`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`
`HYDRITE CHEMICAL CO.,
`Petitioner,
`
`v.
`
`SOLENIS TECHNOLOGIES, L.P.,
`Patent Owner.
`
`___________
`
`Case IPR2015-01592
`Patent No. 8,962,059
`___________
`
`
`
`PATENT OWNER’S OBJECTIONS TO EVIDENCE
`
`
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`Pursuant to 37 C.F.R. §§ 42.64(b)(1), Patent Owner, Solenis Technologies,
`
`IPR2015-01592
`Objections to Evidence
`
`
`L.P. (“Solenis” or “Patent Owner”), objects to evidence filed by Petitioner, Hydrite
`
`Chemical Co., (“Hydrite” or “Petitioner”) on August 22, 2016, for the following
`
`reasons:
`
`1. Solenis objects to Hydrite’s Ex. 1031 under FRE 801 because it is
`
`hearsay and contains hearsay. For example, Hydrite relies on Ex. 1031
`
`for the truth of the matter asserted, i.e., that Ex. 1022 was created by Mr.
`
`Copa. Solenis also objects to Ex. 1031 under FRE 401-403 because this
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`document is irrelevant to the issues in the proceeding. As set forth in
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`Solenis’s previous objections with respect to Ex. 1022 (the CVEC slides),
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`it contains new argument and issues improperly set forth for the first time
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`in reply in violation of 37 C.F.R. § 42.23(b). Because Ex. 1022 exceeds
`
`the permissible scope of reply, it is irrelevant to any issue in the case and
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`allowing it would be prejudicial. For the same reasons, Ex. 1031,
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`purporting to authenticate Ex. 1022, is also irrelevant to any issue in this
`
`case and its admission would be prejudicial.
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`Solenis reserves the right to object to the admissibility of any exhibit offered
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`by Hydrite at the time such exhibit is offered in view of the specific context in
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`which such exhibit is offered or for any other reason, as set forth in the Code of
`
`
`
`1
`
`
`
`Federal Regulations, the Federal Rules of Evidence, or any other applicable
`
`IPR2015-01592
`Objections to Evidence
`
`
`principle of law.
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`These objections have been filed and served within five (5) business days of
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`the filing of the objectionable supplemental evidence on August 22, 2016.
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`
`
`Dated: August 29, 2016
`
`Respectfully submitted,
`
`/Joseph Lucci/
`Joseph Lucci, Esquire
`Reg. No. 33,307
`Baker & Hostetler LLP
`Cira Centre, 12th Floor
`2929 Arch Street
`Philadelphia, PA 19104
`215-568-3100 main
`215-568-3439 fax
`jlucci@bakerlaw.com
`
`Attorney for Patent Owner
`
`
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`
`I, David N. Farsiou, hereby certify that on this 29th day of August, the
`foregoing PATENT OWNER’S OBJECTION TO EVIDENCE was served
`electronically via e-mail on the following:
`
`Richard Roche
`Joel A. Austin
`Christopher J. Fahy
`QUARLES & BRADY LLP
`411 East Wisconsin Avenue
`Suite 2350
`Milwaukee, Wisconsin 53202
`richard.roche@quarles.com
`joel.austin@quarles.com
`christopher.fahy@quarles.com
`
`
`
`
`
`
`
`
`
`/David N. Farsiou/
`David N. Farsiou
`Reg. No. 44,104
`Baker & Hostetler LLP
`Cira Centre, 12th Floor
`2929 Arch Street
`Philadelphia, PA 19104
`
`Attorney for Patent Owner