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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`ORACLE CORPORATION, NETAPP INC. and
`HUAWEI TECHNOLOGIES CO., LTD.
`
`Petitioners,
`
`v.
`
`CROSSROADS SYSTEMS, INC.
`
`Patent Owner.
`
`____________
`
`Case IPR2014-01209
`
`U.S. Patent No. 7,051,147
`
`____________
`
`
`
`
`
`JOINT LIST OF OBJECTIONS TO
`DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`
`
`
`
`
`
`

`
`
`Petitioners’ Objections to Patent Owner’s Demonstrative Exhibits
`
`1) The following slides contain new argument never previously made by Patent
`
`Owner: Slides 15-19, 91-93, 136, 138.
`
`2) The following slides cite to, and contain new argument improperly made by
`
`Patent Owner in, Patent Owner’s Motion to Exclude: 21-23, 125, 163.
`
`3) The following slides cite to evidence never previously cited to support the
`
`referenced argument: 159-60.
`
`4) The following slides cite evidence subject to Petitioners’ Motion to Exclude:
`
`124, 143.
`
`Patent Owner’s Objections to Petitioners’ Demonstratives Exhibits
`
`1) The following slides contain new arguments never previously made by
`
`Petitioners: Slides 8 and 25 (second bullet point); Slides 13, 14, 15, 25, 27, 28
`
`(title); Slides 26, 29, 30, 45, and 46 (entire slide); Slide 23 (entire slide except
`
`title).
`
`2) The following slides cite to evidence never previously cited: Slide 26; or never
`
`previously cited to support the referenced argument: Slides 18, 20, 30, 46.
`
`3) The following slides cite evidence subject to Patent Owner’s motion to exclude,
`
`and reference testimony that should in fairness under FRE 106 be considered
`
`with additional testimony as stated in Patent Owner’s motion to exclude: Slides
`
`14, 15, 27, 28, 49.
`
`
`
`1
`
`

`
`
`Respectfully submitted,
`
`
`
`Date: October 28, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By:
`
`
`
`
`
`
`
`
`
`2
`
`
`
` /Greg H. Gardella/
`Greg H. Gardella
`Reg. No. 46,045
`Counsel for Petitioner
`
`
`
`
`
`/James H. Hall/
`James H. Hall
`Reg. No. 66,317
`Counsel for Patent Owner
`
`

`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies service of JOINT
`
`LIST OF OBJECTIONS TO DEMONSTRATIVE EXHIBITS on the counsel of
`
`record for the Patent Owner by filing this document through the Patent Review
`
`Processing System as well as delivering a copy via electronic mail to the following
`
`address:
`
`Steven Sprinkle
`John Adair
`Scott Crocker
`SPRINKLE IP LAW GROUP
`crossroadsipr@sprinklelaw.com
`
`Russell Wong
`James H. Hall
`Keith Rutherford
`BLANK ROME LLP
`CrossroadsIPR@blankrome.com
`
`
`
`
`
`Dated: October 28, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Greg H. Gardella/
`Greg H. Gardella (Reg. No. 46,045)
`
`
`
`
`
`3

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