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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE, INC.,
`Petitioner
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`v.
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`UNILOC USA, INC. and UNILOC LUXEMBOURG S.A.,
`Patent Owners
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`Case IPR2017-00221 (Patent 7,353,890)
`Case IPR2017-00222 (Patent 8,243,723)
`Case IPR2017-00225 (Patent 8,995,433)
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`JOINT FILING LISTING
`OBJECTIONS TO DEMONSTRATIVES
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`Pursuant to the Board’s Order that the parties may file jointly a one-page list of
`objections, the parties submit the following:
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`Uniloc’s objections
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`1. Uniloc objects to the following slides because they seek to introduce new
`argument and evidence without citation to the briefing: (a) slides 4-5, 38-43
`for IPR2017-00221; and (b) slides 5 - 6, 16, 34, 43 and 51-57 for IPR2017-0225.
`CBS Interactive Inc. v. Helferich Patent Licensing, LLC, IPR2013-00033, Paper
`118 at 2 (Oct. 23, 2013) (“CBS”).
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`2. Uniloc objects to the following slides because they seek to introduce arguments
`and evidence that were impermissibly raised for the first time in Petitioner’s reply
`(including Petitioner’s new argument that an “internal server system” means a
`server with “multiple components”): (a) 7, 19-22, 24, 28-29, 32-36 of IPR2017-
`0221; and (b) 8, 12-13, 21, 26, 29-30, 49 for IPR2017-0222. See 37 C.F.R. §
`42.23; Intelligent Bio-Systems, Inc. v. Illumina Cambridge Ltd., 821 F.3d 1359
`(Fed. Cir. 2016) (“Unlike district court litigation—where parties have greater
`freedom to revise and develop their arguments over time and in response to newly
`discovered material—the expedited nature of IPRs bring with it an obligation for
`petitioners to make their case in their petition to institute.”).
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`3. Uniloc objects to the demonstratives as being overly cumbersome for the Board
`and Uniloc to determine whether something is new by totaling 237 pages in total
`and by making multiple arguments and citing multiple pages of sources without
`identifying which pages of which sources support which arguments. CBS at 4.
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`Petitioner’s objections
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`None.
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`Date: February 1, 2018
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`Respectfully submitted,
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`By: /s/ Brett A. Mangrum
`Brett A. Mangrum
`Attorney for Patent Owners
`Reg. No. 64,783
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`/Jason D. Eisenberg/
`Jason D. Eisenberg
`Registration No. 43,447
`Attorney for Petitioner Apple Inc.
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`CERTIFICATE OF SERVICE
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` I
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` certify that an electronic copy of the foregoing JOINT FILING LISTING
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`OBJECTIONS TO DEMONSTRATIVES was served via email to Petitioner’s
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`counsel of record at the following address:
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`PETITIONER:
`Jason D. Eisenberg: jasone-PTAB@skgf.com
`Michael D. Specht: mspecht-PTAB@skgf.com
`Zhu He: zhe-PTAB@skgf.com
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`Date: February 1, 2018
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`Respectfully submitted,
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`By: /s/ Brett A. Mangrum
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`Brett A. Mangrum
`Attorney for Patent Owners
`Reg. No. 64,783
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