`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`BUNGIE, INC.,
`Petitioner
`
`v.
`
`WORLDS INC.,
`Patent Owner
`_______________
`
`Case IPR2015-01319
`Patent 8,082,501 B2
`_____________
`
`PATENT OWNER WORLDS INC’S
`OBJECTIONS TO PETITIONER’S EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64(b)(1)
`
`
`
`
`
`
`
`
`Patent Owner Worlds Inc. objects to the evidence of Petitioner for the
`
`
`
`reasons set forth below:
`
`Identity of Exhibit
`
`1010 – MSFT
`computer dictionary
`(“avatar”)
`
`Portion to be
`Excluded
`All
`
`1011 – photo essay All
`
`FRE 402/403, 37
`C.F.R. §
`42.22(a)(2)
`
`1012 – Digibarn
`
`All
`
`FRE 402/403, 37
`C.F.R. §
`42.22(a)(2)
`
`2
`
`
`Objection
`
`Grounds
`
`FRE 402/403
`
`Not part of
`instituted
`challenge, not
`relevant to
`knowledge of
`POSITA at critical
`date, not relevant
`to claim
`construction
`Not part of
`instituted
`challenge, not
`relevant to any
`issue in this
`proceeding;
`Petition lacks
`detailed
`explanation of
`evidence’s
`significance
`Not part of
`instituted
`challenge, not
`relevant to any
`issue in this
`proceeding;
`Petition lacks
`detailed
`explanation of
`evidence’s
`significance
`
`
`
`Objection
`
`Grounds
`
`FRE 402/403, 37
`C.F.R. §
`42.22(a)(2)
`
`Not part of
`instituted
`challenge, not
`relevant to any
`issue in this
`proceeding;
`Petition lacks
`detailed
`explanation of
`evidence’s
`significance
`Not part of
`instituted
`challenge, not
`relevant to any
`issue in this
`proceeding;
`Petition lacks
`detailed
`explanation of
`evidence’s
`significance
`Not part of
`instituted
`challenge, not
`relevant to any
`issue in this
`proceeding;
`Petition lacks
`detailed
`explanation of
`evidence’s
`significance
`
`Identity of Exhibit
`
`1014 – Smith
`
`Portion to be
`Excluded
`All
`
`1015 – NPSNET-1-
`
`All
`
`TRG-1991
`
`FRE 402/403, 37
`C.F.R. §
`42.22(a)(2)
`
`1016 - Calvin
`
`All
`
`FRE 402/403, 37
`C.F.R. §
`42.22(a)(2)
`
`3
`
`
`
`
`Identity of Exhibit
`
`1032 – Activision
`
`Portion to be
`Excluded
`All
`
`Destiny Press
`
`Release
`
`1033 – Article re
`
`All
`
`lawsuit against
`
`NCSoft
`
`FRE 402/403,
`801, 901
`
`FRE 402/403,
`801, 901
`
`1034 – Article re
`
`All
`
`Worlds
`
`FRE 402/403,
`801, 901
`
`1035 – Worlds 10-Q All
`
`FRE 402/403
`
`
`
`4
`
`
`Objection
`
`Grounds
`
`Not part of
`instituted
`challenge, not
`relevant to any
`issue in this
`proceeding;
`contains hearsay
`not subject to any
`exception; exhibit
`not authenticated
`Not part of
`instituted
`challenge, not
`relevant to any
`issue in this
`proceeding;
`contains hearsay
`not subject to any
`exception; exhibit
`not authenticated
`Not part of
`instituted
`challenge, not
`relevant to any
`issue in this
`proceeding;
`contains hearsay
`not subject to any
`exception; exhibit
`not authenticated
`Not part of
`instituted
`challenge, not
`relevant to any
`issue in this
`proceeding
`
`
`
`Respectfully submitted,
`
`By: /s/ Wayne M. Helge
`Wayne M. Helge (Reg. No. 56,905)
`Donald L. Jackson (Reg. No. 41,090)
`Michael R. Casey (Reg. No. 40,294)
`DAVIDSON BERQUIST JACKSON & GOWDEY,
`LLP
`8300 Greensboro Drive, Suite 500
`McLean, VA 22102
`Telephone: 571-765-7700
`Fax: 571-765-7200
`Email: whelge@dbjg.com
`Email: djackson@dbjg.com
`Email: mcasey@dbjg.com
`
` Counsel for Patent Owner
`
`
`
`Dated: December 14, 2015
`
`
`
`
`
`5
`
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`
`
`I hereby certify that on December 14, 2015, a true and correct copy of the
`
`foregoing OBJECTIONS TO PETITIONER’S EVIDENCE is being served via
`
`email by consent to the Petitioners at the correspondence addresses of record as
`
`follows:
`
`Michael T. Rosato
`Reg. No. 52,182
`Wilson Sonsini Goodrich & Rosati
`701 Fifth Ave.
`Suite 5100
`Seattle, WA 98104-7036
`Telephone: (206) 883-2529
`Facsimile: (206) 883-2699
`E-mail: mrosato@wsgr.com
`
`Matthew A. Argenti
`Reg. No. 61,836
`Wilson Sonsini Goodrich & Rosati
`650 Page Mill Road
`Palo Alto, CA 94304
`Telephone: (650) 354-4154
`Facsimile: (650) 493-6811
`E-mail: margenti@wsgr.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By: /s/ Wayne M. Helge
`
`Registration No. 56,905
`
`Counsel for Patent Owner
`
`6
`
`
`
`
`
`
`
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