`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`
`
` K.J. PRETECH CO., LTD.,
`Petitioner
`
`v.
`
`
` INNOVATIVE DISPLAY TECHNOLOGIES LLC,
`Patent Owner
`
`_____________________
`
`Case IPR2015-01868
`Patent 7,434,974 B1
`January 6, 2017
`_____________________
`
`PETITIONER’S OBJECTIONS TO PATENT OWNER’S
`DEMONSTRATIVES
`
`
`
`
`Mail Stop: Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`
`
`Pursuant to Paper No. 26, Petitioner objects to Patent Owner’s Oral
`
`Argument Demonstratives, emailed to the Board on January 5, 2017. Pursuant
`
`to the Board’s Order: “The objections should identify with particularity which
`
`demonstratives are subject to objection, and include a short (one sentence or less)
`
`statement of the reason for each objection. No argument or further explanation is
`
`permitted.” Petitioner identifies below which demonstratives are subject to
`
`objection, and include a short statement of the reason for each objection. In
`
`identifying the demonstratives, Petitioner refers to the slide number in the lower
`
`right corner of Patent Owner’s slides.
`
`Demonstrative Slide 4: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`Demonstrative Slide 5: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color and
`
`that mounting holes, lead wires, and solder are not part of the reflector 60.
`
`Demonstrative Slide 7: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`Demonstrative Slide 8: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`Demonstrative Slide 9: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`
`
`
`
`
`
`
`
`Demonstrative Slide 10: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`Demonstrative Slide 12: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`Demonstrative Slide 15: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`Demonstrative Slide 16: New argument not found in any paper with respect to
`
`reference to another IPR (IPR2015-00487) that is irrelevant to this proceeding as it
`
`relates to a different patent.
`
`Demonstrative Slide 17: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`Demonstrative Slide 18: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`Demonstrative Slide 19: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`Demonstrative Slide 20: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`Demonstrative Slide 21: New argument not found in any paper and unsupported
`
`characterization of the evidence with respect to figure annotations and color.
`
`
`
`
`
`
`
`
`
`Demonstrative Slide 22: New argument not found in any paper with respect to
`
`reference to another IPR (IPR2015-00487) that is irrelevant to this proceeding as it
`
`relates to a different patent.
`
`Demonstrative Slide 23: New argument not found in any paper with respect to
`
`reference to another IPR (IPR2015-00487) that is irrelevant to this proceeding as it
`
`Respectfully submitted,
`
`
`
`/Robert G Pluta Reg No 50970/
`Robert G. Pluta
`Registration No. 50,970
`Amanda K. Streff
`Registration No. 65,224
`Mayer Brown LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`Telephone:
`312-701-8641
`Facsimile:
`312-701-7711
`rpluta@mayerbrown.com
`astreff@mayerbrown.com
`
`Jamie B. Beaber (pro hac vice)
`Baldine B. Paul
`Registration No. 54,369
`Anita Y. Lam
`Registration No. 67,394
`Saqib J. Siddiqui
`Registration No. 68,626
`Mayer Brown LLP
`1999 K Street, N.W.
`Washington, DC 20006
`Telephone:
`202-263-3000
`
`relates to a different patent.
`
`
`Dated: January 6, 2017
`
`
`
`
`
`
`
`
`
`202-263-3300
`Facsimile:
`bpaul@mayerbrown.com
`alam@mayerbrown.com
`ssiddiqui@mayerbrown.com
`
`Counsel for K.J. Pretech Co., Ltd.
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE (37 C.F.R. §§ 42.6(e), 42.105(a))
`
`The undersigned hereby certifies that the above-captioned “Objections to
`
`Patent Owner’s Demonstratives” was served on January 6, 2017 upon the attorneys
`
`of record by filing this document through the PTAB E2E System as well as e-
`
`mailing a copy to: JKimble-IPR@bcpc-law.com; jbragalone@bcpc-law.com;
`
`nkliewer@bcpc-law.com; tsaad@bcpc-law.com; and bkennedy@bcpc-law.com.
`
`
`
`Date: January 6, 2017 By:
`
`
`/Robert G Pluta Reg No 50970/
`Robert G. Pluta
`Registration No. 50,970
`Mayer Brown LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`Telephone: 312-701-8641
`Facsimile: 312-701-7711
`
`Counsel for K.J. Pretech Co., Ltd.
`
`
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATION PURSUANT TO 37 C.F.R. § 42.11
`
`Pursuant 37 CFR 42.11, the undersigned certifies that this Paper is not being
`
`presented for an improper purpose and that all legal contentions, allegations, and
`
`denials are warranted and have evidentiary support.
`
`Date: January 6, 2017 By:
`
`
`/Robert G Pluta Reg No 50970/
`Robert G. Pluta
`Registration No. 50,970
`Mayer Brown LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`Telephone: 312-701-8641
`Facsimile: 312-701-7711
`
`Counsel for K.J. Pretech Co., Ltd.