`By: Herbert D. Hart III
`McAndrews, Held & Malloy, Ltd.
`500 W. Madison St., 34th Floor
`Chicago, IL 60661
`Tel: 312 775-8000
`Fax: 312 775-8100
`E-mail: hhart@mcandrews-ip.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`ERICSSON INC. and TELEFONAKTIEBOLAGET LM ERICSSON,
`Petitioners
`
`v.
`
`INTELLECTUAL VENTURES II LLC
`Patent Owner
`_____________
`
`Case IPR2014-01195
`Patent No. 7,787,431
`_____________
`
`PATENT OWNER’S OBJECTIONS TO EVIDENCE
`SUBMITTED WITH REPLY BRIEF
`
`
`
`Patent Owner’s Objections To Evidence Submitted With Reply Brief
`IPR2014-01195
`U.S. Patent No. 7,787,431
`
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner serves the following
`
`objections to evidence Petitioner submitted with its Reply Brief.
`
`Exhibit
`No.
`
`Title
`
`Objection
`
`1030
`
`H. Newton, Newton’s
`Telecom Dictionary, 16th
`Edition, CMP Books (2000)
`
`1031
`
`Dr. Kenneth Zeger
`Deposition Transcript for
`U.S. Patent No. 7,787,431
`
`1032
`
`H. Holma and A. Toskala,
`WCDMA for UMTS, Radio
`Access for Third Generation
`Mobile Communications,
`John Wiley and Sons, Ltd.
`(2001)
`
`Patent Owner objects to this exhibit to
`the extent that Petitioner previously
`marked the Affidavit of Christopher
`Butler as ERIC-1030.
`
`
`Patent Owner objects to this exhibit to
`the extent that Petitioner previously
`marked the Declaration of Zygmunt J.
`Haas, Ph.D. as ERIC-1031.
`
`
`Patent Owner objects to this exhibit to
`the extent that Petitioner previously
`marked the Declaration of Stephen
`Hayes as ERIC-1032.
`Authenticity: Ex. 1032 is not
`authenticated as required by FRE 901
`and this document is not self-
`authenticating.
`
`Remainder of Related Writing: Ex.
`1032 appears to be an excerpt of a large
`writing and fairness requires that the
`Petitioner should have introduced the
`remainder of the writing at the same
`time as the excerpt was introduced. See
`FRE 106.
`
`Relevance: The contents of Ex. 1032
`have no relevance to the validity of
`
`2
`
`
`
`Patent Owner’s Objections To Evidence Submitted With Reply Brief
`IPR2014-01195
`U.S. Patent No. 7,787,431
`
`
`Exhibit
`No.
`
`Title
`
`Objection
`U.S. Patent No. 7,787,431. FRE 402.
`
`
`These objections are made within five business days from July 14, 2015, the
`
`
`
`date of Petitioner’s submission of its Reply Brief.
`
`
`
`
`Respectfully submitted,
`
`/Herbert D. Hart III/
`Herbert D. Hart III
`Registration No. 30,063
`McAndrews, Held & Malloy, Ltd.
`500 West Madison Street, 34th Floor
`Chicago, Illinois 60661
`Office: (312) 775-8000
`Fax: (312) 775-8100
`Email: hhart@mcandrews-ip.com
`
`Lead Counsel for Patent Owner
`
`
`Dated: July 21, 2015
`
`
`
`
`
`3
`
`
`
`Patent Owner’s Objections To Evidence Submitted With Reply Brief
`IPR2014-01195
`U.S. Patent No. 7,787,431
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that true and correct copies of the foregoing PATENT
`
`OWNER’S OBJECTIONS TO EVIDENCE SUBMITTED WITH REPLY
`
`BRIEF were served on July 21, 2015, via email to counsel for Petitioner at the
`
`following:
`
`
`
`J. Andrew Lowes
`andrew.lowes.ipr@haynesboone.com
`David M. O’Dell
`david.odell.ipr@haynesboone.com
`HAYNES AND BOONE, LLP
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`Date: July 21, 2015
`
`/Herbert D. Hart III/
`Herbert D. Hart III
`
`
`4