UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`VALEO NORTH AMERICA, INC., VALEO S.A., VALEO GMBH,
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`VALEO SCHALTER UND SENSOREN GMBH, AND CONNAUGHT
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`ELECTRONICS LTD.,
`Petitioners
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`V.
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`MAGNA ELECTRONICS INC.,
`Patent Owner
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`Case 11311201 5-01410‘
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`Patent 8,643,724
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`PATENT OWNER MAGNA ELECTRONICS INC.’S OBJECTIONS TO
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`EVIDENCE
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`Mail Stop “PA TENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
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`P.O. Box 1450
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`Alexandria, VA 22313-1450
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`1 Case IPR20l5—0l4l4 has been consolidated with this proceeding.
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`VALEO NORTH AMERICA, INC., VALEO S.A., VALEO GMBH,
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`VALEO SCHALTER UND SENSOREN GMBH, AND CONNAUGHT
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`ELECTRONICS LTD.,
`Petitioners
`
`V.
`
`MAGNA ELECTRONICS INC.,
`Patent Owner
`
`Case 11311201 5-01410‘
`
`Patent 8,643,724
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`PATENT OWNER MAGNA ELECTRONICS INC.’S OBJECTIONS TO
`
`EVIDENCE
`
`Mail Stop “PA TENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`
`P.O. Box 1450
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`Alexandria, VA 22313-1450
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`1 Case IPR20l5—0l4l4 has been consolidated with this proceeding.
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`Case IPR2015—01410 of
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`U.S. Patent No- 8,643,724
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`Patent Owner Magna Electronics, Inc. (“Magna”) objects under the Federal
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`Rules of Evidence (“FRE”) and 37 C.F.R. § 42.62 (2012) to Exhibits 1009, 1016,
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`1019, 1020, 1022, and 1024-1044. A decision for Institution of Inter Partes
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`Review was entered on December 28, 2015. Magna’s Objections to Evidence are
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`timely under 37 C.F-R- § 42.64(b)(l) (2012)2. Magna files and serves Petitioners
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`Valeo North America, Inc., er al. (“Valeo”) with these objections to provide notice
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`that Magna may move to exclude Exhibits 1009, 1016, 1019, 1020, 1022, and
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`1024-1044 under 37 C.F-R. § 42.64(c) (2012) unless Valeo cures the defects
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`identified herein-
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`Exhibit 1009: Wang
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`Magna objects to Exhibit 1009 as not properly authenticated under FRE 901
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`because Valeo has not presented any evidence that the document is what Valeo
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`purports it to be, and has failed to authenticate the date by which Exhibit 1009 was
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`publicly accessible as a printed publication. The document
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`is also not self-
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`authenticating under FRE 902.
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`To the extent that Valeo relies on dates in Exhibit 1009 to establish public
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`accessibility as a printed publication, that date is hearsay under FRE 801 and is
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`inadmissible under FRE 802.
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`2 January 1, 2016 was a holiday.
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`Because of the above deficiencies of Exhibit 1009, Valeo has failed to
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`establish that Exhibit 1009 is a prior art printed publication under 35 U.S.C. §
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`l02(b) (2013), and Exhibit 1009 is therefore not relevant under FRE 401 and is
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`inadmissible under FRE 402.
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`Exhibit 1016: SAE Paper No. 871288 to Otsuka
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`Magna objects to Exhibit 1016 as not properly authenticated under FRE 901
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`because Valeo has not presented any evidence that the document is what Valeo
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`purports it to be, and has failed to authenticate the date by which Exhibit 1016 was
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`publicly accessible as a printed publication. The document
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`is also not self-
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`authenticating under FRE 902-
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`To the extent that Valeo relies on dates in Exhibit 1016 to establish public
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`accessibility as a printed publication, that date is hearsay under FRE 801 and is
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`inadmissible under FRE 802.
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`Because of the above deficiencies of Exhibit 1016, Valeo has failed to
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`establish that Exhibit 1016 is a prior art printed publication under 35 U.S.C. §
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`102(b), and Exhibit 1016 is
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`therefore not relevant under FRE 401 and is
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`inadmissible under FRE 402.
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`Exhibit 1019: SAE Paper No. 890288 to Goesch
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`Magna objects to Exhibit 1019 as not properly authenticated under FRE 901
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`because Valeo has not presented any evidence that the document is what Valeo
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`purports it to be, and has failed to authenticate the date by which Exhibit 1019 was
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`publicly accessible as a printed publication. The document
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`is also not self-
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`authenticating under FRE 902-
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`To the extent that Valeo relies on dates in Exhibit 1019 to establish public
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`accessibility as a printed publication, that date is hearsay under FRE 801 and is
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`inadmissible under FRE 802.
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`Because of the above deficiencies of Exhibit 1019, Valeo has failed to
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`establish that Exhibit 1019 is a prior art printed publication under 35 U_S.C. §
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`102(b), and Exhibit 1019 is
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`therefore not relevant under FRE 401 and is
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`inadmissible under FRE 402.
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`Exhibit 1020: Expert Declaration of Dr. George Wolberg
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`To the extent that Valeo is attempting to rely on statements in 1111 84 and 85
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`of Exhibit 1020 as proof of the publication of Wang (Ex. 1020, Wolberg Decl., 1111
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`84, 85), such statements are objected to as inadmissible hearsay under FRE 801
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`and FRE 802 that do not fall under any exception.
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`To the extent that Valeo is attempting to rely on statements in 1111 29-35, 37,
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`and 38 of Exhibit 1020 that discuss other exhibits as proof of the state of the art at
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`the time of the invention (Ex. 1020, 1111 29-35, 37, 38), such statements are objected
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`to as not relevant under FRE 401 and inadmissible under FRE 402 for at least the
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`reason that those other exhibits are inadmissible as discussed herein.
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`Exhibit 1022: Expert Declaration of Dr. Ralph Wilhelm
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`To the extent that Valeo is attempting to rely on statements in ‘W 22, and 23-
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`27 of Exhibit 1022 that discuss other exhibits as proof of the state of the art at the
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`time of the invention (Ex. 1022, Wilhelm Decl., W 22, 23-27), such statements are
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`objected to as not relevant under FRE 401 and inadmissible under FRE 402 for at
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`least the reason that those other exhibits are inadmissible as discussed herein.
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`Exhibit 1024: Robert Nathan, Digital Video Data Handling
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`Magna objects to Exhibit 1024 as not properly authenticated under FRE 901
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`because Valeo has not presented any evidence that the document is what Valeo
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`purports it to be, and has failed to authenticate the date by which Exhibit 1024 was
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`publicly accessible as a printed publication. The document
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`is also not self-
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`authenticating under FRE 902.
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`To the extent that Valeo is attempting to rely on statements in Exhibit 1024
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`as proof of the state of the art at the time of the invention, to include any dates to
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`establish public accessibility as a printed publication, such statements are objected
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`to as inadmissible hearsay under FRE 801 and FRE 802 that do not fall under any
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`exception.
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`Exhibit 1025: P. Burt et al., A Multiresolution Spline with Application to
`Image Mosaics, ACM Transactions on Graphics
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`To the extent that Valeo is attempting to rely on statements in Exhibit 1025
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`as proof of the state of the art at the time of the invention, to include any dates to
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`
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`establish public accessibility as a printed publication, such statements are objected
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`to as inadmissible hearsay under FRE 801 and FRE 802 that do not fall under any
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`exception.
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`Exhibit 1026: Lisa Gottesfeld Brown, A Survey of Image Registration
`Technigues
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`To the extent that Valeo is attempting to rely on statements in Exhibit 1026
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`as proof of the state of the art at the time of the invention, to include any dates to
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`establish public accessibility as a printed publication, such statements are objected
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`to as inadmissible hearsay under FRE 801 and FRE 802 that do not fall under any
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`exception.
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`Exhibit 1027: George Wolberg, Digital Image Warping
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`To the extent that Valeo is attempting to rely on statements in Exhibit 1027
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`as proof of the state of the art at the time of the invention, to include any dates to
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`establish public accessibility as a printed publication, such statements are objected
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`to as inadmissible hearsay under FRE 801 and FRE 802 that do not fall under any
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`exception.
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`Exhibit 1028: N. Greene et 11]., Creating Raster Omnimax Images from
`Multiple Perspective Views Using the Elliptical Weighted Average Filter
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`To the extent that Valeo is attempting to rely on statements in Exhibit 1028
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`as proof of the state of the art at the time of the invention, to include any dates to
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`establish public accessibility as a printed publication, such statements are objected
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`
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`to as inadmissible hearsay under FRE 801 and FRE 802 that do not fall under any
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`exception.
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`Exhibit 1029: Richard Szeliski Ima eM0saicin for Tele-Reali A lications
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`Magna objects to Exhibit 1029 as not properly authenticated under F RE 901
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`because Valeo has not presented any evidence that the document is what Valeo
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`purports it to be, and has failed to authenticate the date by which Exhibit 1029 was
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`publicly accessible as a printed publication. The document
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`is also not self-
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`authenticating under FRE 902.
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`To the extent that Valeo is attempting to rely on statements in Exhibit 1029
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`as proof of the state of the art at the time of the invention, to include any dates to
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`establish public accessibility as a printed publication, such statements are objected
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`to as inadmissible hearsay under FRE 801 and FRE 802 that do not fall under any
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`exception.
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`Exhibit 1030: G. Wolberg, “A Two-Pass Mesh Warping Implementation of
`Morphing”
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`Magna objects to Exhibit 1030 as being not relevant under FRE 401 and
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`inadmissible under FRE 402, as Valeo and its experts have failed to cite to or
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`otherwise rely on this document, other than listing it
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`in a list of selected
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`representative journal publications and in a list of considered documents. (Ex.
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`1020,
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`1] 6, Appendix A.) Even relevant evidence may be objectionable if its
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`probative value is substantially outweighed by factors such as unfair prejudice or
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`undue delay. Fed. R. Evid. 403. To the extent Valeo believes that this document is
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`still relevant, Magna objects to its later introduction or use under at least FRE 403.
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`Exhibit 1031: T. Porter and T. Duff, “Compositing Digital Images”
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`Magna objects to Exhibit 1031 as being not relevant under FRE 401 and
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`inadmissible under FRE 402, as Valeo and its experts have failed to cite to or
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`otherwise rely on this document, other than listing it
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`in a list of considered
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`documents. (Ex- 1020, Appendix A-) Even relevant evidence may be objectionable
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`if its probative value is substantially outweighed by factors such as unfair prejudice
`
`or undue delay. Fed. R. Evid. 403. To the extent Valeo believes that this document
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`is still relevant, Magna objects to its later introduction or use under at least FRE
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`403.
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`Exhibit 1032: SAE Paper No. 750364 to Nolan
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`Magna objects to Exhibit 1032 as not properly authenticated under FRE 901
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`because Valeo has not presented any evidence that the document is what Valeo
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`purports it to be, and has failed to authenticate the date by which Exhibit 1032 was
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`publicly accessible as a printed publication. The document
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`is also not self-
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`authenticating under FRE 902.
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`To the extent Valeo relies on dates in Exhibit 1032 to establish public
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`accessibility as a printed publication, that date is hearsay under FRE 801 and is
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`inadmissible under FRE 802. To the extent that Valeo is attempting to rely on
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`statements in Exhibit 1032 as proof of the state of the art at the time of the
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`invention,
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`to include any dates to establish public accessibility as a printed
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`publication, such statements are objected to as inadmissible hearsay under FRE
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`801 and FRE 802 that do not fall under any exception.
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`Because of the above deficiencies of Exhibit 1032, Valeo has failed to
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`establish that Exhibit 1032 is relevant to the state of the art, and Exhibit 1032 is
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`therefore not relevant under FRE 401 and is inadmissible under FRE 402.
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`Exhibit 1033: SAE Paper No. 890282 to Corsi
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`Magna objects to Exhibit 1033 as not properly authenticated under FRE 901
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`because Valeo has not presented any evidence that the document is what Valeo
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`purports it to be, and has failed to authenticate the date by which Exhibit 1033 was
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`publicly accessible as a printed publication. The document
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`is also not self-
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`authenticating under FRE 902.
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`To the extent Valeo relies on dates in Exhibit 1033 to establish public
`
`accessibility as a printed publication, that date is hearsay under FRE 801 and is
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`inadmissible under FRE 802. To the extent that Valeo is attempting to rely on
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`statements in Exhibit 1033 as proof of the state of the art at the time of the
`
`invention,
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`to include any dates to establish public accessibility as a printed
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`publication, such statements are objected to as inadmissible hearsay under FRE
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`801 and FRE 802 that do not fall under any exception.
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`Because of the above deficiencies of Exhibit 1033, Valeo has failed to
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`establish that Exhibit 1033 is relevant to the state of the art, and Exhibit 1033 is
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`therefore not relevant under F RE 401 and is inadmissible under F RE 402-
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`Exhibit 1034: SAE Paper No. 890283 to Brandt
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`Magna objects to Exhibit 1034 as not properly authenticated under FRE 901
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`because Valeo has not presented any evidence that the document is what Valeo
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`purports it to be, and has failed to authenticate the date by which Exhibit 1034 was
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`publicly accessible as a printed publication. The document
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`is also not self-
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`authenticating under FRE 902.
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`To the extent Valeo relies on dates in Exhibit 1034 to establish public
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`accessibility as a printed publication, that date is hearsay under FRE 801 and is
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`inadmissible under FRE 802. To the extent that Valeo is attempting to rely on
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`statements in Exhibit 1034 as proof of the state of the art at the time of the
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`invention,
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`to include any dates to establish public accessibility as a printed
`
`publication, such statements are objected to as inadmissible hearsay under FRE
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`801 and FRE 802 that do not fall under any exception.
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`Because of the above deficiencies of Exhibit 1034, Valeo has failed to
`
`establish that Exhibit 1034 is relevant to the state of the art, and Exhibit 1034 is
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`therefore not relevant under FRE 401 and is inadmissible under FRE 402-
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`Exhibit 1035: SAE Paper No. 860173 to Ortega
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`Magna objects to Exhibit 1035 as not properly authenticated under FRE 901
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`because Valeo has not presented any evidence that the document is what Valeo
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`purports it to be, and has failed to authenticate the date by which Exhibit 1035 was
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`publicly accessible as a printed publication. The document
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`is also not self-
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`authenticating under FRE 902.
`
`To the extent that Valeo relies on dates in Exhibit 1035 to establish public
`
`accessibility as a printed publication, that date is hearsay under FRE 801 and is
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`inadmissible under FRE 802. To the extent that Valeo is attempting to rely on
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`statements in Exhibit 1035 as proof of the state of the art at the time of the
`
`invention,
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`to include any dates to establish public accessibility as a printed
`
`publication, such statements are objected to as inadmissible hearsay under FRE
`
`801 and FRE 802 that do not fall under any exception.
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`Because of the above deficiencies of Exhibit 1035, Valeo has failed to
`
`establish that Exhibit 1035 is relevant to the state of the art, and Exhibit 1035 is
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`therefore not relevant under FRE 401 and is inadmissible under FRE 402-
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`Exhibit 1036: SAE Paper No. 930456 to Gumkowski
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`Magna objects to Exhibit 1036 as not properly authenticated under FRE 901
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`because Valeo has not presented any evidence that the document is what Valeo
`
`purports it to be, and has failed to authenticate the date by which Exhibit 1036 was
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`10
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`publicly accessible as a printed publication. The document
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`is also not self-
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`authenticating under FRE 902.
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`To the extent Valeo relies on dates in Exhibit 1036 to establish public
`
`accessibility as a printed publication, that date is hearsay under FRE 801 and is
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`inadmissible under FRE 802. To the extent that Valeo is attempting to rely on
`
`statements in Exhibit 1036 as proof of the state of the art at the time of the
`
`invention,
`
`to include any dates to establish public accessibility as a printed
`
`publication, such statements are objected to as inadmissible hearsay under FRE
`
`801 and FRE 802 that do not fall under any exception.
`
`Because of the above deficiencies of Exhibit 1036, Valeo has failed to
`
`establish that Exhibit 1036 is relevant to the state of the art, and Exhibit 1036 is
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`therefore not relevant under F RE 401 and is inadmissible under F RE 402-
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`Exhibit 1037: U.S. Patent No. 6 693 524 to Pa ne
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`Magna objects to Exhibit 1037 as being not relevant under FRE 401 and
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`inadmissible under FRE 402, as Valeo and its experts have failed to cite to or
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`otherwise rely on this document, other than listing it
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`in a list of considered
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`documents. (Ex. 1022, Appendix A.) Even relevant evidence may be objectionable
`
`if its probative value is substantially outweighed by factors such as unfair prejudice
`
`or undue delay. Fed- R. Evid. 403- To the extent Valeo believes that this document
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`11
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`is still relevant, Magna objects to its later introduction or use under at least FRE
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`403.
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`Exhibit 1038: SAE Paper No. 770274 to Smith
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`Magna objects to Exhibit 1038 as not properly authenticated under F RE 901
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`because Valeo has not presented any evidence that the document is what Valeo
`
`purports it to be, and has failed to authenticate the date by which Exhibit 1038 was
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`publicly accessible as a printed publication. The document
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`is also not self-
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`authenticating under FRE 902.
`
`To the extent Valeo relies on dates in Exhibit 1038 to establish public
`
`accessibility as a printed publication, that date is hearsay under FRE 801 and is
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`inadmissible under FRE 802. To the extent that Valeo is attempting to rely on
`
`statements in Exhibit 1038 as proof of the state of the art at the time of the
`
`invention,
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`to include any dates to establish public accessibility as a printed
`
`publication, such statements are objected to as inadmissible hearsay under FRE
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`801 and FRE 802 that do not fall under any exception.
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`Because of the above deficiencies of Exhibit 1038, Valeo has failed to
`
`establish that Exhibit 1038 is relevant to the state of the art, and Exhibit 1038 is
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`therefore not relevant under FRE 401 and is inadmissible under FRE 402.
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`12
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`Exhibit 1039: Declaration of Gerard Grenier in Support of Wang
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`Magna objects to Exhibit 1039 as being not relevant under FRE 401 and
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`inadmissible under FRE 402, as Valeo and its experts have failed to cite to or
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`otherwise rely on this document, other than listing it
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`in a list of considered
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`documents. (Ex. 1020, Appendix A.) Even relevant evidence may be objectionable
`
`if its probative value is substantially outweighed by factors such as unfair prejudice
`
`or undue delay. Fed- R. Evid_ 403- To the extent Valeo believes that this document
`
`is still relevant, Magna objects to its later introduction or use under at least FRE
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`403.
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`Magna further objects to Exhibit 1039 as being not relevant under FRE 401
`
`and inadmissible under FRE 402 because it provides no support for a May 27-31,
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`2001 publication date for Wang. In fact, Exhibit 1039 provides no evidence of fly
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`publication date. Mr. Grenier states that “IEEE’s records confirm the following: a)
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`‘CMOS’ Video Cameras’ was presented as part of Euro SIC ’91 which occurred
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`May 27-31, 1991. b) IEEE has registered this conference with U.S. Copyright
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`Office.” (Ex. 1039, Grenier Decl., p. 001-) A presentation as part of Euro SIC ’91
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`is not a publication, and Exhibit 1039 provides no evidence of a publication as a
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`result of this presentation. In addition, a registration with the U.S. Copyright Office
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`is only the beginning of the formal copyright process—no evidence is presented to
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`show a publication date as a result of registration. In addition, Mr. Grenier states
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`13
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`that a “true and correct copy of the Article accompany this declaration as Exhibit
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`A.” (Id.) But Exhibit A is not identical to any other exhibit in this proceeding and
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`therefore cannot be relevant-
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`To the extent that Valeo is attempting to rely on statements in Exhibit 1039
`
`as proof of the publication of Wang,
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`such statements are objected to as
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`inadmissible hearsay under FRE 801 and FRE 802 that do not fall under any
`
`exception because Exhibit 1039 fails to establish any publication date on the basis
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`of Mr. Grenier’s reliance on IEEE business records.
`
`Exhibit 1040: Tremblay, M., et al. High resolution smart image senor with
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`integrated Qarallel analog processing for multiresolution edge extraction
`
`To the extent
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`that Valeo is attempting to rely on statements, dates, or
`
`citations in Exhibit 1040 as proof of the publication of Wang, such statements,
`
`dates, and citations are objected to as inadmissible hearsay under FRE 801 and
`
`FRE 802 that does not fall under any exception.
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`Exhibit 1041: Abstract for the Publication of High Resolution Smart Image
`Sensor
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`Magna objects to Exhibit 1041 as being not relevant under FRE 401 and
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`inadmissible under FRE 402, as Valeo and its experts have failed to cite to or
`
`otherwise rely on this document, other than listing it
`
`in a list of considered
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`documents. (Ex. 1020, Appendix A.) Even relevant evidence may be objectionable
`
`if its probative value is substantially outweighed by factors such as unfair prejudice
`
`14
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`or undue delay. Fed. R. Evid. 403. To the extent Valeo believes that this document
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`is still relevant, Magna objects to its later introduction or use under at least FRE
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`403.
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`Exhibit 1042: Lu, M., et al. On-chip Automatic Exposure Control Technigue
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`To the extent
`
`that Valeo is attempting to rely on statements, dates, or
`
`citations in Exhibit 1042 as proof of the publication of Wang, such statements,
`
`dates, and citations are objected to as inadmissible hearsay under FRE 801 and
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`FRE 802 that does not fall under any exception.
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`Exhibit 1043: lEEE.org Abstract On-chin Automatic Exposure Control
`Technigue
`
`Magna objects to Exhibit 1043 as being not relevant under FRE 401 and
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`inadmissible under FRE 402, as Valeo and its experts have failed to cite to or
`
`otherwise rely on this document, other than listing it
`
`in a list of considered
`
`documents. (Ex. 1020, Appendix A.) Even relevant evidence may be objectionable
`
`if its probative value is substantially outweighed by factors such as unfair prejudice
`
`or undue delay. Fed. R. Evid. 403. To the extent Valeo believes that this document
`
`is still relevant, Magna objects to its later introduction or use under at least FRE
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`403.
`
`Exhibit 1044: CMOS sensor a e of Universi
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`of Edinbur h
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`To the extent
`
`that Valeo is attempting to rely on statements, dates, or
`
`citations in Exhibit 1044 as proof of the publication of Wang, such statements,
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`15
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`dates, and citations are objected to as inadmissible hearsay under FRE 801 and
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`FRE 802 that does not fall under any exception.
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`CONCLUSION
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`To the extent that Valeo fails to correct the defects associated with Exhibits
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`1009, 1016, 1019, 1020, 1022, and 1024-1044 in View of Magna’s objections
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`herein, Magna may file one or more motions to exclude the exhibits under 37
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`C.F.R. § 42.64(c)-
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`DATE: January 12, 2016
`
`/Salvador M. Bezos/
`
`Respectfully submitted,
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`Salvador M. Bezos, Registration No. 60,889
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`STERNE, KESSLER, GOLDSTEIN & Fox P.L.L.C.
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`1 100 NEW YORK AVENUE, NW
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`WASHINGTON, D.C. 20005
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`(202) 371-2600
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`Attorneyfor Patent Owner
`Magna Electronics, Inc.
`
`
`
`CERTIFICATE OF SERVICE
`
`Case IPR2015—01410 of
`
`U.S. Patent No- 8,643,724
`
`The undersigned hereby certifies that a true and correct copy of the enclosed
`
`PATENT OWNER’S OBJECTIONS T0 EVIDENCE was served electronically
`
`via e-mail on January 12, 2016, in its entirety on Attorneys for Petitioners — Valeo
`
`North America, Inc., et ai.:
`
`Russell Levine (Lead Counsel)
`Hari Santhanam (Back—up Counsel)
`
`rlevine@,kirkland.com
`hsanthanam@,kirkland.com
`
`KIRKLAND & ELLIS LLP
`
`300 North LaSalle Street
`
`Chicago, Illinois 60654
`
`Tammy J. Terry (Back—up Counsel)
`Aly Z. Dossa (Back—up Counsel)
`Seema M. Mehta (Back-up Counsel)
`Peter C. Schechter (Back—up Counsel)
`
`oshalian .com
`te
`dossa@,oshaliang.com
`Ir1ehta@,oshaliang.com
`schechter@,oshaliang.com
`
`OSHA LIANG LLP
`
`909 Fannin Street, Suite 3500
`
`Houston, TX 77010-1034
`
`Date: January 12, 2016
`
`/Salvador M. Bezos/
`
`Salvador M. Bezos, Registration No. 60,889
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`STERNE, KESSLER, GOLDSTEIN & Fox P.L.L.C.
`
`1 1 00 NEW YORK AVENUE, NW
`
`WASHINGTON, D.C. 20005
`
`(202) 371-2600
`
`Attorneyfor Patent Owner
`Magna Electronics, Inc.
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