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`Paper No. ___
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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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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`Petitioner,
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`v.
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`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`_____________
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`Case Nos. IPR2017-018411
`Patent No. 7,893,501
`_____________
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`PATENT OWNER’S OBJECTIONS TO EVIDENCE
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`1 Case IPR2017-01842 has been consolidated with this proceeding.
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`6090268.1
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner submits the following
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`objections to evidence served in connection with the Petition for Inter Partes
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`Review filed on July 26, 2017. These objections are timely filed and served within
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`ten business days of the institution of the trial in this matter.
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`I.
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`EXHIBITS FROM IPR2017-01841
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`Patent Owner objects to each of Exhibits 1008, 1010, 1011, 1014, and 1015
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`for the following reasons:
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` Petitioner objects under Fed. R. Evid. 901 as Petitioner has failed to
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`authenticate the exhibits; more specifically, Petitioner has failed to
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`establish that the exhibits are what Petitioner says they are, and has
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`failed to establish the date by which the exhibits were published;
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` To the extent Petitioner attempts to rely on the copyright date or other
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`date identified in any of the exhibits to establish the publication date,
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`the copyright date or other date is hearsay under Fed. R. Evid. 801 and
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`the exhibit is inadmissible under Fed. R. Evid. 802;
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` Due to the above deficiencies, Petitioner has failed to establish that
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`the exhibits are relevant under Fed. R. Evid. 401, and therefore the
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`exhibits are inadmissible under Fed. R. Evid. 402.
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`Patent Owner likewise objects to any portion of the Petition and the
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`Shanfield Declaration (Exhibit 1002) purporting to rely on these exhibits.
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`1
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`II. EXHIBITS FROM IPR2017-01842
`Patent Owner objects to each of Exhibits 1106, 1110, 1111, 1115, 1116,
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`1117, 1119, 1120, 1121, 1126, 1127, and 1128 for the following reasons:
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` Petitioner objects under Fed. R. Evid. 901 as Petitioner has failed to
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`authenticate the exhibits; more specifically, Petitioner has failed to
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`establish that the exhibits are what Petitioner says they are, and has
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`failed to establish the date by which the exhibits were published;
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` To the extent Petitioner attempts to rely on the copyright date or other
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`date identified in any of the exhibits to establish the publication date,
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`the copyright date or other date is hearsay under Fed. R. Evid. 801 and
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`the exhibit is inadmissible under Fed. R. Evid. 802;
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` Due to the above deficiencies, Petitioner has failed to establish that
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`the exhibits are relevant under Fed. R. Evid. 401, and therefore the
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`exhibits are inadmissible under Fed. R. Evid. 402.
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`Patent Owner likewise objects to any portion of the Petition and the
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`Shanfield Declaration (Exhibit 1102) purporting to rely on these exhibits.
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`Dated: 2/20/2018
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`Respectfully submitted,
`Godo Kaisha IP Bridge 1
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`By /s Gerald B. Hrycyszyn /
`Gerald B. Hrycyszyn, Registration No. 50,474
`Richard F. Giunta, Registration No. 36,149
`Edmund J. Walsh, Registration No. 32,950
`WOLF GREENFIELD & SACKS, P.C.
`600 Atlantic Ave.
`Boston, MA 02210-2206
`Tel: 617-646-8000/Fax: 617-646-8646
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`3
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
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`I certify that on February 20, 2018, I will cause a copy of the foregoing
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`document, including any exhibits or appendices referred to therein, to be served via
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`electronic mail, as previously consented to by Petitioner, upon the following:
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`David L. Cavanaugh
`Dominic E. Massa
`Michael H. Smith
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`David.Cavanaugh@wilmerhale.com
`Dominic.Massa@wilmerhale.com
`MichaelH.Smith@wilmerhale.com
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`Date: February 20, 2018
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`/s Lisa Woodbury/
`Lisa Woodbury
`Litigation Paralegal
`WOLF GREENFIELD & SACKS, P.C.
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`4
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