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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`GOOGLE LLC, ZTE (USA), INC., SAMSUNG ELECTRONICS CO., LTD.,
`LG ELECTRONICS INC., HUAWEI DEVICE USA, INC.,
`HUAWEI DEVICE CO. LTD., HUAWEI TECHNOLOGIES CO. LTD.,
`HUAWEI DEVICE (DONGGUAN) CO. LTD.,
`HUAWEI INVESTMENT & HOLDING CO. LTD.,
`HUAWEI TECH. INVESTMENT CO. LTD., and
`HUAWEI DEVICE (HONG KONG) CO. LTD.,
`
`Petitioner
`
`v.
`
`Cywee Group Ltd.
`
`(record) Patent Owner
`
`IPR2018-01257
`
`Patent No. 8,552,978
`
`
`
`PETITIONER GOOGLE’S OBJECTIONS TO EXHIBITS AND PAPERS
`FILED ON OR AROUND JULY 31, 2019.
`
`
`
`
`
`
`1
`
`
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`Petitioner Google LLC respectfully submits objections under 37 C.F.R.
`
`§ 42.64(b)(1) to CyWee’s filings made on or around July 31, 2019:
`
`Paper / Exhibit
`
`CyWee Sur-Reply to
`Petition
`
`Ex. 2020
`Ex. 2032
`
`Objections
`
`CyWee’s Sur-Reply contains arguments that are
`
`not within the proper scope of reply arguments.
`
`Google additionally objects to discussion of the
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`Bachmann Dissertation under 37 C.F.R. §42.6(c).
`
`Google objects to these exhibits to the extent the
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`witnesses do not appear for cross-examination
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`under reasonable circumstances, or to the extent
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`that CyWee impedes such cross-examination.
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`Ex. 2020
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`Google objects to this exhibit because the purported
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`witness may lack personal knowledge of the
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`contents of the exhibit under FRE 602 and 901. It
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`is unclear whether the purported fact witness
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`drafted, read, signed or understood the English-
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`language exhibit. Google further objects under
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`FRE 802 and 37 C.F.R. 42.53(a) because the
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`exhibit is an alleged out-of-court statement of an
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`
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`2
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`
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`individual that does not meet any hearsay exception
`
`and is not in the form of an affidavit.
`
`
`
`
`Date: Wednesday, August 7, 2019
`
`
`
`
`
`/Matthew A. Smith/ (RN 49,003)
`Matthew A. Smith
`SMITH BALUCH LLP
`1100 Alma St., Ste 109
`Menlo Park, CA
`(202) 669-6207
`smith@smithbaluch.com
`
`Counsel for Petitioner Google LLC
`
`
`
`
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`3
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`
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that the Petitioner Google LLC’s Objections
`
`were served by electronic mail on Wednesday, August 7, 2019, on all counsel of
`
`record at the USPTO having the following addresses:
`
`Counsel for CyWee:
`Jay Kesan
`
`jay@jaykesan.com;
`Cecil Key
`
`cecil@keyiplaw.com
`Ari Rafilson
`arafilson@shorechan.com;
`Michael Shore
`mshore@ShoreChan.com
`
`Counsel for ZTE:
`James R. Sobieraj jsobierah@brinksgilson.com
`Yeuzhong Feng
`yfeng@brinksgilson.com
`Andrea Shoffstall ashoffstall@brinksgilson.com
`ZTE_CyweeIPRs@brinksgilson.com
`
`
`Counsel for Samsung:
`Naveen Modi
`Chetan Bansal
`
`PH-Samsung-Cywee-IPR@paulhastings.com
`
`
`Counsel for LG:
`Collin Park
`Andrew Devkar
`Jeremy Peterson
`Adam Brooke
`
`collin.park@morganlewis.com
`andrew.devkar@morganlewis.com
`jeremy.peterson@morganlewis.com
`adam.brooke@morganlewis.com
`MLB_CyweevsLGE@morganlewis.com
`
`Counsel for Huawei:
`Kristopher L. Reed
`Benjamin M. Kleinman
`Norris P. Boothe
`
`HuaweiCywee@kilpatricktownsend.com
`
`
` Date: Wednesday, August 7, 2019
`
`
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`4
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`/Matthew A. Smith/ (RN 49,003)
`
`
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