 3, 2015
`
`
`
`
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/Jason D. Eisenberg/
`
`Jason D. Eisenberg
`Registration No. 43,447
`Attorney for Patent Owner –
`Capella Photonics, Inc.
`
`
`
`
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
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