`Patent 9,454,748
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`UNIFIED PATENTS INC.
`Petitioner
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`v.
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`FALL LINE PATENTS, LLC
`Patent Owner
`__________________
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`Case IPR2018-00043
`Patent 9,454,748
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`PATENT OWNER’S OBJECTIONS TO PETITIONER’S RPI EVIDENCE
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`Fall Line Patents, LLC (“Patent Owner”) objects under the Federal Rules of
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`IPR2018-0043
`Patent 9,454,748
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`Evidence (“F.R.E.”) and 37 C.F.R. § 42.64 to the admissibility of the following
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`exhibits on the grounds set forth below. All evidence objected to below was served
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`by Petitioner Unified Patents Inc. (“Petitioner”) on February 1, 2019. Pursuant to
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`the Board’s Order (Paper 19), Patent Owner’s objections to evidence are timely.
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`Patent Owner objects as follows:
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`Exhibit 1026
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`Patent Owner objects to Exhibit 1026 as failing to include the best evidence
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`under F.R.E. 1002 because nearly all statements contained therein relate to
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`contracts between Petitioner and its members or communications between
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`Petitioner and its members, and to paragraph 4 of Exhibit 1026 as inadmissible
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`hearsay under F.R.E. 802.
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`Exhibit 1027
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`Patent Owner objects to Exhibit 1027 as unfairly prejudicial, confusing,
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`misleading, and unduly delayed under F.R.E. 403, as inadmissible hearsay under
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`F.R.E. 802, as irrelevant under F.R.E. 402, because the Federal Rules of Civil
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`Procedure and Federal Rules of Evidence do not recognize “voluntary
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`interrogatory responses” in which the party answering the interrogatories chooses
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`which interrogatories to propound, and because the answers are not made on
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`personal knowledge.
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`Dated: February 4, 2019
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`IPR2018-0043
`Patent 9,454,748
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`Respectfully submitted,
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`__/Michael D. Ellis/__
`Michael D. Ellis
`Reg. No. 72,628
`Counsel for Patent Owner
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on February 4,
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`IPR2018-0043
`Patent 9,454,748
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`2019, the foregoing document was served via email on counsel for Petitioner:
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`HAYNES AND BOONE, LLP
`David O’Brien (David.obrien.ipr@haynesboone.com)
`Raghav Bajaj (Raghav.bajaj.ipr@haynesboone.com)
`David McCombs (David.mccombs.ipr@haynesboone.com)
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`UNIFIED PATENTS INC.
`Jonathan Stroud (jonathan@unifiedpatents.com)
`Roshan Mansinghani (roshan@unifiedpatents.com)
`Jonathan Bowser (jbowser@unifiedpatents.com)
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`__/Michael D. Ellis/___
`Michael D. Ellis
`Counsel for Patent Owner
`Reg. No. 72,628
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