`By:
`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
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`Bragalone Conroy PC
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`2200 Ross Ave.
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`Suite 4500 – West
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`Dallas, TX 75201
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`Tel: 214.785.6670
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`Fax: 214.786.6680
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`K.J. PRETECH CO., LTD.,
`Petitioner,
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`v.
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`INNOVATIVE DISPLAY TECHNOLOGIES, LLC,
`Patent Owner.
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`
`
`Case IPR2015-018681
`U.S. Patent No. 7,434,974
`
`
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`PATENT OWNER’S OBJECTIONS
`TO PETITIONER’S DEMONSTRATIVES
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`
`
`1 Case IPR2016-00910 has been joined with this proceeding.
`
`
`
`Case IPR2015-01868
`Patent 7,434,974
`
`
`Pursuant to the Board’s Order, Paper 27, Patent Owner Innovative Display
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`Technologies, LLC (“Patent Owner” or “IDT”) files these objections to Petitioner’s
`
`oral argument demonstratives served by Petitioner on December 30, 2016.
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`Objection No. 1 (to Petitioner’s Demonstrative Slide 5)
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`Patent Owner objects to Slide 5 on the grounds that it includes new
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`argument, in the form of a quotation from Ex. 1026, 53:3-8, for the first time in
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`Petitioner’s Demonstratives.
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`Objection No. 2 (to Petitioner’s Demonstrative Slide 9)
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`Patent Owner objects to Slide 9 on the grounds that it includes new
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`argument, in the form of a quotation to a quotation from Ex. 1006 (7) on page
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`Pretech_000388 (which Petitioner incorrectly cites as Ex. 1006 ¶ 27), for the first
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`time in Petitioner’s Demonstratives.
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`Objection No. 3 (to Petitioner’s Demonstrative Slide 14)
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`Patent Owner objects to Slide 14 on the grounds that it includes new and
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`confusing arguments made for the first time in Petitioner’s Demonstratives relating
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`to the annotation to Figure 1 of Kisou.
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`Objection No. 4 (to Petitioner’s Demonstrative Slide 17)
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`Patent Owner objects to Slide 17 on the grounds that it includes a new
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`argument raised for the first time in Petitioner’s Reply, including citation to the
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`’974 patent and deposition testimony about the same, which is prejudicial to Patent
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`1
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`Case IPR2015-01868
`Patent 7,434,974
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`Owner and prohibited by the Trial Practice Guide, Section II.I., “Petitioner Reply
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`to Patent Owner Response and Patent Owner Reply to Opposition to Amend.”
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`Objection No. 5 (to Petitioner’s Demonstrative Slide 19)
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`Patent Owner objects to Slide 19 on the grounds that it includes a new and
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`factually incorrect argument raised for the first time in Petitioner’s Reply, relating
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`to assertion that Kisou relies on “‘corrugated light paths 31’ for scattering light,”
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`which is prejudicial to Patent Owner and prohibited by the Trial Practice Guide,
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`Section II.I., “Petitioner Reply to Patent Owner Response and Patent Owner Reply
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`to Opposition to Amend.”
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`Objection No. 6 (to Petitioner’s Demonstrative Slide 20)
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`Patent Owner objects to Slide 20 on the grounds that it includes a new
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`argument raised for the first time in Petitioner’s Reply, including quotation to Ex.
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`1008, which is prejudicial to Patent Owner and prohibited by the Trial Practice
`
`Guide, Section II.I., “Petitioner Reply to Patent Owner Response and Patent Owner
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`Reply to Opposition to Amend.”
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`Objection No. 7 (to Petitioner’s Demonstrative Slide 27)
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`Patent Owner objects to Slide 27 on the grounds that it includes a new
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`argument raised for the first time in Petitioner’s Reply, and includes a misleadingly
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`annotated figure 8 of Ex. 1009, which is prejudicial to Patent Owner and prohibited
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`2
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`
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`Case IPR2015-01868
`Patent 7,434,974
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`by the Trial Practice Guide, Section II.I., “Petitioner Reply to Patent Owner
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`Response and Patent Owner Reply to Opposition to Amend.”
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`Respectfully submitted,
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`
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`
`
`
`
`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`
`
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`Dated: January 6, 2017
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`3
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`Case IPR2015-01868
`Patent 7,434,974
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`CERTIFICATE OF SERVICE
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`
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`The undersigned hereby certifies that document was served via electronic mail
`
`on January 6, 2017, to Petitioner via counsel, Robert Pluta, at the email addresses
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`rpluta@mayerbrown.com, bpaul@mayerbrown.com, astreff@mayerbrown.com,
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`alam@mayerbrown.com,
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`jbeaber@mayerbrown.com,
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`and
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`DDGIPR@mayerbrown.com, pursuant to Petitioner’s consent in its revised
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`mandatory notice.
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`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`
`
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`4
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