Filed: May 24, 2017
`
`Ryan Thomas (pro hac vice)
`
`Ph.: (435) 630-6005
`E-mail:
`thomasattorney711@gmail.com
`
`
`Filed on behalf of Patent Owner Voip-Pal.com Inc.
`By:
`
`Kerry S. Taylor
`John M. Carson
`William R. Zimmerman (pro hac vice)
`KNOBBE, MARTENS, OLSON
`& BEAR, LLP
`2040 Main Street, 14th Floor
`Irvine, CA 92614
`
`Ph.: (858) 707-4000
`E-mail: BoxDigifonica@knobbe.com
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`
`Petitioner,
`
`v.
`
`
`
`
`
`VOIP-PAL.COM, INC.,
`
`Patent Owner
`
`
`
`
`Case No. IPR2016-01201
`U.S. Patent 8,542,815
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`PATENT OWNER OBJECTIONS TO APPLE EVIDENCE
`SERVED WITH PETITIONER’S REPLY
`
`
`
`
`
`
`Ryan Thomas (pro hac vice)
`
`Ph.: (435) 630-6005
`E-mail:
`thomasattorney711@gmail.com
`
`
`Filed on behalf of Patent Owner Voip-Pal.com Inc.
`By:
`
`Kerry S. Taylor
`John M. Carson
`William R. Zimmerman (pro hac vice)
`KNOBBE, MARTENS, OLSON
`& BEAR, LLP
`2040 Main Street, 14th Floor
`Irvine, CA 92614
`
`Ph.: (858) 707-4000
`E-mail: BoxDigifonica@knobbe.com
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.
`
`Petitioner,
`
`v.
`
`
`
`
`
`VOIP-PAL.COM, INC.,
`
`Patent Owner
`
`
`
`
`Case No. IPR2016-01201
`U.S. Patent 8,542,815
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`PATENT OWNER OBJECTIONS TO APPLE EVIDENCE
`SERVED WITH PETITIONER’S REPLY
`
`
`
`
`
`
`IPR2016-01201
`Apple Inc v. Voip-Pal
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner Voip-Pal.com, Inc.
`
`(“Voip-Pal”) hereby timely files its objections to the admissibility of evidence
`
`served with the Petitioner’s Reply to Patent Owner Response on May 17, 2017
`
`(Paper 34).
`
`Exhibit Number and
`Description
`Exhibit 1007
`
`Mangione-Smith
`Deposition Transcript
`
`Objections
`Completeness, Foundation, Relevance, Misleading (FRE
`106, 602, 401, 402, 403). Outside Scope of Direct
`Testimony.
`
`26:20-22 Does not support the contention for which it is
`cited, and the use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`45:8-21 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`47:25-49:14 Does not support the contention for which it is
`cited, and the use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`100:18-101:24 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`117:15-19 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`142:11-143:9 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner. Testimony lacked foundation.
`
`-1-
`
`
`
`Objections
`Testimony based on questions outside scope of direct
`testimony.
`
`143:17-144:11 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`150:21-154:1 Does not support the contention for which it is
`cited, and the use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`157:22-158:2 Does not support the contention for which it is
`cited, and the use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`
`
`Completeness, Relevance, Misleading (FRE 106, 401, 402,
`403)
`
`16:14-21:2 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`23:1-22 Does not support the contention for which it is
`cited, and the use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`24:15-19 and 25:1-5 The use of this testimony is misleading
`and incomplete when taken in isolation, and is used in a
`misleading manner.
`
`31:14-32:4 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`-2-
`
`IPR2016-01201
`Apple Inc v. Voip-Pal
`
`Exhibit Number and
`Description
`
`Exhibit 1008
`
`Rutter Deposition
`Transcript
`
`
`
`Objections
`Completeness, Relevance, Misleading (FRE 106, 401, 402,
`403)
`
`24:23-25:18 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`39:21-41:7 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`59:19-22 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`60:19-61:17 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`Completeness, Relevance, Misleading (FRE 106, 401, 402,
`403)
`
`45:8-46:9 Does not support the contention for which it is
`cited, and the use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`48:22-24 Does not support the contention for which it is
`cited, and the use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`48:25-50:12 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`
`
`
`-3-
`
`IPR2016-01201
`Apple Inc v. Voip-Pal
`
`Exhibit Number and
`Description
`Exhibit 1009
`
`Terry Deposition
`Transcript
`
`Exhibit 1010
`
`Perreault Deposition
`Transcript
`
`
`
`Objections
`57:18-20 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`59:3-23 Does not support the contention for which it is
`cited, and the use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`66:23-67:13 Does not support the contention for which it is
`cited, and the use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`79:25-80:21 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`
`
`Completeness, Relevance, Misleading (FRE 106, 401, 402,
`403)
`
`25:5-28:6 and 29:2-8 Do not support the contention for
`which they are cited, and the uses of this testimony are
`misleading and incomplete when taken in isolation, and are
`used in a misleading manner.
`
`83:15-86:5 and 85:24-86:5 Do not support the contention for
`which they are cited, and the uses of this testimony are
`misleading and incomplete when taken in isolation, and are
`used in a misleading manner.
`
`120:12-121:6 The use of this testimony is misleading and
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`120:24-122:1 The use of this testimony is misleading and
`
`-4-
`
`IPR2016-01201
`Apple Inc v. Voip-Pal
`
`Exhibit Number and
`Description
`
`Exhibit 1012
`
`Bjorsell Deposition
`Transcript
`
`
`
`Objections
`incomplete when taken in isolation, and is used in a
`misleading manner.
`
`
`
`IPR2016-01201
`Apple Inc v. Voip-Pal
`
`Exhibit Number and
`Description
`
`
`
`Respectfully submitted,
`
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`
`
`
`By: /Kerry Taylor/
`Kerry Taylor, Reg. No. 43,947
`John M. Carson, Reg. No. 34,303
`William R. Zimmerman, appears pro hac vice
`Customer No. 20,995
`(858) 707-4000
`
`Ryan Thomas, appears pro hac vice
`(435) 630-6005
`
`Attorneys for Patent Owner
`Voip-Pal.com, Inc.
`
`
`-5-
`
`
`
`
`
`
`
`Dated: May 24, 2017
`
`
`
`IPR2016-01201
`Apple Inc v. Voip-Pal
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that true and correct copy of PATENT OWNER
`
`OBJECTIONS TO APPLE EVIDENCE SERVED WITH PETITIONER’S
`
`REPLY is being served on May 24, 2017, via electronic mail pursuant to 37
`
`C.F.R. § 42.6(e) as addressed below:
`
`Adam P. Seitz
`Eric A. Buresh
`ERISE IPA, P.A.
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`Telephone: (913) 777-5600
`Adam.seitz@eriseip.com
`eric.buresh@eriseip.com
`
`
`
`
`
`Paul R. Hart
`ERISE IPA, P.A.
`5600 Greenwood Plaza Blvd., Suite 200
`Greenwood Village, CO 80111
`Telephone: (913) 777-5600
`Paul.Hart@EriseIP.com
`
`
`
`
`
`Dated: May 24, 2017
`
`25958725
`
`
`
`
` /Kerry Taylor/
`Kerry Taylor, Reg. No. 43,947
`John M. Carson, Reg. No. 34,303
`William R. Zimmerman, appears pro hac vice
`Customer No. 20,995
`(858) 707-4000
`
`Ryan Thomas (pro hac vice)
`(435) 630-6005
`
`Attorneys for Patent Owner Voip-Pal.com, Inc.
`
`-6-
`
`
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