`
`
`
`
`
`
`
`
`
`
`
`Paper No. __
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING CO., LTD,
`Petitioner,
`
`v.
`
`GODO KAISHA IP BRIDGE 1,
`Patent Owner.
`____________
`
`IPR2017-018431
`Patent 7,893,501
`____________
`
`PATENT OWNER’S OBJECTIONS TO EVIDENCE SERVED WITH
`PETITIONER’S REPLY
`
`
`
`
`
`
`1 Case IPR2017-01844 has been consolidated with this proceeding.
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner submits the following
`
`objections to evidence served in connection with the Petitioner’s Reply to Patent
`
`Owner’s Response. These objections have been timely filed and served within five
`
`business days of the service of evidence to which the objection is directed.
`
`Exhibit 1232 is the Reply Declaration of Stanley R. Shanfield, Ph.D.
`
`Several portions of Exhibit 1232 contain new evidence and/or support for a new
`
`theory that is not properly included in a reply. Patent Owner objects to the
`
`following portions because they are an improper reply and are therefore irrelevant
`
`and/or substantially more prejudicial than probative pursuant to F.R.E. 401, 402,
`
`and 403.
`
`• ¶¶5-6 and Section I improperly raise a new argument that spacers 23 in
`
`Misra are not made of silicon nitride that is only cited in Petitioner’s Reply
`
`to support new arguments. See Paper No. 22 at pp. 2-6..
`
`Dated: July 13, 2018
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`Godo Kaisha IP Bridge 1
`
`By /Gerald B. Hrycyszyn/
`Gerald B. Hrycyszyn, Reg. No. 50,474
`Richard F. Giunta, Reg. No. 36,149
`Edmund J. Walsh, Reg. No. 32,950
`Joshua J. Miller (admitted pro hac vice)
`WOLF GREENFIELD & SACKS, P.C.
`600 Atlantic Ave.
`Boston, MA 02210-2206
`Tel: 617-646-8000/Fax: 617-646-8646
`
`
`
`
`CERTIFICATE OF SERVICE UNDER 37 C.F.R. §42.6 (e)(4)
`
`I certify that on July 13, 2018 I will cause a copy of the foregoing document
`
`
`
`
`to be served via electronic mail, as previously consented to by Petitioner, upon the
`
`following:
`
`
`
`David L. Cavanaugh
`
`David.Cavanaugh@wilmerhale.com
`
`Dominic.Massa@wilmerhale.com
`
`MichaelH.Smith@wilmerhale.com
`
`
`
`
`
`Dominic E. Massa
`
`Michael H. Smith
`
`
`
`
`
`
`
`
`Date: July 13, 2018
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/MacAulay Rush/
`MacAulay Rush
`Patent Paralegal
`WOLF GREENFIELD & SACKS, P.C.
`
`
`
`
`
`3
`
`