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`Paper No. ___
`Filed: February 26, 2019
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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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`VISA INC. and VISA U.S.A. INC.,
`Petitioners,
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`v.
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`UNIVERSAL SECURE REGISTRY LLC,
`Patent Owner.
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`Case IPR2018-01350
`Patent No. 8,856,539
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`PETITIONER’S NOTICE OF OBJECTION TO EVIDENCE
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`Case IPR2018-01350
`Patent 8,856,539
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`I.
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`INTRODUCTION
`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioners Visa Inc. and Visa U.S.A.
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`Inc., (together, “Visa”), submit the following objections to Patent Owner Universal
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`Secure Registry LLC’s (“PO”) Exhibit 2001 and 2002. As required by 37 C.F.R.
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`§ 42.62, Visa’s objections below apply the Federal Rules of Evidence (“F.R.E.”).
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`II. OBJECTIONS
`A. Objections to Ex. 2001 and any Reference to/Reliance Thereon
`Evidence objected to: Ex. 2001.
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`Grounds for Objection: F.R.E. 401 (Test for Relevant Evidence); F.R.E. 402
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`(General Admissibility of Relevant Evidence); F.R.E. 403 (Excluding Relevant
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`Evidence for Prejudice, Confusion, Waste of Time, or Other Reasons).
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`Exhibit 2001 has not been relied upon by PO in rebutting or addressing any
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`instituted ground of challenge. Accordingly, this exhibit is not relevant to the
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`proceeding. Further, to the extent this exhibit is deemed relevant admission of the
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`exhibit would be unduly prejudicial, misleading, and a waste of time in view of the
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`fact that it has not been relied upon by PO in rebutting or addressing any instituted
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`ground of challenge.
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`B. Objections to Ex. 2002 and any Reference to/Reliance Thereon
`Evidence objected to: Ex. 2002.
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`Grounds for Objection: F.R.E. 401 (Test for Relevant Evidence); F.R.E. 402
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`-1-
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`Case IPR2018-01350
`Patent 8,856,539
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`(General Admissibility of Relevant Evidence); F.R.E. 403 (Excluding Relevant
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`Evidence for Prejudice, Confusion, Waste of Time, or Other Reasons).
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`Exhibit 2002 has not been relied upon by PO in rebutting or addressing any
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`instituted ground of challenge. Accordingly, this exhibit is not relevant to the
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`proceeding. Further, to the extent this exhibit is deemed relevant admission of the
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`exhibit would be unduly prejudicial, misleading, and a waste of time in view of the
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`fact that it has not been relied upon by PO in rebutting or addressing any instituted
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`ground of challenge.
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`III. CONCLUSION
`Exhibits 2001 and 2002 were served on November 13, 2018 and trial was
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`instituted in this proceeding on February 11, 2019. These objections are made
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`within ten business days of institution.
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`Date: February 26, 2019
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`Respectfully submitted,
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`/ Matthew A. Argenti /
`Matthew A. Argenti, Lead Counsel
`Reg. No. 61,836
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`Case IPR2018-01350
`Patent 8,856,539
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`CERTIFICATE OF SERVICE
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`I certify that the foregoing Petitioner’s Notice of Objection to Evidence was
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`served on this 26th day of February, 2019, on the Patent Owner at the electronic
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`correspondence address of the Patent Owner as follows:
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`James M. Glass
`Tigran Guledjian
`Christopher A. Matthews
`Nima Hefazi
`Richard Lowry
`Razmig Messerian
`QUINN EMANUEL URQUHART & SULLIVAN LLP
`jimglass@quinnemanuel.com
`tigranguledjian@quinnemanuel.com
`qe-usr-ipr@quinnemanueal.com
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`Respectfully submitted,
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`Date: February 26, 2019
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`/ Matthew A. Argenti /
`Matthew A. Argenti, Lead Counsel
`Reg. No. 61,836
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`-3-
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