`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC., AND LG ELECTRONICS, INC.
`Petitioners
`
`
`
`
`
`v.
`
`Papst Licensing GMBH & CO. KG,
`Patent Owner
`
`
`
`Case No: IPR2016-017331
`U.S. Patent No. 9,189,437
`
`
`JOINT OBJECTIONS
`TO DEMONSTRATIVE EXHIBITS
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`1 IPR2017-01038 has been joined with this proceeding.
`
`
`
`Case No. IPR2016-01733
`Patent No. 9,189,437
`
`Petitioners and Patent Owner hereby submit the following objections to the
`
`opposing parties’ demonstrative exhibits that the parties were unable to resolve:
`
`Petitioners’ Objections:
`Slide 3, Bullet 6: Contains an argument regarding “transfer of the correct file
`requested,” which is not supported by the cited evidence, was not previously made,
`and constitutes new argument.
`Slide 3, Bullet 9: Same objection as Slide 3, Bullet 6.
`Slide 4: The title of the slide presents a new argument and is overbroad as it relates
`to any specialized software beyond specialized software required for data transfer.
`Slide 17: The title of the slide is misleading and misrepresents the record because
`not all of Gafford’s testimony regarding CATSYNC.VXD is undisputed.
`
`Patent Owner’s Objections:
`Slide 58: Slide contains reproduction of portion of Petition and cited evidence
`therein not previously identified with respect to A/D converter limitation of claim
`41 and therefore constitutes new argument and evidence.
`Slide 59: Same objection as Slide 58.
`Slide 61: Same objection as Slide 58.
`
`
`
`
`
`
`Dated: October 25, 2017
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Carrie A. Beyer/
`
`
`
`
`Carrie A. Beyer
`Registration No. 59,195
`Carrie.Beyer@dbr.com
`Counsel for Petitioners Samsung Electronics
`Co., Ltd. and Samsung Electronics America,
`Inc.
`
`Nicholas T. Peters
`Registration No. 53,456
`Lead Counsel for Patent Owner
`ntpete@fitcheven.com
`
`1
`
`
`
`Case No. IPR2016-01733
`Patent No. 9,189,437
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on October 25,
`
`2017, a complete and entire copy of the above paper has been served in its entirety
`
`by e-mail on the following addresses of record for Counsel:
`
`Ntpete@fitcheven.com,
`
`phenkelmann@fitcheven.com,
`
`Brian.Rupp@dbr.com,
`
`Carrie.Beyer@dbr.com,
`
`Nick.Colic@dbr.com,
`
`LG-Papst-IPR@gtlaw.com,
`
`finnh@gtlaw.com, and
`
`girouxj@gtlaw.com
`
`
`
`Dated: October 25, 2017
`
`
`
`
`By:
`
`/Carrie A. Beyer/
`
`
`
`
`
`
`
`
`
`2
`
`
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