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`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________
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`LG ELECTRONICS, INC.,
`Petitioner,
`
`v.
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`CORE WIRELESS LICENSING S.A.R.L.,
`Patent Owner.
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`_______________
`
`Case IPR2015-01984
`Patent 8,434,020 B2
`_______________
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`
`
`PATENT OWNER’S OBJECTIONS TO PETITIONER’S REPLY
`EVIDENCE PURSUANT TO 37 C.F.R. § 42.64(b)(1)
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`Patent Owner objects to the reply evidence of Petitioner filed and served on
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`September 30, 2016 for the reasons set forth below:
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`Objection
`
`Grounds
`
`FRE 402/403,
`801, 901
`
`Exhibit is not relevant to
`any issue in this
`proceeding; exhibit is not
`established to be prior art,
`and contains hearsay
`(including alleged
`publication date) not
`subject to any exception;
`exhibit not authenticated
`Exhibit is not relevant to
`any issue in this
`proceeding; exhibit is not
`established to be prior art,
`and contains hearsay
`(including alleged
`publication date) not
`subject to any exception;
`exhibit not authenticated
`Exhibit is not relevant to
`any issue in this
`proceeding; exhibit is not
`established to be prior art,
`and contains hearsay
`(including alleged release
`date) not subject to any
`exception; exhibit not
`authenticated
`
`Identity of Exhibit
`
`1010
`
`Portion to be
`Excluded
`All
`
`1011
`
`All
`
`FRE 402/403,
`801, 901
`
`1012
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`All
`
`FRE 402/403,
`801, 901
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`
`
`2
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`
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`Objection
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`Grounds
`
`FRE 402/403,
`801, 901
`
`Exhibit is not relevant to
`any issue in this
`proceeding; exhibit is not
`established to be prior art,
`and contains hearsay
`(including alleged
`publication date) not
`subject to any exception;
`exhibit not authenticated
`Exhibit is not relevant to
`any issue in this
`proceeding; exhibit is not
`established to be prior art,
`and contains hearsay
`(including alleged
`publication date) not
`subject to any exception;
`exhibit not authenticated
`Opinions rely on
`unauthenticated exhibits
`that are not relevant to any
`issue in this proceeding,
`not established to be prior
`art and contain hearsay not
`subject to any exception;
`Dr. Rhyne does not
`establish that Exs. 1010-
`1013 are documents that a
`POSITA would have relied
`upon at the relevant time.
`
`Identity of Exhibit
`
`1013
`
`Portion to be
`Excluded
`All
`
`1014
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`All
`
`FRE 402/403,
`801, 901
`
`1015
`
`¶¶ 13-18
`
`FRE 402/403,
`702/703, 801,
`901
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`
`
`3
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`
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`Identity of Exhibit
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`1015
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`Portion to be
`Excluded
`¶¶ 40-46
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`
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`Dated: October 7, 2016
`
`Objection
`
`Grounds
`
`FRE 402/403,
`702/703, 801,
`901
`
`Opinions rely on
`unauthenticated exhibits
`that are not relevant to any
`issue in this proceeding,
`not established to be prior
`art and contain hearsay not
`subject to any exception;
`Dr. Rhyne does not
`establish that Ex. 1014 is a
`document that a POSITA
`would have relied upon at
`the relevant time.
`
`Respectfully submitted,
`
`By: /s/ Wayne M. Helge
`Wayne M. Helge (Reg. No. 56,905)
`Walter D. Davis (Reg. No. 45,137)
`DAVIDSON BERQUIST JACKSON & GOWDEY,
`LLP
`8300 Greensboro Drive, Suite 500
`McLean, VA 22102
`Telephone: 571-765-7700
`Fax: 571-765-7200
`Email: whelge@dbjg.com
`Email: wdavis@dbjg.com
`
` Counsel for Patent Owner
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`4
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`CERTIFICATE OF SERVICE
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`
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`I hereby certify that on October 7, 2016, a true and correct copy of the
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`foregoing Patent Owner’s Objections to Petitioner’s Reply Evidence is being filed
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`and served via email, by consent, to the Petitioner at the correspondence e-mail
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`LG-CoreWireless-IPR@gtlaw.com
`finnh@gtlaw.com
`harrisr@gtlaw.com
`maierse@gtlaw.com
`kudlack@gtlaw.com
`brownn@gtlaw.com
`cyrusa@gtlaw.com
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`
`
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`By: /s/ Wayne M. Helge
` USPTO Reg. No. 56,905
` Counsel for Patent Owner
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`5
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`addresses of record as follows:
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`Herbert H. Finn
`Richard D. Harris
`Eric J. Maiers
`Kevin Kudlac
`Nicholas A. Brown
`Ashkon Cyrus
`Greenberg Traurig, LLP
`77 W. Wacker Dr., Suite 3100
`Chicago, IL 60601
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`
`
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`