`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`
`
`TELIT WIRELESS SOLUTIONS INC.
`and
`TELIT COMMUNICATIONS PLC,
`Petitioners,
`
`v.
`
`M2M SOLUTIONS LLC,
`Patent Owner.
`
`
`
`Case IPR2016-00055
`Patent 8,648,717
`_______________
`
`
`
`
`
`M2M SOLUTIONS LLC’S OBJECTIONS TO EVIDENCE
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`M2M Solutions LLC’s Objections to Evidence
`IPR2016-00055
`
`
`Pursuant to 37 C.F.R. § 42.64 (b) Patent Owner, M2M Solutions LLC
`
`(“M2M”) objects under the Federal Rules of Evidence (“FRE”) to Exhibits 1105,
`
`1114, 1115, 1116, and 1122 cited in Telit Wireless Solutions Inc. and Telit
`
`Communications PLC.’s (collectively, “Telit”) Petition for Inter Partes Review
`
`(“Petition”).1 The Patent Trial and Appeal Board instituted trial on April 22,
`
`20162; therefore, M2M’s Objections to Evidence are timely under 37 C.F.R. §
`
`42.64(b)(1).
`
`I.
`
`OBJECTIONS TO EXHIBITS 1114, 1115, 1116, AND 1122
`
`Exhibit 1114: M2M objects to Exhibit 1114, Bettstetter C., “GSM
`
`Phase 2+ General Packet Radio Service GPRS: Architecture, Protocols, and Air
`
`Interface”, IEEE Communications Survey, 1999, because it is inadmissible hearsay
`
`under FRE 802; it has not been properly authenticated, as required by FRE 901;
`
`and this exhibit is not self-authenticating under FRE 902.
`
`Exhibit 1115: M2M objects to Exhibit 1115, Ames et al., “The
`
`Evolution of Third-Generation Cellular Standards”, Intel Technology Journal, Q2,
`
`2000, because it is inadmissible hearsay under FRE 802; it has not been properly
`
`authenticated, as required by FRE 901; and this exhibit is not self-authenticating
`
`
`1 Paper 1, filed October 21, 2015.
`
`2 See Paper 9, entered April 22, 2016.
`
`
`
`
`
`
`
`1
`
`
`
`M2M Solutions LLC’s Objections to Evidence
`IPR2016-00055
`
`under FRE 902
`
`Exhibit 1116: M2M objects to Exhibit 1116, 1G, 2G, 3G, 4G - The
`
`Evolution of Wireless Generations,” 2008, because it is inadmissible hearsay under
`
`FRE 802; it has not been properly authenticated, as required by FRE 901; and this
`
`exhibit is not self-authenticating under FRE 902.
`
`Exhibit 1122: M2M objects to Exhibit 1122, Redl et al. “GSM and
`
`Personal Communications Handbook,” 1998, because it is inadmissible hearsay
`
`under FRE 802; it has not been properly authenticated, as required by FRE 901;
`
`and this exhibit is not self-authenticating under FRE 902.
`
`II. OBJECTIONS TO EXHIBIT 1105
`
`M2M objects to paragraphs 35, 88, 97, 98, 104, and 105, in Exhibit 1105,
`
`under FRE 703, to the extent those paragraphs rely on Exhibit 1114, which M2M
`
`has objected to as inadmissible evidence.
`
`M2M objects to paragraphs 35, 47, 48, 83, and 104 in Exhibit 1105, under
`
`FRE 703, to the extent those paragraphs rely on Exhibit 1115, which M2M has
`
`objected to as inadmissible evidence.
`
`M2M objects to paragraph 47 in Exhibit 1105, under FRE 703, to the extent
`
`that paragraph relies on Exhibit 1116, which M2M has objected to as inadmissible
`
`evidence.
`
`M2M objects to paragraphs 47, 48, 83, 104, 118, and 202 in Exhibit 1105,
`
`2
`
`
`
`M2M Solutions LLC’s Objections to Evidence
`IPR2016-00055
`
`under FRE 703, to the extent those paragraphs rely on Exhibit 1122, which M2M
`
`has objected to as inadmissible evidence.
`
`
`
`Dated: May 6, 2016
`
`
`
`Respectfully Submitted,
`
`/s/ Jeffrey N. Costakos
`Jeffrey N. Costakos
`Registration Number 34,144
`Attorney for Patent Owner
`Foley & Lardner LLP
`777 East Wisconsin Avenue
`Milwaukee, WI 53202-5306
`Telephone: 414-297-5782
`Email: jcostakos@foley.com
`
`
`
`3
`
`
`
`M2M Solutions LLC’s Objections to Evidence
`IPR2016-00055
`
`
`
`CERTIFICATION OF SERVICE
`
`
`The undersigned hereby certifies that the above-captioned M2M
`SOLUTIONS LLC’S OBJECTIONS TO EVIDENCE was served in its entirety
`on May 6, 2016, upon the following parties via e-mail:
`
`cpollack@pearlcohen.com
`meadan@ pearlcohen.com
`gyonay@ pearlcohen.com
`
`FOLEY & LARDNER LLP
`
`/s/ Michelle A. Moran
`Michelle A. Moran
`Pro Hac Vice
`Back-up Attorney for Patent Owner
`M2M Solutions LLC
`
`777 East Wisconsin Avenue
`Milwaukee, WI 53202-5306
`Telephone: 414-297-5629
`E-mail: mmoran@foley.com
`
`
`
`
`Date: May 6, 2016
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