`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
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`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
`__________________
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`PATENT OWNER THE TRUSTEES OF
`COLUMBIA UNIVERSITY IN THE CITY OF NEW YORK'S
`OBJECTIONS TO EVIDENCE SERVED WITH REPLY
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Case IPR2015-00375 of
`U.S. Patent No. 8,074,115
`Patent owner, The Trustees of Columbia University in the City of New York
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`("Columbia"), hereby objects to the admissibility of certain evidence submitted or
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`cited in support of Petitioner's Reply, filed January 8, 2016. Columbia's objections
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`are based on the Federal Rules of Evidence ("FRE"), relevant case law and PTAB
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`Rules, as further detailed below.
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`Columbia objects to paragraphs 5-7, 9-14, 17-21 of Exhibit 1015 as not
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`relevant or unduly prejudicial because these paragraphs raise new arguments
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`outside the scope of the Petition, are inconsistent with arguments in the original
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`declaration, and any probative value is substantially outweighed by a danger of
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`unfair prejudice. See, e.g., FRE 401-403. Columbia further objects to these
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`paragraphs as conclusory, mischaracterizing evidence of records, and lacking the
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`requisite indicia of reliability. See FRE 702.
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`Columbia objects to Exhibit 1016 as not authentic or original because there
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`is no indication of the origin of the paper. See, e.g., FRE 901(a), 1002.
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`Columbia objects to Exhibit 1017 as incomplete, out of context and
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`therefore unfairly prejudicial See, e.g., FRE 106, 403.
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`Respectfully submitted,
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` /
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` Hong A. Zhong /
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`
`Hong A. Zhong (Reg. No. 66,530)
`Irell & Manella LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067-4276
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`Date: January 15, 2016
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`Case IPR2015-00375 of
`U.S. Patent No. 8,074,115
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. 42.6, the undersigned certifies that on January 15,
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`2016, a copy of the foregoing document was served upon the following, by
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`ELECTRONIC MAIL:
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`Brian M. Hoffman
`bhoffman@fenwick.com
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`Michael Sacksteder
`msacksteder@fenwick.com
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`Fenwick & West LLP
`555 California Street
`12th Floor
`San Francisco, CA 94104
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`/s/ Susan M. Langworthy /
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