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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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`GLOBAL TEL*LINK CORPORATION
`Petitioner
`
`v.
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`SECURUS TECHNOLOGIES, INC.
`Patent Owner
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`___________________
`
`Case IPR2016-01362
`Patent 9,083,850
`___________________
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`PETITIONER GLOBAL TEL*LINK CORPORATION’S
`OBJECTIONS TO PATENT OWNER’S DEMONSTRATIVES
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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 22313-14
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`
`
`Case IPR2016-01362
`U.S. Patent No. 9,083,850
`Pursuant to the Board’s Trial Hearing Order (Paper 35), Petitioner submits
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`
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`the following objections to Patent Owner’s demonstrative exhibits, served on
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`Petitioner on September 7, 2017. (Paper 35, pp. 3-4.)
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`1.
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`Petitioner objects to Patent Owner’s Slide 8, titled “Level of Ordinary
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`Skill,” because Slide 8 relies on evidence, for example, paragraph 52 of Dr.
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`Bovik’s declaration, that was never cited in any paper before the Board. St. Jude
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`Medical, Cardiology Division, Inc. v. The Board of Regents of the University of
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`Michigan, IPR2013-00041, Paper 65 at 2-3 (P.T.A.B. Jan. 27, 2014).
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`2.
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`Petitioner objects to Patent Owner’s Slide 14, titled “The Term ‘depth
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`of field’ Means ‘the distance between the nearest and farthest objects in a scene
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`that appear acceptably sharp in an image,’” because Slide 14 relies on evidence, for
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`example, Dr. Richardson’s deposition testimony, that was never cited in any paper
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`before the Board. St. Jude Medical, Paper 65 at 2-3.
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`3.
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`Petitioner objects to Patent Owner’s Slide 15, titled “The Term ‘depth
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`of field’ Means ‘the distance between the nearest and farthest objects in a scene
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`that appear acceptably sharp in an image,’” because Slide 15 contains new
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`arguments that rely on citations to Dr. Richardson’s deposition testimony, which
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`were not previously presented in any paper before the Board. St. Jude Medical,
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`Paper 65 at 3.
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`
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`- 1 -
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`4.
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`Petitioner objects to Patent Owner’s Slide 18, titled “The Term ‘depth
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`of field’ Means ‘the distance between the nearest and farthest objects in a scene
`
`that appear acceptably sharp in an image,’” because Slide 18 contains new
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`arguments that directly respond to Petitioner’s Reply and were not previously
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`presented in any paper before the Board. St. Jude Medical, Paper 65 at 3.
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`5.
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`Petitioner objects to Patent Owner’s Slide 19, titled “The Phrase ‘a
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`depth of field parameter for the video’ Means ‘any set of properties of a camera
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`system that determines a depth of field,’” because Slide 19 contains new arguments
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`not previously presented in any paper before the Board, for example discussing a
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`“blurring parameter.” St. Jude Medical, Paper 65 at 3.
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`6.
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`Petitioner objects to Patent Owner’s Slide 22, titled “The Phrase ‘a
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`depth of field parameter for the video’ Means ‘any set of properties of a camera
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`system that determines a depth of field,’” because Slide 22 adds new evidence
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`(e.g., images with captions) not in the record or previously presented in any paper
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`before the Board. St. Jude Medical, Paper 65 at 2.
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`7.
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`Petitioner objects to Patent Owner’s Slides 26, 29-31, and 35-37, each
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`titled “The Phrase ‘a depth of field parameter for the video’ Means ‘any set of
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`properties of a camera system that determines a depth of field,’” because Slides 26,
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`29-31, and 35-37 contain new arguments that directly respond to Petitioner’s Reply
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`- 2 -
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`and were not previously presented in any paper before the Board. St. Jude Medical,
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`Paper 65 at 3.
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`8.
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`Petitioner objects to Patent Owner’s Slides 27 and 28, both titled “The
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`Claimed Inventions of the ’850 Patent vs. Prior Art Object and Facial-Recognition
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`Techniques,” because Slides 27 and 28 add new evidence (e.g., images) not in the
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`record or previously presented in any paper before the Board. St. Jude Medical,
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`Paper 65 at 2.
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`9.
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`Petitioner objects to Patent Owner’s Slides 32 and 33, both titled “The
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`Phrase ‘a depth of field parameter for the video’ Means ‘any set of properties of a
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`camera system that determines a depth of field,’” because Slides 32 and 33 contain
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`new arguments and evidence that directly respond to Petitioner’s Reply and were
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`not previously presented in any paper before the Board. St. Jude Medical, Paper 65
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`at 2-3.
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`10. Petitioner objects to Patent Owner’s Slides 42-45, each titled
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`“Garrison Fails to Disclose ‘adjusting a depth of field parameter for the video,’”
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`because Slides 42-45 contain new arguments that directly respond to Petitioner’s
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`Reply and were not previously presented in any paper before the Board. St. Jude
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`Medical, Paper 65 at 3.
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`11. Petitioner objects to Patent Owner’s Slide 49, titled “Persons of
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`Ordinary Skill Would Not Have Combined Shipman and Garrison with Mayhew to
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`- 3 -
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`Arrive at the Claimed Inventions,” because Slide 49 adds new evidence (e.g.,
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`images with captions) not in the record or previously presented in any paper before
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`the Board. St. Jude Medical, Paper 65 at 2.
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`12. Petitioner objects to Patent Owner’s Slide 50, titled “Persons of
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`Ordinary Skill Would Not Have Combined Shipman and Garrison with Mayhew to
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`Arrive at the Claimed Inventions,” because at least the third bullet point of Slide 50
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`contains new arguments not previously presented in any paper before the Board.
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`St. Jude Medical, Paper 65 at 3.
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`
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`Date: September 11, 2017
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`Respectfully submitted,
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`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/ Byron L. Pickard /
`
`Byron L. Pickard (Registration No. 65,172)
`Attorney for Petitioner
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`- 4 -
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that on September 11, 2017 the foregoing
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`PETITIONER GLOBAL TEL*LINK CORPORATION’S OBJECTIONS TO
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`PATENT OWNER’S DEMONSTRATIVES were served electronically via e-
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`mail in their entireties on the following counsel of record for Patent Owner:
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`Nicholas C. Kliewer (Lead Counsel)
`Jeffrey B. Bragalone (Back up Counsel)
`Daniel F. Olejko (Back up Counsel)
`Terry A. Saad (Back up Counsel)
`Justin B. Kimble (Back up Counsel)
`BRAGALONE CONROY PC
`jkimble-IPR@bcpc-law.com
`jbragalone@bcpc-law.com
`dolejko@bcpc-law.com
`tsaad@bcpc-law.com
`nkliewer@bcpc-law.com
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` STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
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`/ Byron L. Pickard /
`
`
`Byron L. Pickard (Registration No. 65,172)
`Attorney for Petitioner
`
`Date: September 11, 2017
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`
`
`
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