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`PETITIONER’S OBJECTIONS TO EXHIBITS
`PURSUANT TO 37 C.F.R. § 42.64
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`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`10152026
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`PRIME FOCUS CREATIVE SERVICES CANADA INC.,
`Petitioner
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`v.
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`LEGEND3D, INC.,
`Patent Owner
`___________________
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`
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`CASE IPR2016-01243
`Patent 7,907,793
`___________________
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`A. OBJECTIONS TO EXHIBIT 2018
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`Petitioner objects to Ex. 2018, which Patent Owner asserts is a copy of the
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`deposition transcript of Dr. David Forsyth in IPR2016-00806. Grounds for
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`objection: 37 C.F.R. § 42.53(f); F.R.E. 106 and 1002. This document is not signed
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`by the deponent, nor does it include the errata sheets prepared by the deponent. As
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`such, this “rough” transcript is incomplete, inaccurate, and does not comply with the
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`applicable statutory requirements.
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`B. OBJECTIONS TO EXHIBIT 2024
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`Petitioner hereby objects to Ex. 2024, which purports to be a declaration from
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`Mr. Carlos Vazquez. Grounds for objection: 37 C.F.R. § 42.65; F.R.E. 702 and 703.
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`This declaration contains opinions for which the factual bases have not been
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`disclosed, including numerous conclusory statements made without citation to
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`evidence or explanation. See, e.g., Ex. 2024 at ¶¶ 43-44 (offering a claim
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`construction of the term “depth parameter” without any specific citation to the ‘793
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`Patent); see generally id. at Sections VI through IX. This declaration contains
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`statements based on unreliable analysis or methods, including statements that are
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`demonstrably false. See, e.g., id. at ¶ 14 (Mr. Vazquez claiming that he reviewed his
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`own declaration “In preparation” of the same declaration); see generally id. at
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`Sections VI through IX. This document contains statements that are not actually
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`Mr. Vazquez’s opinion, as will be further probed in subsequent discovery. See, e.g.,
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`10152026
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`- 1 -
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`IPR2016-01243
`Patent 7,907,793
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`id. at ¶ 32 (claiming that “perceived shape implies perceived depth”); see generally
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`id. at Sections VI through IX.
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`Date: March 31, 2017
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` Respectfully submitted,
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` By: /Joshua Glucoft/
` Joshua Glucoft, Esq. (Reg. No. 67,696)
` Irell & Manella LLP
`Attorneys for Patent Owner Prime Focus
`Creative Services Canada Inc.
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`10152026
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`IPR2016-01243
`Patent 7,907,793
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. 42.6, the undersigned certifies that on March 31, 2017,
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`a copy of the foregoing document was served electronically to the email addresses
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`listed below:
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`Daniel N. Yannuzzi, Reg. No. 36,727
`Trevor J. Quist, Reg. No. 75,856
`Sheppard Mullin Richter & Hampton LLP
`12275 El Camino Read, Ste. 200
`San Diego, A 92130
`(858)720-8924
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`dyannuzzi@sheppardmullin.com
`tquist@sheppardmullin.com
`Sheppard-Legend3DIPR@sheppardmullin.com
`DM-PatentTm-Legend3DIPRs@sheppardmullin.com
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`/s/Susan M. Langworthy
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` Susan M. Langworthy
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`IPR2016-01243
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`10152026
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