`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Ghiam, Armin
`Wednesday, November 29, 2017 5:54 PM
`'Jennifer Meredith'
`'Darius Keyhani'; Mortazavi, Sheila; Billah, Zaed; Quan, Liberty
`IPR2017-00117 & IPR2017-01036 - Kawasaki Rail Car v. Blair
`
`Counsel,
`
`At the depositions of Lowell Malo, counsel for Patent Owner marked as Patent Owner Exhibit 8 a document entitled
`“CPSC Guidelines For Television Receive Safety.” This document is allegedly authored by the United States Consumer
`Product Safety Commission.
`
`As indicated yesterday, Kawasaki objects to Exhibit 8. Under Fed. R. Evid. 802, Exhibit 8 constitutes inadmissible hearsay
`for which no exception has been established to the extent it is offered by Patent Owner to prove the truth of any matter
`asserted therein. Kawasaki further objects to Exhibit 8 as irrelevant pursuant to Fed. R. Evid. 401, and therefore
`inadmissible under Fed. R. Evid. 402 or Fed. R. Evid. 403. In particular, Exhibit 8 is irrelevant for any non-hearsay
`purpose. If Patent Owner attempts to include Exhibit 8 as all or part of a 37 CFR 42.63 Exhibit, Kawasaki will maintain
`these objections.
`
`Sincerely,
`
`Armin Ghiam
`Associate
`
`
`ANDREWS KURTH KENYON LLP
`One Broadway | New York, NY 10004-1007
`+1.212.908.6207 Phone | +1.212.425.5288 Fax
`+1.212.908.6196 Assistant - Rose Macera
`email | vCard | Bio | andrewskurthkenyon.com | Twitter
`
`
`
`1
`
`KAWASAKI-1029
`
`
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