`Filed: April 13, 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 IPR2015-01502
`Patent No. 7,542,045
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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. Petitioner’s objections apply equally to Patent Owner’s reliance
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`on these exhibits in any subsequently-filed documents. These objections are
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`timely, having been filed and served within five business days from when the
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`exhibits were served on Petitioner.
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`Exhibit 2004
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`Petitioner objects to Exhibit 2004 under Rules 401-403 of the Federal Rules
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`of Evidence on the ground that it is not relevant because Patent Owner never relied
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`on this exhibit in its Patent Owner’s Response.
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`Exhibit 2005
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`Petitioner objects to Exhibit 2005 under Rules 401-403 of the Federal Rules
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`of Evidence. Patent Owner only cited one page of the several hundred pages of
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`Exhibit 2005 in its Patent Owner’s Response. As such, these uncited pages lack
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`relevance.
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`Exhibit 2008
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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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`Petitioner objects to Exhibit 2008 under Rule 802 of the Federal Rules of
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`Case No. IPR2015-01502
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`Evidence because the testimony and/or evidence in this exhibit constitutes
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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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`inadmissible hearsay.
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`Dated: April 13, 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
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`counsel a true and correct copy of the foregoing Petitioner’s Objections to Patent
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`Owner’s Exhibits by electronic means on the date below at the following address
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`of record:
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`Masood Anjom (manjom@azalaw.com)
`Alisa Lipski (alipski@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: April 13, 2016
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