`Filed By: Donald R. Steinberg, Reg. No. 37,241
`David L. Cavanaugh, Reg. No. 36,476
`Michael H. Smith, Reg. No. 71,190
`60 State Street,
`Boston, Massachusetts 02109
`Tel: (617) 526-6000
`Email: Don.Steinberg@wilmerhale.com
`
` David.Cavanaugh@wilmerhale.com
`
` MichaelH.Smith@wilmerhale.com
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`
`
`
`
`ASML NETHERLANDS B.V., EXCELITAS TECHNOLOGIES CORP., AND QIOPTIQ
`PHOTONICS GMBH & CO. KG,
`Petitioners
`
`v.
`
`ENERGETIQ TECHNOLOGY, INC.,
`Patent Owner.
`
`Case IPR2015-01300;
`IPR2015-01303
`
`
`
`PETITIONERS’ OBJECTIONS TO EVIDENCE
`
`
`
`IPR2015-01300; IPR2015-01303
`Petitioners’ Objections to Evidence
`
`Pursuant to 37 C.F.R. § 42.64, ASML Netherlands B.V., Excelitas
`
`
`
`
`Technologies Corp., and Qioptiq Photonics GmbH & Co. KG (collectively,
`
`“Petitioners”) serve the following objections to evidence served with the Patent
`
`Owner’s Response of Energetiq Technology, Inc. (“Patent Owner”).
`
`Petitioners object to Exhibit 2006, J. Gary Eden’s Deposition Transcript
`
`Excerpts, as incomplete (FRE 106).
`
`Petitioners object to Exhibit 2016, Declaration of Donald K. Smith, Ph.D.
`
`Specifically, Petitioners object to ¶¶ 9-10, 16-26, 28-38, 41-43, 46-51, 53-54, 56-
`
`57, 59-61, 63-64, 66-67, 69, 71-73, 75, 77, 79-80, 83, 85, 87, 89-97 as lacking
`
`personal knowledge/foundation (FRE 602) and being improper expert testimony by
`
`a lay witness (FRE 701). Petitioners further object to ¶ 48 as hearsay (FRE 802).
`
`Petitioners object to Exhibit 2022, Fridman et al., Plasma Physics and
`
`Engineering, pp. 404-419, 618-619 (1st ed. 2004), as incomplete (FRE 106).
`
`Petitioners object to Exhibit 2045, I.N. Toumanov, “General Analysis of
`
`Plasma Technique in Chemical Technology and Metallurgy,” Plasma and High
`
`Frequency Processes for Obtaining and Processing Materials in the Nuclear Fuel
`
`Cycle, p. 60 (2003), as incomplete (FRE 106).
`
`Petitioners object to Exhibit 2046, Fridman et al., Plasma Physics and
`
`Engineering, pp. 409-424, 639-640 (2nd ed. 2011), as incomplete (FRE 106).
`
`
`
`1
`
`
`
`Petitioners object to Exhibit 2050, Schöne et al., “Diode-Pumped High-
`
`IPR2015-01300; IPR2015-01303
`Petitioners’ Objections to Evidence
`
`
`
`Power cw Nd:YAG Lasers,” Laser in Forschung und Technik (1996), as
`
`incomplete (FRE 106) and as lacking authentication (FRE 901).
`
`Petitioners object to Exhibit 2051, Optics & Photonics News, January 1999,
`
`as incomplete (FRE 106).
`
`Petitioners objection to Exhibit 2076, LuxteL, Ceralux Xenon Arc Lamps
`
`(2003-2004), as lacking authentication (FRE 901).
`
`
`
`
`
`
`
`Date: March 8, 2016
`
`
`
`
`
`
`
`
`
`Respectfully Submitted,
`
`/Donald R Steinberg/
`Donald R. Steinberg
`Registration No. 37,241
`Lead Counsel for Petitioners
`Wilmer Cutler Pickering
` Hale & Dorr LLP
`Tel: 617-526-6453
`Fax: 617-526-5000
`
`
`
`2
`
`
`
`
`
`
`IPR2015-01300; IPR2015-01303
`Petitioners’ Objections to Evidence
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on March 8, 2016, I caused a true and correct copy of the
`
`following materials:
`
`• Petitioners’ Objections to Evidence
`
`to be served by electronic mail to the following address:
`
`PTABMattersBoston@proskauer.com.
`
`Respectfully Submitted,
`
`__/Michael Smith/____
`Michael H. Smith
`Registration No. 71,190
`Wilmer Cutler Pickering
`
`Hale & Dorr LLP
`Tel: 202-663-6055
`Fax: 202-663-6363
`
`3
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
