`IPR2015-01675
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`SMART MODULAR TECHNOLOGIES, INC.
`
`Petitioner
`
`v.
`
`JAMES B. GOODMAN
`
`Patent Owner
`
`
`
`Case No. IPR2015-01675
`
`Patent 6,243,315
`
`
`
`PETITIONER’S OBJECTIONS TO PATENT OWNER’S UNMARKED
`ATTACHMENTS SUBMITTED WITH IT’S POST-INSTITUTION RESPONSE
`
`
`Michael F. Heafey (Lead Counsel)
`Registration No. 38,178
`King & Spalding, LLP
`601 South California Avenue, Suite 100
`Palo Alto, California 94304
`(650) 422-6700
`
`
`
`
`
`
`
`
`
`
`
`ATTORNEY REFERENCE NO.: 21584-112005.4
`IPR2014-01372
`
`Patent Owner’s March 3, 2016 Response includes two unmarked
`
`attachments. Patent Owner identifies the first unmarked attachment as “selected
`
`pages from web site of www.jedec.org.” and the second unmarked attachment as
`
`“JEDEC21-C.” Patent Owner’s Response cites to these exhibits at page 9.
`
`Petitioner objects to:
`
`1.
`
`Patent Owner’s improper submission of attachments as exhibits,
`
`pursuant to
`
`a.
`
`b.
`
`37 C.F.R. § 42.63(a) (failure to file in the form of an exhibit);
`
`37 C.F.R. § 42.63(d)(1), (2)(ii) (failure to label the exhibits);
`
`and
`
`c.
`
`42.63(d)(2)(i) (failure to sequentially number the exhibit
`
`pages); and
`
`2.
`
`the attachments themselves, pursuant to 37 C.F.R. § 42.64 as follows:
`
`a.
`
`Objection to completeness of the Exhibits under F.R.E. 106
`
`(Remainder of or Related Writings or Recorded Statements),
`
`because both Exhibits appear to be incomplete sections of a
`
`document or webpage.
`
`
`
`
`
`ATTORNEY REFERENCE NO.: 21584-112005.4
`IPR2014-01372
`Objection to Patent Owner’s characterization of these Exhibits
`
`b.
`
`at page 8 of Patent Owner’s Response under F.R.E. 701
`
`(Opinion Testimony by Lay Witnesses) and F.R.E. 702
`
`(Testimony by Expert Witnesses), because the characterization
`
`is unsupported by expert testimony and Patent Owner’s counsel
`
`is not identified as an expert in this case.
`
`
`Dated: March 11, 2016
`
`
`
`
`
`
`
`
`
`/Michael F. Heafey/
`Michael F. Heafey
`Registration No. 38,178
`King & Spalding LLP
`601 South California Avenue
`Palo Alto, California 94304
`(650) 422-6719 (telephone)
`(650 422-6800 (facsimile)
`mheafey@kslaw.com (email)
`
`Sanjiva K. Reddy
`Registration No. 70,816
`King & Spalding LLP
`1185 Avenue of the Americas
`New York, New York 10036
`(212) 556-2157 (telephone)
`(212) 556-2222(facsimile)
`sreddy@kslaw.com (email)
`
`
`
`
`
`ATTORNEY REFERENCE NO.: 21584-112005.4
`IPR2014-01372
`Certificate Of Service In Compliance With 37 C.F.R. § 42.6(e)(4)
`
`The undersigned certifies that a complete copy of this PETITIONER’S
`
`OBJECTIONS TO PATENT OWNER’S UNMARKED ATTACHMENTS SUBMITTED WITH IT’S
`
`POST-INSTITUTION RESPONSE was served via email on Counsel for Patent Owner in
`
`this proceeding:
`
`David Fink
`Fink & Johnson
`7519 Apache Plume
`Houston, TX 77071
`Admission No. 299869
`Tel. 713 729-4991
`Fax: 713 729-4951
`Email: texascowboy6@gmail.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Sanjiva K. Reddy/
`Sanjiva K. Reddy
`Registration No. 70,816
`King & Spalding LLP
`1185 Avenue of the Americas
`New York, New York 10036
`(212) 556-2157 (telephone)
`(212) 556-2222(facsimile)
`sreddy@kslaw.com (email)
`
`
`
`
`
`
`
`via Electronic Mail, on March 11, 2016.
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