`June 9, 2017
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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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`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioner
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`v.
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`IMAGE PROCESSING TECHNOLOGIES LLC,
`Patent Owner
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`Case IPR2017-00353
`U.S. Patent No. 8,983,134 B2
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`PAPER NO. 14
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`PATENT OWNER’S OBJECTIONS TO
`PETITIONER’S EVIDENCE
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`Paper 14
`June 9, 2017
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner, Image Processing
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`Technologies LLC (“IPT”) objects to the admissibility of the following exhibits
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`filed by Petitioners.
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`In this paper, a reference to “FRE” means the Federal Rules of Evidence and
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`“’134 patent” means U.S. Patent No. 8,983,134.
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`IPT’s objections are as follows:
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`Exhibit 1002 ¶¶ 23–30 (Hart Declaration)
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`Patent Owner objects to these paragraphs of Exhibit 1002 under FRE 402
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`(relevance) and FRE 403 (confusing, waste of time).
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`Exhibit 1002 ¶¶ 109–135 & Table at Pages 93–109 (Hart Declaration)
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`Patent Owner objects to these paragraphs of Exhibit 1002 under FRE 802
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`(hearsay). Patent Owner also objects to these paragraphs of Exhibit 1002 under
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`FRE 402 (relevance) and FRE 403 (confusing, waste of time) at least because the
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`paragraphs are not relevant to any issue in this IPR because the grounds for which
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`they were submitted have not been instituted.
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`Exhibit 1005 (Gilbert)
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`Patent Owner objects to Exhibit 1005 under FRE 802 (hearsay). Patent
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`Owner also objects to Exhibit 1005 under FRE 402 (relevance) and FRE 403
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`(unfairly prejudicial, confusing, waste of time) at least because the document is not
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`Paper 14
`June 9, 2017
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`relevant to any issue in this IPR proceeding because the disclosure is not prior art
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`and/or Petitioner has not met its burden to show the exhibit to be prior art.
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`Exhibit 1008 (Trier)
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`Patent Owner objects to Exhibit 1008 under FRE 901 because authenticating
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`information has not been provided. Patent Owner also objects to Exhibit 1008
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`under FRE 402 (relevance) and FRE 403 (unfairly prejudicial, confusing, waste of
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`time) at least because the document is not discussed in the Declaration of Dr. Hart
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`(Exhibit 1002) nor cited to or discussed in the Petition.
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`Exhibit 1009 (Glauberman)
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`Patent Owner objects to Exhibit 1009 under FRE 901 because authenticating
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`information has not been provided. Patent Owner also objects to Exhibit 1009
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`under FRE 402 (relevance) and FRE 403 (unfairly prejudicial, confusing, waste of
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`time) at least because the document is not discussed in the Declaration of Dr. Hart
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`(Exhibit 1002) nor cited to or discussed in the Petition.
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`Exhibit 1010 (Grenier Declaration)
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`Patent Owner objects to Exhibit 1010 under FRE 802 (hearsay).
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`Paper 14
`June 9, 2017
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`/s/Chris J. Coulson/
`Chris J. Coulson (Reg. No. 61,771)
`Lead Counsel for Patent Owner
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`Fax: (212) 425-5288
`chriscoulson@andrewskurthkenyon.com
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`Michael Zachary (pro hac vice)
`michaelzachary@andrewskurthkenyon.com
`Mark Chapman (pro hac vice)
`MarkChapman@andrewskurthkenyon.com
`Rose Prey (pro hac vice)
`RosePrey@andrewskurthkenyon.com
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`Dated: June 9, 2017
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`Paper 14
`June 9, 2017
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on June 9,
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`2017, the foregoing Patent Owner’s Objections to Petitioner’s Evidence was
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`served via electronic mail upon the following counsel of record for the Petitioner:
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`John Kappos (Reg. No. 37,861)
`O’Melveny & Myers LLP
`610 Newport Center Drive, 17th Floor
`Newport Beach, CA 92660
`jkappos@omm.com
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`Nicholas J. Whilt (Reg. No. 72,081)
`O’Melveny & Myers LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
`nwhilt@omm.com
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`Brian M. Cook (Reg. No. 59,356)
`O’Melveny & Myers LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
`bcook@omm.com
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`IPTSAMSUNGOMM@OMM.COM
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`/s/Chris J. Coulson
`Chris J. Coulson
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`Fax: (212) 425-5288
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