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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`Petitioner,
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`v.
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`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
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`Case IPR2016-01378
`Patent 6,197,696 B1
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`PETITIONER’S OBJECTIONS TO PATENT OWNER’S EVIDENCE
`SUBMITTED DURING THE PRELIMINARY PROCEEDING
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`IPR2016—0l378
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`Patent 6,197,696 B1
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`In accordance with 37 C -F.R. § 42.64(b)(l), Petitioner Taiwan
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`Semiconductor Manufacturing Company, Ltd. hereby submits a list of objections to
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`Patent Owner IP Bridge’s Exhibit 2004 submitted during the preliminary
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`proceeding, identified in the chart below:
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`.
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` E h'b't
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`2004
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`S-M. Kaplan, Wiley Electrical and Electronics Engineering Dictionary
`(2004) (excerpted)
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`I.
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`Objection to Patent Owner’s Exhibit 2004—Irrelevant and Non-
`Probative Evidence
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`Patent Owner’s Exhibit 2004 is irrelevant to any material facts at issue in
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`these proceedings, and any probative Value Patent Owner may try to assign them is
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`substantially outweighed by their tendency to confuse the issues, mislead the
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`Board, waste time, and needlessly present cumulative evidence. Exhibit 2004 is
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`therefore inadmissible under Fed. R. Evid. 401, 402, and 403.
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`Exhibit 2004, which bears a copyright date of 2004, appears to have been
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`published years after the date of invention (March 23, 1999, see Paper 11, at 19-
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`26). It thus provides only “impermissible .
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`. later knowledge about later art-
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`related facts,” In re Hogan, 559 F.2d 595, 605 (CCPA 1977), and is irrelevant.
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`IPR2016-01378
`Patent 6,197,696 B1
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`Dated: February 1, 2017
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`Respectfully submitted,
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`By: /Darren M. Jiron/
`Darren M. Jiron
`Reg. No. 45,777
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`Lead Counsel for Petitioner
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`IPR2016-01378
`Patent 6,197,696 B1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), this is to certify that I served a true and
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`correct copy of the Petitioner’s Objections to Patent Owner’s Evidence
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`Submitted During the Preliminary Proceeding by electronic mail, on this 1st
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`day of February, 2017, on counsel of record for the Patent Owner as follows:
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`J. Steven Baughman
`steven.baughman@ropesgray.com
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`Andrew N. Thomases
`andrew.thomases@ropesgray.com
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`IPBridgeTSMCPTABService@ropesgray.com
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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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`Dated: February 1, 2017
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