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UNITED STATES PATENT AND TRADEMARK OFFICE
`___________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`HTC Corporation,
`HTC America, Inc.,
`LG Electronics, Inc.,
`Samsung Electronics, Co., Ltd., and
`Samsung Electronics America, Inc.
`PETITIONERS
`
`V.
`Parthenon Unified Memory Architecture LLC
`PATENT OWNER
`___________
`
`Case IPR No: 2015-01501
`Patent No. 7,777,753
`Title: ELECTRONIC SYSTEM AND METHOD FOR SELECTIVELY ALLOWING ACCESS TO
`A SHARED MEMORY
`____________
`PATENT OWNER’S RESPONSE TO PETITIONER’S OBJECTIONS TO
`EVIDENCE DATED APRIL 13, 2016
`
` 
`
`
`
`

`
`Patent Owner’s Responses to Petitioner’s Objections
`IPR2015-01501
` 
`
`
`In response to Petitioner’s April 13, 2016, Objections to Patent Owner’s
`
`Exhibits, Parthenon Unified Memory Architecture LLC (“Patent Owner”)
`
`hereby responds pursuant to 37 C.F.R. § 42.64(b)(2), on an exhibit-by-exhibit
`
`basis, as follows:
`
`Exhibit 2004
`
`Exhibit 2004 is an Affidavit from Mitchell A. Thornton authenticating
`
`Exhibit 2005 which is relied on in the Patent Owner’s Response. Therefore,
`
`Exhibit 2004 is relevant.
`
`Exhibit 2005
`
`That the Patent Owner relied upon one page of the document in Exhibit
`
`2005 does not render the remaining pages of that exhibit irrelevant as the
`
`remaining pages provide context for the page relied upon.
`
`Exhibit 2008
`
`Exhibit 2008 is dated June 1995. Further, Patent Owner provides an
`
`affidavit from Mitchell A. Thornton, Phd., as Exhibit 2010. Accordingly,
`
`Exhibit 2008 is not inadmissible hearsay pursuant to Rule 803(16) of the
`
`Federal Rules of Evidence.
`
`1
`
`
`
` 
`
`

`
`
`
`
`
`Patent Owner’s Responses to Petitioner’s Objections
`IPR2015-01501
` 
`Dated: April 22, 2016
`
`
`
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`
`
`Respectfully submitted,
`
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` 
`
`
`/s/ Masood Anjom
`Masood Anjom, Lead Counsel
`Reg. No. 62,167
`Alisa Lipski, Back-Up Counsel
`Reg. No. 55,386
`Attorney for Patent Owner
`Parthenon Unified Memory
`Architecture, LLC
`
`AHMAD, ZAVITSANOS, ANAIPAKOS,
`ALAVI &MENSING, P.C.
`1221 McKinney Street, Suite 2500
`Houston, TX 77010
`Telephone: 713-655-1101
`
`
`
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`2
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`

`
`Patent Owner’s Responses to Petitioner’s Objections
`IPR2015-01501
` 
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that the foregoing Responses to Patent Owner’s Objections,
`
`Exhibit 2010, and an updated Exhibit List for this proceeding were served on this
`Friday, April 22, 2016 by electronic mail to the following:
`Lead Counsel for LG Electronics, Inc.
`Back-up Counsel for LG Electronics,
`Inc.
`Darren M. Jiron
`Reg. No. 45,777
`Finnegan, Henderson, Farabow, Garrett
`& Dunner, L.L.P.
`11955 Freedom Drive
`Reston, VA 20190-5675
`Tel: (571) 203-2700
`Fax: (202) 408-4400
`Email: Darren.jiron@finnegan.com
`
`Back-up Counsel for HTC Corporation
`Stephen M. Everett
`Reg. No. 30,050
`Sidley Austin LLP
`555 California Street, Suite 2000
`San Francisco, CA 94104
`Tel: (415) 772-7482
`Email: Stephen.everett@sidley.com
`
`Rajeev Gupta
`Reg. No. 55,873
`Finnegan, Henderson, Farabow, Garrett
`& Dunner, L.L.P.
`901 New York Avenue, N.W.
`Washington, D.C. 20001-4413
`Tel: (202) 408-4000
`Fax: (202) 408-4400
`Email: raj.gupta@finnegan.com
`
`Lead Counsel for HTC Corporation
`Joseph A. Micallef
`Reg. No. 39,772
`Sidley Austin LLP
`1501 K Street, N.W.
`Washington, DC 20005
`Tel: (202) 736-8492
`Email: jmicallef@sidley.com
`
`Lead Counsel for Samsung Electronics Back-up Counsel for Samsung
`Electronics
`Naveen Modi
`Reg. No. 46,224
`Paul Hastings LLP
`875 15th Street NW
`Washington, DC 20005
`Tel: (202) 551-1990
`Fax: (202)551-0490
`Email: Samsung-PUMA-
`IPR@paulhastings.com
`
`Allan M. Soobert
`Reg. No. 36,284
`Paul Hastings LLP
`875 15th Street NW
`Washington, DC 20005
`Tel: (202) 551-1990
`Fax: (202)551-0490
`Email: Samsung-PUMA-
`IPR@paulhastings.com
`
` 
`
`3
`
`

`
`
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`
`
`Patent Owner’s Responses to Petitioner’s Objections
`IPR2015-01501
` 
`
`Dated: April 22, 2016
`
`
`
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`
`
`By: /s/ Masood Anjom
`
`Masood Anjom, Lead Counsel
`
`Reg. No. 62,167
`
`Alisa Lipski, Back-Up Counsel
`
`Reg. No. 55,386
`Attorney for Patent Owner
`Parthenon Unified Memory
`Architecture, LLC
`
`AHMAD, ZAVITSANOS, ANAIPAKOS,
`ALAVI &MENSING, P.C.
`1221 McKinney Street, Suite 2500
`Houston, TX 77010
`Telephone: 713-655-1101
`
`
`
`
`
`
`
`4811‐4856‐7600, v.  1 
`
` 
`
` 
`
`4

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