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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 AMERICA, INC.
`Petitioner
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`v.
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`UNILOC LUXEMBOURG, S.A.1
`Patent Owner
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`Case: IPR2017-01801
`U.S. Patent No. 8,995,433
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`JOINT FILING OF
`OBJECTIONS TO DEMONSTRATIVES
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`1 Uniloc’s updated mandatory notice filed on August 27, 2018, indicates that the
`owner of U.S. Patent No. 8,995,433 is now Uniloc 2017 LLC. (Paper 18.)
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`Samsung’s Objections to Demonstratives
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`Case: IPR2017-01801
`U.S. Patent No. 8,995,433
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`The following slides belatedly attempt to introduce new arguments and
`evidence: 5 (“‘message content 406’ is not an ‘object field,’” “three distinct
`elements,” “only description of message content 406,” graphics), 7 (graphics), 10
`(Ex. 2001 at ¶¶ 40-46, 48 are not relied upon), 11 (Ex. 2007 not an exhibit or relied
`upon in IPR2017-01797), 12 (“relies solely on Griffin”), 16 (“relies exclusively on
`Low’s description” of connect/disconnect), 17 (“At most…”), 22 (referenced
`proceedings not discussed), 23 (IPR2017-02085 not discussed), 25 (same), 26
`(same), 27 (discussion of 26 IPRs), 32 (Ex. 2001 at ¶ 53 not relied upon for
`“device-specific information” argument), 34 (“This is true regardless…”; “The
`Board further noted…”), 40 (IPR2017-02085 not discussed), 54 (argument
`regarding “queuing”), 55 (Ex. 2001 at ¶ 34 not relied on for this limitation), 57
`(“Petitioner’s reliance…”), 58 (arguments and citations related to Ex. 2004).
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`Petitioner requests a pre-hearing call or additional time at the hearing to
`address these issues.
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`Uniloc’s Objections to Demonstratives
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`1. Slides 12‒24 rely on new claim construction argument presented for the first
`time in Petitioner’s Reply that is outside the proper scope of the Reply. See,
`e.g., IPR2017-01799 at 6 n.4.
`2. Slides 31‒33 rely on new argument concerning the “attaching” limitations,
`presented for the first time in Petitioner’s Reply, that is outside the proper scope
`of the Reply.
`3. Slides 36‒39 rely on new argument concerning the “controlling” limitations,
`presented for the first time in Petitioner’s Reply, that is outside the proper scope
`of the Reply.
`4. Slides 18, 24, 31‒32, 40, 63, 74, 80, 88, 97, and 101 purport to rely on selected
`excerpts from cross-examination testimony that is outside the scope of Doctor
`Easttom’s declaration and that violate the rule of completeness.
`5. Petitioner’s slides fail to properly refer to Patent Owner’s expert by his proper
`title “Doctor Easttom.”
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`Patent Owner submits that it is unnecessary to have a pre-hearing call or
`additional time at the hearing to address these issues.
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`2
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`Case: IPR2017-01801
`U.S. Patent No. 8,995,433
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`Respectfully submitted,
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`By: /Naveen Modi/
` Naveen Modi (Reg. No. 46,224)
` Counsel for Petitioner
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`Dated: October 23, 2018
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`3
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), I certify that I caused to be served on the
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`Case: IPR2017-01801
`U.S. Patent No. 8,995,433
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`counsel for Patent Owner a true and correct copy of the foregoing Joint Filing of
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`Objections To Demonstratives by electronic means on October 23, 2018 at the
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`following address of record:
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`Brett Mangrum (brett@etheridgelaw.com)
`Sean D. Burdick (sean.burdick@unilocusa.com)
`Ryan Loveless (ryan@etheridgelaw.com)
`James Etheridge (jim@etheridgelaw.com)
`Jeffrey Huang (jeff@etheridgelaw.com)
`Etheridge Law Group
`2600 E. Southlake Blvd., Ste. 120-324
`Southlake, TX 76092
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`Dated: October 23, 2018
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`Respectfully submitted,
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`By: /Naveen Modi/
` Naveen Modi (Reg. No. 46,224)
` Counsel for Petitioner
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