`Patent 9,712,494
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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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`APPLE INC.,
`Petitioner,
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`v.
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`MPH TECHNOLOGIES OY,
`Patent Owner,
`____________
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`Case IPR2019-00823
`Patent 9,712,494
`____________
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`PATENT OWNER’S OBJECTIONS PURSUANT TO 37 C.F.R. § 42.64(b)(1)
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`Pursuant to 37 C.F.R. § 42.64(b)(1) and the Federal Rules of Evidence
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`(“FRE”), Patent Owner MPH Technologies Oy (“Patent Owner”) hereby objects to
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`the evidence presented in the following document submitted by Petitioner Apple
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`Inc. (“Petitioner”).
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`Nothing in this paper should be construed as an admission that any rights of
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`Patent Owner would have been waived or forfeited had the paper or any objection
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`herein not been filed, or that 37 C.F.R. § 42.64(b) applies to any of the objections
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`herein if § 42.64(b) would not otherwise apply. The objections herein are
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`premised upon § 42.64 potentially being determined to apply to the document in
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`question and are submitted solely to preserve the rights of Patent Owner should
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`§ 42.64(b) be determined to apply.
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`In accordance with 37 C.F.R. § 42.64, Patent Owner hereby objects to the
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`following evidence referenced in Petitioner’s Reply, Paper 17, filed on June 1,
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`2020:
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`1. Exhibit 1025 Merriam-Webster’s Collegiate Dictionary: Patent Holder
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`objects to this document as not being identified as part of the prior art relied upon
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`in the grounds submitted in the Petition. Patent Holder objects to this exhibit as
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`being irrelevant pursuant to FRC 401. Patent Holder objects to this exhibit as being
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`inadmissible under FRE 403 because, inter alia, its probative value is outweighed
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`by the danger of unfair prejudice and confusion of the issues.
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`- 1 -
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`2. Exhibit 1022 (Goldschlag Reply Declaration): Patent Holder objects to the
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`testimony in this exhibit to the extent it relies upon or cites Ex. 1025.
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`- 2 -
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`Respectfully submitted,
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` /
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` James T. Carmichael /_________
`James T. Carmichael, Reg. No. 45,306
`CARMICHAEL IP, PLLC
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`Date: June 8, 2020
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`- 3 -
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`Case IPR2019-00823
`Patent 9,712,494
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the following documents were served
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`by electronic service, by agreement between the parties, on the date signed below:
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`PATENT OWNER’S OBJECTIONS PURSUANT TO 37 C.F.R. § 42.64(b)(1)
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`The names and address of the parties being served are as follows:
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`Michael D. Specht
`Daniel S. Block
`Steven M. Pappas
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`mspecht-PTAB@sternekessler.com
`dblock-PTAB@sternekessler.com
`spappas-PTAB@sternekessler.com
`PTAB@sternekessler.com
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`Respectfully submitted,
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` / James Carmichael /
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`Date: June 8, 2020
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