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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`Petitioner,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`
`
`Case IPR2016-01379
`Patent 6,197,696 B1
`
`
`PETITIONER’S OBJECTIONS TO PATENT OWNER’S EVIDENCE
`SUBMITTED DURING THE PRELIMINARY PROCEEDING
`
`
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`

`

`IPR2016—0 1 379
`
`Patent 6,197,696 B1
`
`In accordance with 37 C -F.R. § 42.64(b)(l), Petitioner Taiwan
`
`Semiconductor Manufacturing Company, Ltd. hereby submits a list of objections to
`
`Patent Owner IP Bridge’s Exhibit 2004 submitted during the preliminary
`
`proceeding, identified in the chart below:
`
`.
`
`.
`
` E h'b't
`
`
`2004
`
`S-M. Kaplan, Wiley Electrical and Electronics Engineering Dictionary
`(2004) (excerpted)
`
`I.
`
`Objection to Patent Owner’s Exhibit 2004—Irrelevant and Non-
`Probative Evidence
`
`Patent Owner’s Exhibit 2004 is irrelevant to any material facts at issue in
`
`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.
`
`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 .
`
`.
`
`. later knowledge about later art-
`
`related facts,” In re Hogan, 559 F.2d 595, 605 (CCPA 1977), and is irrelevant.
`
`

`

`IPR2016-01379
`Patent 6,197,696 B1
`
`Dated: February 1, 2017
`
`Respectfully submitted,
`
`By: /Darren M. Jiron/
`Darren M. Jiron
`Reg. No. 45,777
`
`
`
`Lead Counsel for Petitioner
`
`
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` 2
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`
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`
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`

`

`IPR2016-01379
`Patent 6,197,696 B1
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), this is to certify that I served a true and
`
`
`
`correct copy of the Petitioner’s Objections to Patent Owner’s Evidence
`
`Submitted During the Preliminary Proceeding by electronic mail, on this 1st
`
`day of February, 2017, on counsel of record for the Patent Owner as follows:
`
`J. Steven Baughman
`steven.baughman@ropesgray.com
`
`Andrew N. Thomases
`andrew.thomases@ropesgray.com
`
`IPBridgeTSMCPTABService@ropesgray.com
`
`
`
`
`
`
`
`
`
`
`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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`

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