`U.S. Patent No. 6,538,324
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`Filed on behalf of Godo Kaisha IP Bridge 1
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`By: Michael J. Fink (mfink@gbpatent.com)
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: (703) 716-1191
`Fax: (703) 716-1180
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY LIMITED,
`Petitioner,
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`v.
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`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`Case IPR2016-01264
`U.S. Patent No. 6,538,324
`____________
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`PATENT OWNER’S NOTICE OF SUPPLEMENTAL EVIDENCE IN
`RESPONSE TO PETITIONER’S OBJECTIONS TO EXHIBITS
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`Mail Stop PATENT BOARD, PTAB
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
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` Case IPR2016-01264 for
`U.S. Patent No. 6,538,324
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`Patent Owner, Godo Kaisha IP Bridge 1 (“Patent Owner”), submits this
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`Notice of Supplemental Evidence in Response to “Petitioner’s Objections to Patent
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`Owner’s Exhibits 2001-2004” dated January 3, 2017. In response to Petitioner’s
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`objections, Patent Owner serves herewith supplemental evidence, identified as
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`Exhibits 2005, 2006 and 2007 pursuant to 37 C.F.R. § 42.64(b)(2). Patent Owner
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`further files and serves herewith Patent Owner’s Current Exhibit List pursuant to
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`37 C.F.R. § 42.63(e). Patent Owner’s Current Exhibit List identifies its
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`supplemental evidence, Exhibits 2005, 2006 and 2007.
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`I. Petitioner’s Objections to Exhibit 2001
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`Petitioner objects to Exhibit 2001 under FRE 401-403 alleging that the
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`exhibit is irrelevant because it presents cumulative information. Exhibit 2001 does
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`not present cumulative information.
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`Petitioner objects to Exhibit 2001 as hearsay under FRE 802. Exhibit 2001
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`is not inadmissible hearsay under FRE 801, and would nevertheless be admissible
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`under one or more of the hearsay exceptions under FRE 803 and 807, e.g., FRE
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`803(18). In the event Patent Owner seeks to exclude Exhibit 2001 for any reason,
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`Patent Owner reserves the right to seek judicial notice under FRE 201 of scientific
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`facts contained therein, the accuracy of which Petitioner has not disputed.
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`II. Petitioner’s Objections to Exhibit 2002
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` Case IPR2016-01264 for
`U.S. Patent No. 6,538,324
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`Petitioner objects to Exhibit 2002 under FRE 401-403 as irrelevant. Exhibit
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`2002, a portion of the prosecution history of the Ding patent, is not irrelevant.
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`Exhibit 2002 is additional evidence of how a person of ordinary skill in the art
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`would have understood the Ding patent at the relevant time period. Exhibit 2002
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`confirms the express teachings in the Ding patent.
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`In the event Patent Owner seeks to exclude Exhibit 2002, Patent Owner
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`reserves the right to seek judicial notice under FRE 201 of undisputed statements
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`contained therein.
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`III. Petitioner’s Objections to Exhibits 2003 and 2004
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`Petitioner objects to Exhibits 2003 and 2004 under FRE 401-403 as
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`irrelevant because of the dates of the dictionary definitions. Exhibits 2005 and
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`2006 are submitted to overcome these objections. Exhibit 2007 authenticates these
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`exhibits.
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`In the event Patent Owner seeks to exclude Exhibits 2003 and 2004, or
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`Exhibits 2005 and 2006, Patent Owner reserves the right to seek judicial notice
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`under FRE 201 of the apparently undisputed dictionary definitions.
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`Patent Owner reserves all rights to respond to any further explanations
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`Petitioner is allowed to provide regarding its evidentiary objections. Patent
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`Owner’s service of supplemental evidence is timely under 37 C.F.R. § 42.64(b)(2)
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` Case IPR2016-01264 for
`U.S. Patent No. 6,538,324
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`because it is served within 10 business days of the service of Petitioner’s
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`objections.
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`Dated: January 11, 2017
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`
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`Respectfully Submitted by:
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`/Michael J. Fink/
`Michael J. Fink
`Registration No. 31,827
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: mfink@gbpatent.com
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`Attorney for Patent Owner,
`IP Bridge
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`3
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`{R50502 02985245.DOC}
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`Case IPR2016-01264
`for U.S. Patent No. 6,538,324
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true copy of the foregoing:
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`PATENT OWNER’S NOTICE OF SUPPLEMENTAL EVIDENCE IN
`RESPONSE TO PETITIONER’S OBJECTIONS TO EXHIBITS
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`including exhibits, was served by electronic mail on this 11th day of January,
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`2017, upon Counsel for Petitioner, as follows:
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`E. Robert Yoches (bob.yoches@finnegan.com);
`Stephen E. Kabakoff (stephen.kabakoff@finnegan.com);
`Joshua L. Goldberg (joshua.goldberg@finnegan.com); and
`TSMC-IPB-PTAB@finnegan.com.
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`
`
`/Michael J. Fink/
`Michael J. Fink
`Registration No. 31,827
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
`Fax: 703-716-1180
`Email: mfink@gbpatent.com
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