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UNITED STATES PATENT AND TRADEMARK OFFICE
`—————————————————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`—————————————————
`
`HUGHES NETWORK SYSTEMS, LLC
`and HUGHES COMMUNICATIONS, INC.,
`Petitioner,
`
`v.
`
`CALIFORNIA INSTITUTE OF TECHNOLOGY,
`Patent Owner.
`
`—————————————————
`
`Case IPR2015-00059
`Patent 7,916,781
`
`—————————————————
`
`
`
`PATENT OWNER’S NOTICE OF OBJECTION TO EVIDENCE
`
`
`
`
`
`
`
`CALTECH - EXHIBIT 2032
`
`

`
`Case IPR2015-00059
`Patent 7,916,781
`
`I.
`
`INTRODUCTION
`
`
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner California Institute of
`
`Technology (“Caltech”), submits the following objections to Petitioners Hughes
`
`Network Systems, LLC and Hughes Communications, Inc. (“Petitioner”) Exhibits
`
`1001-1004, 1007-1009, 1012, 1013, 1017-1021, 1023, 1030-1036, 1038-1044,
`
`1046-1063, 1065, and 1066, as listed on Petitioner’s List of Exhibits served on
`
`October 30, 2014. As required by 37 C.F.R. § 42.62, Patent Owner’s objections
`
`below apply the Federal Rules of Evidence (“F.R.E.”).
`
`II. OBJECTIONS
`
`Grounds for Objection: F.R.E. 401 (Test for Relevant Evidence) and/or
`
`F.R.E. 403 (Excluding Relevant Evidence for Prejudice, Confusion, Waste of
`
`Time, or Other Reasons).
`
`Each of the exhibits listed below is not cited in the petition that initiated this
`
`proceeding. As such, each of these exhibits is not relevant to the instituted ground
`
`of review or any other aspect of this proceeding as it has no tendency to make a
`
`fact more or less probable than it would be without the evidence. Moreover, each
`
`of these exhibits is additionally not relevant to the instituted ground because any
`
`asserted facts to which the exhibit relates are of no consequence in determining this
`
`proceeding.
`
`Caltech objects to each of the following exhibits on this basis:
`• Ex. 1001
`• Ex. 1002
`• Ex. 1003
`
`-1-
`
`

`
`Case IPR2015-00059
`Patent 7,916,781
`• Ex. 1004
`• Ex. 1007
`• Ex. 1008
`• Ex. 1009
`• Ex. 1012
`• Ex. 1013
`• Ex. 1017
`• Ex. 1018
`• Ex. 1019
`• Ex. 1020
`• Ex. 1021
`• Ex. 1023
`• Ex. 1030
`• Ex. 1031
`• Ex. 1032
`• Ex. 1033
`• Ex. 1034
`• Ex. 1035
`• Ex. 1036
`• Ex. 1038
`• Ex. 1039
`• Ex. 1040
`• Ex. 1041
`
`
`
`-2-
`
`
`
`
`
`

`
`Case IPR2015-00059
`Patent 7,916,781
`• Ex. 1042
`• Ex. 1043
`• Ex. 1044
`• Ex. 1046
`• Ex. 1047
`• Ex. 1048
`• Ex. 1049
`• Ex. 1050
`• Ex. 1051
`• Ex. 1052
`• Ex. 1053
`• Ex. 1054
`• Ex. 1055
`• Ex. 1056
`• Ex. 1057
`• Ex. 1058
`• Ex. 1059
`• Ex. 1060 (Objection to paragraphs 13-38 and 40-83 only)
`• Ex. 1061
`• Ex. 1062
`• Ex. 1063
`• Ex. 1065
`• Ex. 1066
`
`
`
`-3-
`
`
`
`
`
`

`
`Case IPR2015-00059
`Patent 7,916,781
`
`III. CONCLUSION
`
`
`
`The above referenced exhibits were filed on October 14, 2014, and this
`
`proceeding was instituted on April 27, 2015. These objections are made within ten
`
`Respectfully submitted,
`
`/Michael T. Rosato/
`Michael T. Rosato, Lead Counsel
`Reg. No. 52,182
`
`
`
`business days of institution.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Date: May 11, 2015
`
`
`
`
`
`
`
`
`
`
`
`-4-
`
`
`
`

`
`
`
`
`
`Case IPR2015-00059
`Patent 7,916,781
`
`CERTIFICATE OF SERVICE
`
`I certify that the foregoing Patent Owner’s Notice of Objection to Evidence
`
`was served on this 11th day of May, 2015, on the Petitioner at the correspondence
`
`Respectfully submitted,
`
`/Michael T. Rosato/
`Michael T. Rosato, Lead Counsel
`Reg. No. 52,182
`
`address of the Petitioner as follows:
`
`
`Eliot D. Williams
`G. Hopkins Guy
`BAKER BOTTS LLP
`1001 Page Mill Road
`Palo Alto, CA 94304
`eliot.williams@bakerbotts.com
`hop.guy@bakerbotts.com
`
`
`
`
`
`Date: May 11, 2015
`
`
`
`-5-

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