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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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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY LIMITED,
`and GLOBALFOUNDRIES U.S. INC.,
`Petitioners,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`Cases. IPR2016-01249 and IPR2016-012641
`U.S. Patent No. 6,538,324
`____________
`
`
`JOINT LIST OF OBJECTIONS TO DEMONSTRATIVES
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`1 GlobalFoundries U.S. Inc.’s motion for joinder in Cases IPR2017-00919 and
`IPR2017-00920 was granted.
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`Petitioner objects to Patent Owner slides 9, 14, and 57.
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`Slide 57 is objected to because it contains new arguments about Figure 1
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`from Exhibit 2039, which is a figure that Patent Owner did not previously rely
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`upon in its Motion to Amend.
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`
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`Slide 14 contains new arguments because Patent Owner only cited to Exhibit
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`1004, 3:62-64 in its Patent Owner Response, but copies a larger disclosure from
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`3:62-67 (including an additional sentence not previously relied upon) in this slide.
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`Slide 9 contains new arguments because Patent Owner only cited to Exhibit
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`1004, 9:47 in its Patent Owner Responses, but copies a larger disclosure from 9:47-
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`50 in this slide.
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`Patent Owner objects to Petitioner’s slides 16, 30, 31, 35, 38, 39, 51, 50
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`and 64 for the reasons set forth below:
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`Slides 35 and 51 refer to new evidence Ex.1033 in its Replies to support its
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`case-in-chief, and neither exhibit is cited in the Petitions or Responses. These
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`exhibits should be limited to the Contingent Motion to Amend.
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`Slides 38 and 64 refer to new evidence Ex.2042 in its Replies to support its
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`case-in-chief, and neither exhibit is cited in the Petitions or Responses. These
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`exhibits should be limited to the Contingent Motion to Amend.
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`Slides 16, 30, 31, 39 and 50 are objected to for referring to new arguments
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`and/or new evidence not raised or cited in the Petitions.
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`Date: August 3, 2017
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`By: /Stephen E. Kabakoff/
`
`Stephen E. Kabakoff
`Reg. No. 51,276
`
`Backup Counsel for Petitioner
`
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`Respectfully submitted,
`
`
`
`By: /Michael J. Fink/
`
`Michael J. Fink
`Reg. No. 31,827
`
`Lead Counsel for Patent Owner
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing JOINT LIST
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`OF OBJECTIONS TO DEMONSTRATIVES was served on August 3, 2017,
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`via email directed to counsel of record for the Patent Owner at the following:
`
`Michael J. Fink (Reg. No. 31,827)
`mfink@gbpatent.com
`
`Neil F. Greenblum (Reg. No. 28,394)
`ngreenblum@gbpatent.com
`
`Arnold Turk (Reg. No. 33,094)
`aturk@gbpatent.com
`
`Greenblum & Bernstein, P.L.C.
`1950 Roland Clarke Place
`Reston, Virginia 20191
`Tel: 703-716-1191
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`Patent Owner has agreed to electronic service.
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`A copy of the foregoing JOINT LIST OF OBJECTIONS TO
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`DEMONSTRATIVES was also served on August 3, 2017, via email directed to
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`counsel of record for Petitioner GlobalFoundries U.S. Inc. at the following:
`
`David Tennant (dtennant@whitecase.com);
`Shamita Etienne-Cummings (setienne@whitecase.com);
`Allen Wang (allen.wang@whitecase.com);
`wcptab@whitecase.com;
`WCGlobalFoundriesIPR1Team@whitecase.com.
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`Dated: August 3, 2017
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`By: /Lauren K. Young/
`Lauren K. Young
`Litigation Legal Assistant
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, L.L.P.
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