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UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`SYMANTEC CORPORATION
`Petitioner
`v.
`THE TRUSTEES OF COLUMBIA UNVERSITY
`IN THE CITY OF NEW YORK
`Patent Owner
`_________________
`Case IPR2015-00375
`Patent No. 8,074,115
`__________________
`
`PATENT OWNER THE TRUSTEES OF
`COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK'S
`OBJECTIONS TO EVIDENCE SERVED WITH REPLY
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`

`
`
`
`Case IPR2015-00375 of
`U.S. Patent No. 8,074,115
`Patent owner, The Trustees of Columbia University in the City of New York
`
`
`
`("Columbia"), hereby objects to the admissibility of certain evidence submitted or
`
`cited in support of Petitioner's Reply, filed January 8, 2016. Columbia's objections
`
`are based on the Federal Rules of Evidence ("FRE"), relevant case law and PTAB
`
`Rules, as further detailed below.
`
`Columbia objects to paragraphs 5-7, 9-14, 17-21 of Exhibit 1015 as not
`
`relevant or unduly prejudicial because these paragraphs raise new arguments
`
`outside the scope of the Petition, are inconsistent with arguments in the original
`
`declaration, and any probative value is substantially outweighed by a danger of
`
`unfair prejudice. See, e.g., FRE 401-403. Columbia further objects to these
`
`paragraphs as conclusory, mischaracterizing evidence of records, and lacking the
`
`requisite indicia of reliability. See FRE 702.
`
`Columbia objects to Exhibit 1016 as not authentic or original because there
`
`is no indication of the origin of the paper. See, e.g., FRE 901(a), 1002.
`
`Columbia objects to Exhibit 1017 as incomplete, out of context and
`
`therefore unfairly prejudicial See, e.g., FRE 106, 403.
`
`Respectfully submitted,
`
` /
`
` Hong A. Zhong /
`
`
`Hong A. Zhong (Reg. No. 66,530)
`Irell & Manella LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067-4276
`
`
`
`
`
`Date: January 15, 2016
`
`
`
`
`- 1 -
`
`

`
`
`
`
`
`
`
`
`
`Case IPR2015-00375 of
`U.S. Patent No. 8,074,115
`
`CERTIFICATE OF SERVICE
`
`
`
`Pursuant to 37 C.F.R. 42.6, the undersigned certifies that on January 15,
`
`2016, a copy of the foregoing document was served upon the following, by
`
`ELECTRONIC MAIL:
`
`
`Brian M. Hoffman
`bhoffman@fenwick.com
`
`
`
`Michael Sacksteder
`msacksteder@fenwick.com
`
`Fenwick & West LLP
`555 California Street
`12th Floor
`San Francisco, CA 94104
`
`
`
`
`
`/s/ Susan M. Langworthy /
`
`
`
`
`
`
`
`- 2 -

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