`By:
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`Joseph E. Palys
`Paul Hastings LLP
`875 15th Street NW
`Washington, DC 20005
`Telephone: (202) 551-1996
`Facsimile: (202) 551-0496
`E-mail: josephpalys@paulhastings.com
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`
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`Paper No. _____
`Filed: October 21, 2015
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`Naveen Modi
`Paul Hastings LLP
`875 15th Street NW
`Washington, DC 20005
`Telephone: (202) 551-1990
`Facsimile: (202) 551-0490
`E-mail: naveenmodi@paulhastings.com
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`THE MANGROVE PARTNERS MASTER FUND, LTD.,
`Petitioner
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`v.
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`VIRNETX INC.
`Patent Owner
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`Case IPR2015-01046
`Patent No. 6,502,135
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`PATENT OWNER’S OBJECTIONS TO
`PETITIONER’S EXHIBITS
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner VirnetX Inc. submits the
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`Case IPR2015-01046
`Patent No. 6,502,135
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`following objections to certain exhibits submitted by Mangrove Partners Master
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`Fund, Ltd. (“Petitioner”) in Case No. IPR2015-01046. Patent Owner’s objections
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`apply equally to Petitioner’s reliance on these exhibits in any subsequently-filed
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`documents. These objections are timely, having been served within ten business
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`days of the Board’s decision to institute a trial in this proceeding.
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`Exhibit 1025
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`Patent Owner objects to Exhibit 1025 under Rule 802 of the Federal Rules of
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`Evidence because the testimony in this Exhibit constitutes inadmissible hearsay.
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`Exhibits 1010, 1014, and 1020
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`Patent Owner objects to Exhibits 1010, 1014, and 1020 under Rules 401-403
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`of the Federal Rules of Evidence on the grounds that these exhibits contain
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`evidence not relevant to issues in this proceeding because the evidence lacks a
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`nexus to the grounds of rejection on which the Board has instituted inter partes
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`review.
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`Exhibits 1005, 1010, 1014, and 1020
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`Patent Owner objects to Exhibits 1005, 1010, 1014, and 1020 under Rules
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`401-403 of the Federal Rules of Evidence because Petitioner never relied on these
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`exhibits in the Petition.
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`Case IPR2015-01046
`Patent No. 6,502,135
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`Respectfully submitted,
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` /Joseph E. Palys/
`Joseph E. Palys
`Registration No. 46,508
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`Counsel for VirnetX Inc.
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`Dated: October 21, 2015
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`CERTIFICATE OF SERVICE
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`Case IPR2015-01046
`Patent No. 6,502,135
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`I hereby certify that on this 21st day of October 2015, a copy of the
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`foregoing Patent Owner’s Objections to Petitioner’s Exhibits was served by
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`electronic means on the date below at the following address of record:
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`Abraham Kasdan (akasdan@wiggin.com)
`Wiggin and Dana LLP
`450 Lexington Avenue
`New York, NY 10017
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` James T. Bailey (jtb@jtbaileylaw.com)
`504 W. 136th St. #1B
`New York, NY 10031
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` IP@wiggin.com
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`Dated: October 21, 2015
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`Respectfully submitted,
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` /Joseph E. Palys/
`Joseph E. Palys
`Registration No. 46,508
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`Counsel for VirnetX Inc.