UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`GOOGLE INC.,
`Petitioner
`
`v.
`
`SUMMIT 6 LLC,
`Patent Owner
`
`
`
`
`Case IPR2015-00806
`Patent No. 7,765,482
`
`
`
`
`
`
`PETITIONER’S OBJECTIONS TO ADMISSIBILITY OF EVIDENCE
`SERVED WITH PATENT OWNER SUMMIT 6 LLC’S RESPONSE TO
`PETITION FOR INTER PARTES REVIEW
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`GOOGLE INC.,
`Petitioner
`
`v.
`
`SUMMIT 6 LLC,
`Patent Owner
`
`
`
`
`Case IPR2015-00806
`Patent No. 7,765,482
`
`
`
`
`
`
`PETITIONER’S OBJECTIONS TO ADMISSIBILITY OF EVIDENCE
`SERVED WITH PATENT OWNER SUMMIT 6 LLC’S RESPONSE TO
`PETITION FOR INTER PARTES REVIEW
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.64(b), Petitioner objects as follows to the
`
`admissibility of evidence served with Patent Owner’s Response filed December 9,
`
`2015.
`
`Evidence
`
`Objection
`
`Exhibit 2044 – iPIX
`Presentation eBay Picture
`Services Stats
`
`Exhibit 2045 –eBay
`Presentation – Jeff Jordan,
`Senior Vice President,
`
`
`
`
`FRE 402: The exhibit is not relevant to any ground
`upon which trial was instituted. For example,
`Patent Owner has failed to demonstrate a sufficient
`nexus between the purported secondary
`considerations of non-obviousness allegedly
`disclosed in the exhibit and the invention claimed
`by the patent-at-issue.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, Patent Owner
`has failed to demonstrate a sufficient nexus
`between the purported secondary considerations of
`non-obviousness allegedly disclosed in the exhibit
`and the invention claimed by the patent-at-issue.
`
`FRE 802: The exhibit is inadmissible hearsay if
`offered to prove the truth of any matter allegedly
`asserted therein.
`
`FRE 901: The exhibit is inadmissible because
`Patent Owner has not submitted evidence sufficient
`to support a finding that the item is what Patent
`Owner claims it is.
`FRE 402: The exhibit is not relevant to any ground
`upon which trial was instituted. For example,
`Patent Owner has failed to demonstrate a sufficient
`
`-1-
`
`
`
`
`
`eBay U.S.
`
`
`
`
`nexus between the purported secondary
`considerations of non-obviousness allegedly
`disclosed in the exhibit and the invention claimed
`by the patent-at-issue.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, Patent Owner
`has failed to demonstrate a sufficient nexus
`between the purported secondary considerations of
`non-obviousness allegedly disclosed in the exhibit
`and the invention claimed by the patent-at-issue.
`
`FRE 602: The exhibit is inadmissible because
`Patent Owner has not submitted evidence sufficient
`to support a finding that Patent Owner has personal
`knowledge of the statements made therein.
`
`FRE 603: The exhibit is inadmissible because the
`statements made therein were not made under oath.
`
`FRE 701/702/703: The exhibit is inadmissible
`because it includes opinions that are not admissible
`testimony under FRE 701, 702, or 703. For
`instance, the testimony is not rationally based on
`the witness’s perception; helpful to clearly
`understanding the witness’s testimony or to
`determining a fact in issue; and/or based on
`scientific, technical, or other specialized knowledge
`within the scope of Rule 702.
`
`FRE 802: The exhibit is inadmissible hearsay if
`offered to prove the truth of any matter allegedly
`asserted therein.
`
`FRE 901: The exhibit is inadmissible because
`Patent Owner has not submitted evidence sufficient
`-2-
`
`
`
`to support a finding that the item is what Patent
`Owner claims it is.
`FRE 402: The exhibit is not relevant to any ground
`upon which trial was instituted. For example,
`Patent Owner has failed to demonstrate a sufficient
`nexus between the purported secondary
`considerations of non-obviousness allegedly
`disclosed in the exhibit and the invention claimed
`by the patent-at-issue.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, Patent Owner
`has failed to demonstrate a sufficient nexus
`between the purported secondary considerations of
`non-obviousness allegedly disclosed in the exhibit
`and the invention claimed by the patent-at-issue.
`
`FRE 802: The exhibit is inadmissible hearsay if
`offered to prove the truth of any matter allegedly
`asserted therein.
`
`FRE 901: The exhibit is inadmissible because
`Patent Owner has not submitted evidence sufficient
`to support a finding that the item is what Patent
`Owner claims it is.
`
`37 C.F.R. § 42.64(b)(2): The exhibit is
`inadmissible because it was filed and served by
`Patent Owner as supplemental evidence to correct
`deficiencies in Patent Owner’s evidence more than
`10 business days after Patent Owner received
`Petitioner’s timely served objections.
`FRE 402: The exhibit is not relevant to any ground
`upon which trial was instituted. For example, the
`exhibit is not offered by Patent Owner to rebut any
`-3-
`
`
`
`
`
`Exhibit 2046 – Press
`Release, Admission Wins
`Far-Reaching Patent
`
`Exhibit 2047 -
`[PROTECTIVE ORDER
`MATERIAL] LG
`
`
`
`
`
`
`
`Electronics – Summit 6
`License and Settlement
`Agreement
`
`Exhibit 2048 – Prepare and
`Post Product Overview
`
`
`
`
`argument made by Petitioner.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, the exhibit is
`not offered by Patent Owner to rebut any argument
`made by Petitioner.
`
`FRE 802: The exhibit is inadmissible hearsay if
`offered to prove the truth of any matter allegedly
`asserted therein.
`
`FRE 901: The exhibit is inadmissible because
`Patent Owner has not submitted evidence sufficient
`to support a finding that the item is what Patent
`Owner claims it is.
`FRE 402: The exhibit is not relevant to any ground
`upon which trial was instituted. For example,
`Patent Owner has failed to demonstrate a sufficient
`nexus between the purported secondary
`considerations of non-obviousness allegedly
`disclosed in the exhibit and the invention claimed
`by the patent-at-issue.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, Patent Owner
`has failed to demonstrate a sufficient nexus
`between the purported secondary considerations of
`non-obviousness allegedly disclosed in the exhibit
`and the invention claimed by the patent-at-issue.
`
`FRE 802: The exhibit is inadmissible hearsay if
`offered to prove the truth of any matter allegedly
`-4-
`
`
`
`
`
`Exhibit 2049 –
`Correspondence between S.
`Lewis/G. Dillabough with
`attached Proposal to eBay
`
`Exhibit 2050 –
`[PROTECTIVE ORDER
`MATERIAL] Declaration
`of Scott Lewis
`
`
`
`
`asserted therein.
`
`FRE 901: The exhibit is inadmissible because
`Patent Owner has not submitted evidence sufficient
`to support a finding that the item is what Patent
`Owner claims it is.
`FRE 402: The exhibit is not relevant to any ground
`upon which trial was instituted. For example,
`Patent Owner has failed to demonstrate a sufficient
`nexus between the purported secondary
`considerations of non-obviousness allegedly
`disclosed in the exhibit and the invention claimed
`by the patent-at-issue.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, Patent Owner
`has failed to demonstrate a sufficient nexus
`between the purported secondary considerations of
`non-obviousness allegedly disclosed in the exhibit
`and the invention claimed by the patent-at-issue.
`
`FRE 802: The exhibit is inadmissible hearsay if
`offered to prove the truth of any matter allegedly
`asserted therein.
`
`FRE 901: The exhibit is inadmissible because
`Patent Owner has not submitted evidence sufficient
`to support a finding that the item is what Patent
`Owner claims it is.
`FRE 402: The declaration of Mr. Lewis is not
`relevant to any ground upon which trial was
`instituted at least because Patent Owner has failed
`to demonstrate a sufficient nexus between the
`purported secondary considerations of non-
`obviousness allegedly disclosed in the declaration
`and the invention claimed by the patent-at-issue.
`-5-
`
`
`
`
`
`
`FRE 403: The declaration of Mr. Lewis includes
`information whose probative value to any ground
`upon which trial was instituted is substantially
`outweighed by the danger of unfair prejudice,
`confusing the issues, undue delay, wasting time, or
`needlessly presenting cumulative evidence. For
`example, Patent Owner has failed to demonstrate a
`sufficient nexus between the purported secondary
`considerations of non-obviousness allegedly
`disclosed in the declaration and the invention
`claimed by the patent-at-issue.
`
`FRE 701/702/703: The exhibit is inadmissible
`because it includes opinions that are not admissible
`testimony under FRE 701, 702, or 703. For
`instance, the expert’s scientific, technical, or other
`specialized knowledge will not help the trier of fact
`to understand the evidence or to determine a fact in
`issue; the testimony is based on sufficient facts or
`data; the testimony is not the product of reliable
`principles and methods; and the expert has not
`reliably applied the principles and methods to the
`facts of the case. Further, experts in this field
`would not reasonably rely on the kinds of facts or
`data relied upon by the declarant in forming an
`opinion on the subject.
`
`37 C.F.R. § 42.64(b)(2): The exhibit is
`inadmissible because it was filed and served by
`Patent Owner as supplemental evidence to correct
`deficiencies in Patent Owner’s evidence more than
`10 business days after Patent Owner received
`Petitioner’s timely served objections.
`
`Reservation of Right to Cross-examination:
`Petitioner reserves the right to cross-examine the
`declarant regarding any subject that is within the
`scope of his declaration testimony.
`Exhibit 2051 – Declaration FRE 402: The declaration of Ms. Pate is not
`
`-6-
`
`
`
`
`
`
`of Sarah Pate
`
`
`
`
`relevant to any ground upon which trial was
`instituted at least because Patent Owner has failed
`to demonstrate a sufficient nexus between the
`purported secondary considerations of non-
`obviousness allegedly disclosed in the declaration
`and the invention claimed by the patent-at-issue.
`
`FRE 403: The declaration of Ms. Pate includes
`information whose probative value to any ground
`upon which trial was instituted is substantially
`outweighed by the danger of unfair prejudice,
`confusing the issues, undue delay, wasting time, or
`needlessly presenting cumulative evidence. For
`example, Patent Owner has failed to demonstrate a
`sufficient nexus between the purported secondary
`considerations of non-obviousness allegedly
`disclosed in the declaration and the invention
`claimed by the patent-at-issue.
`
`FRE 701/702/703: The exhibit is inadmissible
`because it includes opinions that are not admissible
`testimony under FRE 701, 702, or 703. For
`instance, the testimony is not rationally based on
`the witness’s perception; helpful to clearly
`understanding the witness’s testimony or to
`determining a fact in issue; and/or based on
`scientific, technical, or other specialized knowledge
`within the scope of Rule 702.
`
`37 C.F.R. § 42.64(b)(2): The exhibit is
`inadmissible because it was filed and served by
`Patent Owner as supplemental evidence to correct
`deficiencies in Patent Owner’s evidence more than
`10 business days after Patent Owner received
`Petitioner’s timely served objections.
`
`Reservation of Right to Cross-examination:
`Petitioner reserves the right to cross-examine the
`declarant regarding any subject that is within the
`scope of her declaration testimony.
`-7-
`
`
`
`
`
`Exhibit 2052 – Email
`communication from J.
`Townsend re Far reaching
`patent for AdMission
`
`Exhibit 2053 – Classified
`Intelligence Report,
`AdMission patent – What
`
`
`
`FRE 402: The exhibit is not relevant to any ground
`upon which trial was instituted. For example,
`Patent Owner has failed to demonstrate a sufficient
`nexus between the purported secondary
`considerations of non-obviousness allegedly
`disclosed in the exhibit and the invention claimed
`by the patent-at-issue.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, Patent Owner
`has failed to demonstrate a sufficient nexus
`between the purported secondary considerations of
`non-obviousness allegedly disclosed in the exhibit
`and the invention claimed by the patent-at-issue.
`
`FRE 603: The exhibit is inadmissible because the
`statements made therein were not made under oath.
`
`FRE 802: The exhibit is inadmissible hearsay if
`offered to prove the truth of any matter allegedly
`asserted therein.
`
`FRE 901: The exhibit is inadmissible because
`Patent Owner has not submitted evidence sufficient
`to support a finding that the item is what Patent
`Owner claims it is.
`
`37 C.F.R. § 42.64(b)(2): The exhibit is
`inadmissible because it was filed and served by
`Patent Owner as supplemental evidence to correct
`deficiencies in Patent Owner’s evidence more than
`10 business days after Patent Owner received
`Petitioner’s timely served objections.
`FRE 402: The exhibit is not relevant to any ground
`upon which trial was instituted. For example,
`Patent Owner has failed to demonstrate a sufficient
`-8-
`
`
`
`
`
`does it Mean
`
`
`Exhibit 2054 – eBay –
`How do I Put Pictures in
`My Listings
`
`
`
`
`nexus between the purported secondary
`considerations of non-obviousness allegedly
`disclosed in the exhibit and the invention claimed
`by the patent-at-issue.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, Patent Owner
`has failed to demonstrate a sufficient nexus
`between the purported secondary considerations of
`non-obviousness allegedly disclosed in the exhibit
`and the invention claimed by the patent-at-issue.
`
`FRE 701/702/703: The exhibit is inadmissible
`because it includes opinions that are not admissible
`testimony under FRE 701, 702, or 703. For
`instance, the testimony is not (a) rationally based
`on the witness’s perception; (b) helpful to clearly
`understanding the witness’s testimony or to
`determining a fact in issue; and/or (c) not based on
`scientific, technical, or other specialized knowledge
`within the scope of Rule 702.
`
`FRE 802: The exhibit is inadmissible hearsay if
`offered to prove the truth of any matter allegedly
`asserted therein.
`
`FRE 901: The exhibit is inadmissible because
`Patent Owner has not submitted evidence sufficient
`to support a finding that the item is what Patent
`Owner claims it is.
`Lack of Foundation: The exhibit is inadmissible
`because Patent Owner has not provided sufficient
`explanation of what the exhibit is or what it
`allegedly shows.
`
`FRE 402: The exhibit is not relevant to any ground
`-9-
`
`
`
`
`
`Exhibit 2055 – Mandate –
`Summit6 v. Samsung, Fed.
`Cir.
`
`Exhibit 2056 – Affidavit of
`Christopher Butler
`
`
`
`
`upon which trial was instituted. For example,
`Patent Owner has not cited to this exhibit in its
`Response to rebut any argument presented by
`Petitioner.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, the exhibit is
`not offered by Patent Owner to rebut any argument
`made by Petitioner.
`
`FRE 602: The exhibit is inadmissible because
`Patent Owner has not submitted evidence sufficient
`to support a finding that Patent Owner has personal
`knowledge of the statements made therein.
`FRE 402: The exhibit is not relevant to any ground
`upon which trial was instituted. For example,
`Patent Owner has not cited to this exhibit in its
`Response to rebut any argument presented by
`Petitioner.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, the exhibit is
`not offered by Patent Owner to rebut any argument
`made by Petitioner.
`Lack of Foundation: The exhibit is inadmissible
`because Patent Owner has not provided sufficient
`explanation of what the exhibit is or what it
`allegedly shows.
`
`FRE 402: The declaration of Mr. Butler is not
`relevant to any ground upon which trial was
`instituted. For example, Patent Owner has failed to
`-10-
`
`
`
`
`
`
`
`
`demonstrate a sufficient nexus between the
`purported secondary considerations of non-
`obviousness allegedly disclosed in the exhibit and
`the invention claimed by the patent-at-issue. Patent
`Owner also fails to cite to the declaration and
`exhibit thereto in its Response to rebut any
`argument presented by Petitioner.
`
`FRE 403: The declaration of Mr. Butler includes
`information whose probative value to any ground
`upon which trial was instituted is substantially
`outweighed by the danger of unfair prejudice,
`confusing the issues, undue delay, wasting time, or
`needlessly presenting cumulative evidence. For
`example, Patent Owner has failed to demonstrate a
`sufficient nexus between the purported secondary
`considerations of non-obviousness allegedly
`disclosed in the exhibit and the invention claimed
`by the patent-at-issue.
`
`FRE 602: The declaration of Mr. Butler and the
`exhibit thereto are inadmissible because Patent
`Owner has not submitted evidence sufficient to
`support a finding that Patent Owner has personal
`knowledge of the statements made therein.
`
`FRE 603: The declaration of Mr. Butler and the
`exhibit thereto are inadmissible because the
`statements made therein were not made under oath.
`
`FRE 701/702/703: The declaration of Mr. Butler
`and the exhibit thereto are inadmissible because it
`includes opinions that are not admissible testimony
`under FRE 701, 702, or 703. For instance, the
`testimony is not (a) rationally based on the
`witness’s perception; (b) helpful to clearly
`understanding the witness’s testimony or to
`determining a fact in issue; and/or (c) not based on
`scientific, technical, or other specialized knowledge
`within the scope of Rule 702.
`-11-
`
`
`
`
`
`Exhibit 2058 – Declaration
`of Marty Kaliski
`
`
`
`
`
`FRE 802: The declaration of Mr. Butler and the
`exhibit thereto are inadmissible hearsay if offered
`to prove the truth of any matter allegedly asserted
`therein.
`
`FRE 901: The declaration of Mr. Butler and the
`exhibit thereto are inadmissible because Patent
`Owner has not submitted evidence sufficient to
`support a finding that the item is what Patent
`Owner claims it is.
`
`37 C.F.R. § 42.64(b)(2): The exhibit is
`inadmissible because it was filed and served by
`Patent Owner as supplemental evidence to correct
`deficiencies in Patent Owner’s evidence more than
`10 business days after Patent Owner received
`Petitioner’s timely served objections.
`
`Reservation of Right to Cross-examination:
`Petitioner reserves the right to cross-examine the
`declarant regarding any subject that is within the
`scope of his declaration testimony.
`FRE 402: The declaration of Dr. Kaliski is not
`relevant to any statutory ground upon which trial
`was instituted at least because Dr. Kaliski’s
`testimony (e.g., at least ¶¶ 185-310) fails to
`demonstrate a sufficient nexus between the
`purported secondary considerations of non-
`obviousness allegedly disclosed in the exhibit and
`the invention claimed by the patent-at-issue.
`
`
`FRE 403: The declaration of Dr. Kaliski includes
`information whose probative value to any ground
`upon which trial was instituted is substantially
`outweighed by the danger of unfair prejudice,
`confusing the issues, undue delay, wasting time, or
`needlessly presenting cumulative evidence. For
`example, Dr. Kaliski’s testimony (e.g., at least ¶¶
`185-310) fails to demonstrate a sufficient nexus
`-12-
`
`
`
`
`
`Exhibit 2059 – U.S. Patent
`No. 6,895,557 to Wood et
`al. – Web-Based Media
`Submission Tool
`
`
`
`
`between the purported secondary considerations of
`non-obviousness allegedly disclosed in the exhibit
`and the invention claimed by the patent-at-issue.
`
`FRE 702: Dr. Kaliski’s declaration is improper
`expert testimony at least because Dr. Kaliski’s
`testimony (e.g., at least ¶¶ 185-310) fails to
`demonstrate a sufficient nexus between the
`purported secondary considerations of non-
`obviousness allegedly disclosed in the exhibit and
`the invention claimed by the patent-at-issue.
`Further, Dr. Kaliski’s testimony that certain
`practices or technology were merely conventional,
`well-known, or routine is based on insufficient
`facts or data, and is not the product of reliable
`principles and methods reliably applied by Dr.
`Kaliski.
`
`FRE 703: Dr. Kaliski’s declaration is improper
`expert testimony at least because testimony (e.g., at
`least ¶¶ 185-310) regarding the purported
`secondary considerations of non-obviousness
`allegedly disclosed in the exhibit and the invention
`claimed by the patent-at-issue is not based upon
`data on which experts in this field would
`reasonably rely.
`
`Reservation of Right to Cross-examination:
`Patent Owner reserves the right to cross-examine
`the declarant regarding any subject that is within
`the scope of his declaration testimony.
`FRE 402: The exhibit is not relevant to any ground
`upon which trial was instituted. For example,
`Patent Owner has not cited to this exhibit in its
`Response to rebut any argument presented by
`Petitioner.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`-13-
`
`
`
`
`
`Exhibit 2060 – Declaration
`of Reference Publication
`Date
`
`
`
`
`
`
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, Patent Owner
`has not cited to this exhibit in its Response to rebut
`any argument presented by Petitioner.
`FRE 402: The exhibit is not relevant to any ground
`upon which trial was instituted. For example,
`Patent Owner has not cited to this exhibit in its
`Response to rebut any argument presented by
`Petitioner.
`
`FRE 403: The exhibit includes information whose
`probative value to any ground upon which trial was
`instituted is substantially outweighed by the danger
`of unfair prejudice, confusing the issues, undue
`delay, wasting time, or needlessly presenting
`cumulative evidence. For example, Patent Owner
`has not cited to this exhibit in its Response to rebut
`any argument presented by Petitioner.
`
`FRE 701/702/703: The exhibit is inadmissible
`because it includes opinions that are not admissible
`testimony under FRE 701, 702, or 703. For
`instance, the testimony is not (a) rationally based
`on the witness’s perception; (b) helpful to clearly
`understanding the witness’s testimony or to
`determining a fact in issue; and/or (c) not based on
`scientific, technical, or other specialized knowledge
`within the scope of Rule 702.
`
`FRE 802: The declaration and the exhibit thereto
`are inadmissible hearsay if offered to prove the
`truth of any matter allegedly asserted therein.
`
`Reservation of Right to Cross-examination:
`Patent Owner reserves the right to cross-examine
`the declarant regarding any subject that is within
`the scope of his declaration testimony.
`
`-14-
`
`
`
`
`
`Respectfully submitted,
`
`By:
`John Alemanni
`Registration No. 47,384
`Lead Counsel for Petitioner
`
`
`
`Lead Counsel
`John Alemanni
`Registration No. 47,384
`JAlemanni@kilpatricktownsend.com
`
`Postal and Hand-Delivery Address:
`Kilpatrick Townsend & Stockton LLP
`1001 West Fourth Street
`Winston-Salem, NC 27101-2400
`Telephone: (336) 607-7311
`Fax: (336) 607-7500
`
`
`Back-Up Counsel
`Michael Morlock
`Registration No. 62,245
`MMorlock@kilpatricktownsend.com
`
`Postal and Hand-Delivery Address:
`Kilpatrick Townsend & Stockton LLP
`1001 West Fourth Street
`Winston-Salem, NC 27101-2400
`Telephone: (336) 607-7391
`Fax: (336) 607-7500
`
`
`
`-15-
`
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of this PETITIONER’S
`
`OBJECTIONS TO ADMISSIBILITY OF EVIDENCE SERVED WITH
`
`PATENT OWNER SUMMIT 6 LLC’S RESPONSE TO PETITION FOR
`
`INTER PARTES REVIEW has been served via electronic mail on December 16,
`
`2015, upon the following:
`
`Peter J. Ayers
`peter@leehayes.com
`John Shumaker
`jshumaker@leehayes.com
`Brian Mangum
`brianm@leehayes.com
`LEE & HAYES, PLLC
`11501 Alterra Parkway, Suite 450
`Austin, TX 78758
`
`
`
`Date: December 16, 2015
`
`
`
`
`
`
`
`By:
`John C. Alemanni (Reg. No. 47,384)
`
`
`
`
`
`-16-
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