`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________________________________________________________________
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`SONY CORPORATION, SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG DISPLAY CO., LTD.
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`Petitioners
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`Patent No. 7,202,843
`Issue Date: April 10, 2007
`Title: DRIVING CIRCUIT OF A LIQUID CRYSTAL DISPLAY
`PANEL AND RELATED DRIVING METHOD
`__________________________________________________________________
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`PETITIONERS' OBJECTIONS TO EVIDENCE
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`FOR
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`INTER PARTES REVIEW OF U.S. PATENT NO. 7,202,843
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`No. IPR2015-00863
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`_____________________________________________________________
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`PETITIONERS' OBJECTIONS TO EVIDENCE
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`On October 28, 2015, during the deposition of Petitioners’ expert, Thomas
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`Credelle, Patent Owner's counsel Wayne Helge presented Mr. Credelle with a copy
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`of U.S. Patent Application Publication No. 2008/0106540, which Mr. Helge
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`marked as Exhibit A. Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioners hereby
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`submit their objections to Exhibit A. (Petitioners also stated their objection during
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`the deposition of Mr. Credelle.)
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`Petitioners object to the admissibility of Exhibit A under Fed. R. Evid. 402
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`and 403. As testified by Mr. Credelle during his deposition, the filing date of
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`Exhibit A is 2006, and, thus, the content of Exhibit A would not have been
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`available to a person of ordinary skill in the art as of the 2003 claimed priority date
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`of the U.S. Patent No. 7,202,843 (the "'843 patent"), and, therefore, would not have
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`been within the knowledge base of such a person so as to form part of his or her
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`level of skill as of 2003. Thus, Exhibit A is irrelevant. Moreover, even assuming
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`for the sake of argument that Exhibit A might be considered relevant on some
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`theory, whatever probative value it might have is substantially outweighed by a
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`danger of unfair prejudice and confusion of the issues, since it did not exist until
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`well after the claimed priority date of the '843 patent.
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`Petitioners further object to Exhibit A pursuant to 37 C.F.R. § 42.53(f)(3) as
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`it was not properly served on Petitioners, and as being improperly numbered.
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`Dated: November 4, 2015
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`/Michelle Carniaux/
`Michelle Carniaux
`Lead Counsel, Reg. No. 36,098
`Kenyon & Kenyon LLP
`One Broadway, New York, NY 10004
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`- 3 -
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on November
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`4, 2015, the foregoing Petitioners' Objections to Evidence is being served via
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`electronic mail upon the following counsel of record for Patent Owner:
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`Wayne M. Helge
`Donald L. Jackson
`Michael R. Casey
`whelge@dbjg.com
`djackson@dbjg.com
`mcasey@dbjg.com
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`Davidson Berquist Jackson & Gowdey, L.L.P.
`8300 Greenboro Drive, Suite 500
`McLean, VA 22102
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`/Michelle Carniaux/
`Michelle Carniaux
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004-1007
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`Tel.: (212) 425-7200
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