`Patent 8,577,813
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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
`
`v.
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`UNIVERSAL SECURE REGISTRY LLC
`Patent Owner
`____________
`
`IPR2018-00067
`Patent 8,577,813
` ____________
`
`PETITIONER UNIFIED PATENTS INC.’S OBJECTIONS
`TO EVIDENCE PURSUANT TO 37 C.F.R. § 42.64(b)(1)
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner Unified Patents Inc.
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`IPR2018-00067
`Patent 8,577,813
`
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`(“Petitioner”) submits the following objections to evidence that Universal Secure
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`Registry LLC (“Patent Owner”) served in its Patent Owner Response. These
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`objections are timely filed and served within five business days of Patent Owner’s
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`August 30, 2018 Patent Owner Response.
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`Evidence
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`Exhibit 2007
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`Exhibit 2008
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`Objections
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`FRE 901: Petitioner objects to this exhibit as being
`an unauthenticated document that is not self-
`authenticating under FRE 902.
`
`FRE 801 & 802: Petitioner objects to this exhibit as
`constituting hearsay under FRE 801 that is
`inadmissible under FRE 802.
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`FRE 401, 402, & 403: Petitioner objects to this
`exhibit as irrelevant and because its probative value
`is substantially outweighed by a danger of unfair
`prejudice, confusing the issues, and wasting time,
`given that Patent Owner has not provided any
`foundation for what this exhibit is, how it was
`maintained, whether it is accurate, whether any date
`printed thereon is accurate, and whether it was ever
`actually published or publicly available.
`
`FRE 901: Petitioner objects to this exhibit as being
`an unauthenticated document that is not self-
`authenticating under FRE 902.
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`FRE 801 & 802: Petitioner objects to this exhibit as
`constituting hearsay under FRE 801 that is
`inadmissible under FRE 802.
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`Exhibit 2009
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`
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`Dated: September 7, 2018
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`IPR2018-00067
`Patent 8,577,813
`
`
`FRE 401, 402, & 403: Petitioner objects to this
`exhibit as irrelevant and because its probative value
`is substantially outweighed by a danger of unfair
`prejudice, confusing the issues, and wasting time,
`given that Patent Owner has not provided any
`foundation for what this exhibit is, how it was
`maintained, whether it is accurate, whether any date
`printed thereon is accurate, and whether it was ever
`actually published or publicly available.
`
`FRE 901: Petitioner objects to this exhibit as being
`an unauthenticated document that is not self-
`authenticating under FRE 902.
`
`FRE 801 & 802: Petitioner objects to this exhibit as
`constituting hearsay under FRE 801 that is
`inadmissible under FRE 802.
`
`FRE 401, 402, & 403: Petitioner objects to this
`exhibit as irrelevant and because its probative value
`is substantially outweighed by a danger of unfair
`prejudice, confusing the issues, and wasting time,
`given that Patent Owner has not provided any
`foundation for what this exhibit is, how it was
`maintained, whether it is accurate, whether any date
`printed thereon is accurate, and whether it was ever
`actually published or publicly available.
`
`
`
`
`
`BY: /s/ Jason R. Mudd
`Jason R. Mudd, Reg. No. 57,700
`Roshan Mansinghani, Reg. No. 62,429
`Eric A. Buresh, Reg. No. 50,394
`Jonathan Stroud, Reg. No. 72,518
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`ATTORNEYS FOR PETITIONER
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`CERTIFICATE OF SERVICE
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`IPR2018-00067
`Patent 8,577,813
`
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that this
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`PETITIONER UNIFIED PATENTS INC.’S OBJECTIONS TO EVIDENCE
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`PURSUANT TO 37 C.F.R. § 42.64(b)(1) was served on September 7, 2018 on
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`counsel for Patent Owner by e-mailing to counsel of record for Patent Owner,
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`including:
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`• jimglass@quinnemanuel.com
`• nimahefazi@quinnemanuel.com
`• tigranguledjian@quinnemanuel.com
`• qe-usr-ipr@quinnemanuel.com
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`Dated: September 7, 2018
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`By: /s/ Jason R. Mudd__________________
` Attorney for Petitioner
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