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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`NORMAN INTERNATIONAL, INC.,
`Petitioner
`
`v.
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`HUNTER DOUGLAS INC.,
`Patent Owner
`
`
`
`
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`CASE IPR2014-01175
`Patent No. 6,968,884 B2
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`
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`
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`Before LINDA M. GAUDETTE, JAMES P. CALVE, and
`HYUN J. JUNG, Administrative Patent Judges.
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`PETITIONER’S OBJECTIONS TO PATENT OWNER’S EVIDENCE
`SUBMITTED AFTER INSTITUTION OF A TRIAL
`UNDER 37 C.F.R. § 42.64(b)(1)
`
`
`
`
`Norman Int., Ex. 1014
`Norman Int. v Hunter Douglas
`IPR2014-01175
`
`
`
`CASE IPR2014-01175
`Petitioner’s Objections to Patent Owner’s Evidence
`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner Norman International, Inc.
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`
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`(“Petitioner”) hereby timely objects to the evidence submitted by Patent Owner
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`with Patent Owner’s Response under 37 C.F.R. § 42.120 (Paper 9) filed May 4,
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`2015, in response to the Board’s Institution Decision (Paper 7) of February 10,
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`2015, which instituted trial for inter partes review of United States Patent No.
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`6,968,884 (“the ’884 patent”). These objections are timely made within five
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`business days of service of evidence.
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`1. Exhibit 2001 filed by Patent Owner is inadmissible under Federal Rule of
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`Evidence (“FRE”) 702 because it fails to demonstrate that Mr. Corey has
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`special knowledge, skill, experience, training, or education in the relevant
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`field of art of the ’884 patent. Instead, Exhibit 2001 merely presents vague,
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`conclusory, and self-serving assertions that fall short of the requirements of
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`FRE 702. (See, e.g. Ex. 2001 at ¶¶ 10, 26, 28.) A close read of Mr. Corey’s
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`own description of his knowledge and experience in his declaration and
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`curriculum vitae reveals that he has no specialized knowledge, skill,
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`experience, training, or education in the use of spring motors and brakes in
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`mechanical and component design. (See Ex. 2001 at ¶ 10; id., Attach. A at 2
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`(describing experience with
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`fabric products
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`instead of mechanical
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`products).) Accordingly, Mr. Corey’s alleged window covering experience
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`has no bearing on the claimed invention of the ’884 patent. Exhibit 2001 is
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`1
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`Norman Int., Ex. 1014
`Norman Int. v Hunter Douglas
`IPR2014-01175
`
`
`
`CASE IPR2014-01175
`Petitioner’s Objections to Patent Owner’s Evidence
`therefore inadmissible because Patent Owner fails to establish or explain
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`why Mr. Corey is qualified to testify regarding the field of invention or the
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`validity of the ’884 patent.
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`2. Exhibit 2001 is further inadmissible under FRE 403 and 702 as unreliable
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`and biased in view of Mr. Corey’s longstanding employment with
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`Comfortex Window Fashions, which is a subsidiary of Patent Owner Hunter
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`Douglas, Inc. (Ex. 2001 at ¶ 10; id., Attach. A at 2.)
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`These objections have been timely made and served within five business
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`
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`days of service of evidence to which the objections are directed.
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`Respectfully submitted,
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`
`
`/Bing Ai /
`Lead Counsel Bing Ai
`Reg. No. 43,312
`
`Backup Counsel Kourtney Mueller Merrill
`Reg. No. 58,195
`
`Attorneys for Norman International, Inc.
`
`2
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`
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`Dated: May 11, 2015
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`
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`PERKINS COIE LLP
`11988 El Camino Real, Suite 350
`San Diego, CA 92130
`(858) 720-5700
`norman-hd-ipr@perkinscoie.com
`
`Norman Int., Ex. 1014
`Norman Int. v Hunter Douglas
`IPR2014-01175
`
`
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`CERTIFICATE OF SERVICE
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`
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`The undersigned hereby certifies that a true copy of the foregoing
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`PETITIONER’S OBJECTIONS TO PATENT OWNER’S EVIDENCE has been
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`served in its entirety this 11th day of May, 2015 by electronic mail as agreed upon
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`by the parties on the Patent Owner via its attorneys of record:
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`KILPATRICK TOWNSEND & STOCKTON LLP
`Kristopher L. Reed (kreed@kilpatricktownsend.com)
`Darin Gibby (dgibby@kilpatricktownsend.com)
`HD-Norman-IPR@kilpatricktownsend.com
`1400 Wewatta Street, Suite 600
`Denver, Colorado 80202
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`
`
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`Respectfully submitted,
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`
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`/Bing Ai/
`Lead Counsel Bing Ai
`Reg. No. 43,312
`
`Backup Counsel Kourtney Mueller Merrill
`Reg. No. 58,195
`
`Attorneys for Norman International, Inc.
`
`Dated: May 11, 2015
`
`
`
`PERKINS COIE LLP
`11988 El Camino Real, Suite 350
`San Diego, CA 92130
`(858) 720-5700
`norman-hd-ipr@perkinscoie.com
`
`
`
`Norman Int., Ex. 1014
`Norman Int. v Hunter Douglas
`IPR2014-01175
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