`Filed: January 21, 2016
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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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`HTC Corporation,
`HTC America, Inc.,
`LG Electronics, Inc.,
`Samsung Electronics Co., Ltd., and
`Samsung Electronics America, Inc.
`Petitioner
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`v.
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`Parthenon Unified Memory Architecture LLC
`Patent Owner
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`Case IPR2015-01500
`Patent No. 7,321,368
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`Petitioner’s Objections to Patent Owner’s Exhibits
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner1 submits the following
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`objections to exhibits submitted by Patent Owner, Parthenon Unified Memory
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`Architecture LLC. These objections are timely, having been filed and served
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`within ten business days of institution of trial.
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`Exhibit 2001
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`Petitioner objects to Exhibit 2001 under Rules 901 and 902 of the Federal
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`Rules of Evidence as not having been properly authenticated.
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`Petitioner also objects to Exhibit 2001 under Rules 401-403 of the Federal
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`Rules of Evidence on the ground that Patent Owner has not established that it is
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`relevant in the absence of an established publication date.
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`Petitioner also objects to Exhibit 2001 under Rule 602 of the Federal Rules
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`of Evidence as lacking proper foundation.
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`Petitioner also objects to Exhibit 2001 under Rule 802 of the Federal Rules
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`of Evidence on the ground of hearsay.
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`1 “Petitioner” refers collectively to HTC Corporation, HTC America, Inc., LG
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`Electronics, Inc., Samsung Electronics Co., Ltd., and Samsung Electronics
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`America, Inc.
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`Case No. IPR2015-01501
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`Respectfully submitted,
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`By: /Allan M. Soobert/
`Allan M. Soobert
`Reg. No. 36,284
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`Counsel for Petitioner
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`Dated: January 21, 2016
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`2
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), I certify that I caused to be served on the
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`counsel for Petitioner a true and correct copy of the foregoing Petitioner’s
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`Objections to Patent Owner’s Exhibits by electronic means on the date below at the
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`following address of record:
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`Masood Anjom (manjom@azalaw.com)
`Alisa Lipski (alipski@azalaw.com)
`Amir Alavi (aalavi@azalaw.com)
`Ahmad, Zavitsanos, Anaipakos, Alavi & Mensing P.C.
`1221 McKinney, Suite 3460
`Houston, TX 77010
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`Respectfully submitted,
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`By: /Allan M. Soobert/
`Allan M. Soobert
`Reg. No. 36,284
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`Counsel for Petitioner
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`Dated: January 21, 2016