`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`INTEL CORP., CAVIUM, INC., and
`WISTRON CORPORATION,
`Petitioner,
`
`v.
`
`ALACRITECH, INC.,
`Patent Owner.
`______________________
`
`Case IPR2017-013921
`U.S. Patent No. 7,337,241
`Title: FAST-PATH APPARATUS FOR RECEIVING DATA CORRESPONDING
`TO A TCP CONNECTION
`______________________
`
`PETITIONER’S OBJECTIONS TO DOCUMENTS SERVED
`WITH PATENT OWNER’S REPLY IN SUPPORT OF
`CONTINGENT MOTION TO AMEND
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`1 Cavium, Inc., which filed a Petition in Case IPR2017-01728, has been joined as a
`
`petitioner in this proceeding. Wistron Corporation, who filed a Petition in
`
`Case IPR2018-00328, has been joined as a petitioner in this proceeding.
`
`
`
`Case IPR2017-01392
`U.S. Patent No. 7,337,241
`
`Pursuant to 37 C.F.R. § 42.64(b), Petitioner Intel Corporation, hereby makes
`
`the following objections to the admissibility of documents submitted with Patent
`
`Owner’s Reply In support of Contingent Motion to Amend.
`
`Evidence
`
`Exhibit 2305
`
`Objections
`
`Petitioner objects to this exhibit because it raises new issues
`and belatedly presents evidence on which Patent Owner has
`the burden of proof, e.g., in Paragraphs 19-28.
`
`FRE 701/702/703: Petitioner objects to Ex. 2305 as being
`improper expert testimony because paragraphs 22, 23, 25-
`28, 33, 34, 35, 39, 40 are not based on sufficient facts or
`data, are irrelevant, are not based on a reliable foundation,
`and constitute conclusory opinions without sufficient
`support. It includes opinions that are not admissible under
`FRE 701, 702, or 703 or Daubert v. Merrell Dow Pharms.,
`Inc., 509 U.S. 579 (1993).
`
`
`
`
`
`
`
`
`1
`
`
`
`Dated: May 25, 2018
`
`Case IPR2017-01392
`U.S. Patent No. 7,337,241
`
`
`
`Respectfully submitted,
`
`/s/ Garland T. Stephens
`Garland T. Stephens, Reg. No. 37,242
`Justin L. Constant, Reg. No. 66,883
`Weil, Gotshal & Manges LLP
`700 Louisiana, Suite 1700
`Houston, TX 77002
`Tel: (713) 546-5000
`Fax: (713) 224-9511
`garland.stephens@weil.com
`justin.constant@weil.com
`Anne M. Cappella, Reg. No. 43,217
`Adrian Percer, Reg. No. 46,986
`Weil, Gotshal & Manges LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`Tel: (650) 802-3141
`Fax: (650) 802-3100
`anne.cappella@weil.com
`adrian.percer@weil.com
`William S. Ansley, Reg. No. 67,828
`Weil, Gotshal & Manges LLP
`2001 M Street, N.W, Suite 600
`Washington, DC 20036
`Tel: (202) 682-7000
`Fax: (202) 857-0940
`sutton.ansley@weil.com
`
`
`
`Attorneys for Petitioner Intel Corporation
`
`2
`
`
`
`Case IPR2017-01392
`U.S. Patent No. 7,337,241
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on May 25, 2018, a copy of PETITIONER’S
`
`OBJECTIONS TO DOCUMENTS SERVED WITH PATENT OWNER’S
`
`REPLY IN SUPPORT OF CONTINGENT MOTION TO AMEND was served
`
`by filing this document through the PTAB’s E2E Filing System as well as
`
`delivering a copy via electronic mail upon the following:
`
`James M. Glass
`Registration No. 46,729
`Quinn Emanuel Urquhart & Sullivan LLP
`51 Madison Ave., 22nd Fl.
`New York, NY 10010
`Tel.: (212) 849-7000
`Email: jimglass@quinnemanuel.com
`Joseph M. Paunovich
`Registration No. 59,033
`Quinn Emanuel Urquhart & Sullivan LLP
`865 S. Figueroa Street, 10th Fl.
`Los Angeles, CA 90017
`Tel.: (213) 443-3000
`Email: joepaunovich@quinnemanuel.com
`Brian E. Mack
`Registration No. 57,189
`Quinn Emanuel Urquhart & Sullivan LLP
`50 California Street, 22nd Fl.
`San Francisco, CA 94111
`Tel.: (415) 875-6600
`Email: brianmack@quinnemanuel.com
`
`
`
`
`3
`
`
`
`Case IPR2017-01392
`U.S. Patent No. 7,337,241
`
`Mark Lauer
`Registration No. 36,578
`Silicon Edge Law Group LLP
`7901 Stoneridge Dr., Ste. 528
`Pleasanton, CA 94588
`Tel.: (925) 621-2121
`Email: mark@siliconedgelaw.com
`
`Dated: May 25, 2018
`
`
`
`/s/ Garland T. Stephens
`Garland T. Stephens
`Reg. No. 37,242
`
`
`
`4
`
`
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