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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner
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`v.
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`CHESTNUT HILL SOUND INC.,
`Patent Owner
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`Case IPR2016-00794
`Patent 8,090,309
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`PETITIONER’S OBJECTIONS TO PATENT OWNER’S
`DEMONSTRATIVE EXHIBITS
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`Case IPR2016-00794
`Attorney Docket No: 39521-0016IP2
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`Petitioner objects to Patent Owner’s bringing the George™ product to the
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`oral hearing. The George™ product is new evidence; not of record. Petitioner
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`objects to service of these demonstratives as untimely. They were served on April
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`12 at 12:50am ET, after the April 11th deadline. Petitioner objects, as follows, to
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`Patent Owner’s slides as including new evidence and/or new argument:
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`Slides
`8
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`Objections
`New evidence: These portions of the ’309 patent are not specifically
`discussed in the papers of record and are suggestive of new argument.
`10 New evidence: The excerpts from AbiEzzi and Baumgartner and the
`newly-introduced picture are not evidence discussed in the papers of
`record and are suggestive of new argument.
`12 New evidence: FIG. 4 of the ’309 patent is not specifically discussed in
`the papers of record and is suggestive of new argument
`19 New evidence: FIG. 3 of Baumgartner is not specifically discussed in the
`papers of record.
`New evidence: The excerpts from Mercer’s Deposition Transcript in these
`26,
`slides are not specifically discussed in the papers of record.
`30-31
`32 New evidence/argument: The excerpts from Mercer’s Deposition
`Transcript in these slides are not specifically discussed in the papers of
`record and the parenthetical is not an argument in a paper of record.
`36 New argument: The arguments in this slide are not in a paper of record.
`43 New argument/evidence: The arguments in this slide are not in a paper
`of record and the excerpts from Barton and Klemets are not specifically
`discussed in the papers.
`45 New argument: The arguments in this slide are not in a paper of record.
`New evidence: The slides feature portions of evidence not specifically
`47,
`51-52
`discussed in the papers of record.
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`1
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`Date: April 17, 2017
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`Case IPR2016-00794
`Attorney Docket No: 39521-0016IP2
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`Respectfully submitted,
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`/Joshua A. Griswold/
`Joshua A. Griswold
`Reg. No. 46,310
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`Attorney for Petitioner
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`2
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`Case IPR2016-00794
`Attorney Docket No: 39521-0016IP2
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(1) and 42.6(e)(4)(iii), the undersigned
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`certifies that on April 17, 2017, a complete and entire copy of this Petitioner’s
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`Objections to Patent Owner’s Demonstrative Exhibits was provided via email to
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`the Patent Owner by serving the email correspondence addresses of record as
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`follows:
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`Alexis (Steinberg) Mosser
`Hamad M. Hamad
`CALDWELL CASSADY CURRY, P.C.
`2101 Cedar Springs Road, Suite 1000
`Dallas, Texas 75201
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`Email: chillsound@caldwellcc.com
` cccptab@caldwellcc.com
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`/Diana Bradley/
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`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
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