`IPR2016-01407
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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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`SONY CORPORATION, SONY MOBILE COMMUNICATIONS (USA) INC.,
`SONY MOBILE COMMUNICATIONS AB & SONY MOBILE
`COMMUNICATIONS INC.
`Petitioners
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`v.
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`CREATIVE TECHNOLOGY LIMITED
`Patent Owner
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`U.S. Patent No. 6,928,433
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`Case No. IPR2016-01407
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`PATENT OWNER’S OBJECTIONS TO EVIDENCE
`SERVED WITH PETITIONER’S REPLY
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner submits the following
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`Patent No. 6,928,433
`IPR2016-01407
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`objections to evidence served in connection with the Petitioner’s Reply on June 2,
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`2017. These objections have been timely filed and served within five business
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`days of the service of the evidence to which the objections are directed.
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`Patent Owner objects to Exhibits 1023 and 1024 as lacking authentication
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`(FRE 901), as containing hearsay (FRE 801), as irrelevant (FRE 402), and as
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`lacking foundation.
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`Patent Owner objects to the following statements in Exhibit 1020 as lacking
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`authentication (FRE 901), as containing hearsay (FRE 801), as irrelevant (FRE
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`402), as lacking foundation, and as lacking personal knowledge (FRE 602):
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` “ISO9241-14 was published June 1, 1997, ISO9241- 14 at i, Ex. 1024,
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`and is referenced in ISO 13407, which was published in 1999.” (Ex.
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`1020 ¶ 4).
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` “Petitioners’ counsel has informed me ISO9241-14 qualifies as prior
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`art to the ’433 patent under 35 U.S.C. §102(b).” (Ex. 1020 ¶ 4).
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` “A POSA further would have understood ISO9241-14 to explain that
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`‘hierarchical’ and ‘network’ menu structures were as of 1997 a known
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`solution to this difficulty” ).” (Ex. 1020 ¶ 7).
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` “Accordingly, at the time of the invention, a POSA would have
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`understood from ISO9241-14 that if a large number of menu options
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`were to be displayed, a long scrollable list should not be used when
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`Patent No. 6,928,433
`IPR2016-01407
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`rapid search time is important, and instead a ‘hierarchical’ or
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`‘network’ menu structure should be used, which would organize menu
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`options into conventional groups known to users.” (Ex. 1020 ¶ 8).
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`Date: June 9, 2017
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`Respectfully submitted,
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`/Jonathan D. Baker/
`Jonathan D. Baker, Reg. No. 45708
`Farney Daniels PC
`411 Borel Avenue, Suite 310
`San Mateo, California 94402
`Phone: 424-268-5210
`E-mail: JBaker@farneydaniels.com
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`CERTIFICATE OF SERVICE
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`Patent No. 6,928,433
`IPR2016-01407
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`The undersigned hereby certifies that a copy of the foregoing Patent
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`Owner’s Objections to Evidence Served with Petitioner’s Reply was served via
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`email on June 9, 2017, on the attorneys for the Petitioners:
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`Randy J. Prizker, Reg. No. 35,986
`Micahel N. Rader, Reg. No. 52,146
`Andrew J. Tibbetts, Reg. No. 65,139
`Wolf Greenfield & Sacks, P.C.
`600 Atlantic Avenue
`Boston, MA 02210-2206
`Phone: 617-646-8000
`Fax: 617-646-8646
`E-mail: RPritzker-PTAB@wolfgreenfield.com
`MRader-PTAB@wolfgreenfield.com
`ATibbetts-PTAB@wolfgreenfield.com
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`/Jonathan D. Baker/
`Jonathan D. Baker, Reg. No. 45708
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`Date: June 9, 2017
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