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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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`ADVANCED MICRO DEVICES, INC.
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`Petitioner
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`v.
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`AQUILA INNOVATIONS INC.
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`Patent Owner
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`Case IPR2019-01525
`Patent 6,239,614 B2
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`PATENT OWNER’S EVIDENTIARY OBJECTIONS
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`Pursuant to 37 C.F.R § 42.64(b)(1), Patent Owner Aquila Innovations Inc.
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`(“Aquila”) objects to the admissibility of evidence served by Petitioner Advanced
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`Micro Devices, Inc. (“AMD”) in connection with its petition filed on August 28,
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`2019.
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`Aquila objects, under FRE 402/403, to all references that do not form the
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`basis of the instituted review.
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`Aquila additionally objects to Exhibit 1003 (Declaration of Douglas
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`Holberg) to the extent it provides opinions that are irrelevant under FRE 402, or
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`that their probative value is substantially outweighed by other consideration under
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`FRE 403, including unfair prejudice, confusion of the issue and waste of time.
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`Patent Owner further objects that Exhibit 1003 is hearsay not subject to any
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`exceptions under FRE 802. Aquila objects to paragraphs 34 – 55 of Exhibit 1003
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`under FRE 402 and 403 to the extent they provide opinions related to purported
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`references that do not form the basis for any instituted ground.
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`Aquila objects to Exhibit 1006 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1008 under FRE 802 because it is inadmissible
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`hearsay not subject to any exceptions.
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`Aquila objects to Exhibit 1009 under FRE 802 because it is inadmissible
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`hearsay not subject to any exceptions.
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`-2-
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`Aquila objects to Exhibit 1013 under FRE 802 because it is inadmissible
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`hearsay not subject to any exceptions.
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`Aquila objects to Exhibit 1014 under FRE 802 because it is inadmissible
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`hearsay not subject to any exceptions.
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`Aquila objects to Exhibit 1015 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground. Aquila
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`objects to Exhibit 1015 under FRE 802 because it is inadmissible hearsay not
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`subject to any exceptions.
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`Aquila objects to Exhibit 1016 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground. Aquila
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`objects to Exhibit 1016 under FRE 802 because it is inadmissible hearsay not
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`subject to any exceptions.
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`Aquila objects to Exhibit 1017 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground. Aquila
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`objects to Exhibit 1017 under FRE 802 because it is inadmissible hearsay not
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`subject to any exceptions.
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`Aquila objects to Exhibit 1018 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground. Aquila
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`objects to Exhibit 1018 under FRE 802 because it is inadmissible hearsay not
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`subject to any exceptions.
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`-3-
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`Aquila objects to Exhibit 1020 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1021 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1022 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1023under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1024 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1025 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground. Aquila
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`objects to Exhibit 1025 under FRE 802 because it is inadmissible hearsay not
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`subject to any exceptions.
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`Aquila objects to Exhibit 1026 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground. Aquila
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`objects to Exhibit 1026 under FRE 802 because it is inadmissible hearsay not
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`subject to any exceptions.
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`Aquila objects to Exhibit 1027 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground. Aquila
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`-4-
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`objects to Exhibit 1027 under FRE 802 because it is inadmissible hearsay not
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`subject to any exceptions.
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`Aquila objects to Exhibit 1028 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1032 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1033 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1034 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground. Aquila
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`objects to Exhibit 1034 under FRE 802 because it is inadmissible hearsay not
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`subject to any exceptions.
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`Aquila objects to Exhibit 1038 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1039 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1040 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1041 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`-5-
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`Aquila objects to Exhibit 1042 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1043 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1044 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1045 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Aquila objects to Exhibit 1046 under FRE 402 and 403 because it is a
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`purported reference that does not form the basis of any instituted ground.
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`Date: March 20, 2020
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`/s/Jing H. Cherng
`Jing H. Cherng
`Reg. No. 68,144
`Counsel for Patent Owner
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`-6-
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`CERTIFICATE OF SERVICE
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`It is certified that a copy of the foregoing has been served on Petitioner via
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`electronic mail transmission addressed to the person(s) at the address below:
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`Michael D. Specht
`mspecht-PTAB@sternekessler.com
`Christopher R. O’Brien
`COBrien-PTAB@sternekessler.com
`Wenchong Shu
`wshu-PTAB@sternekessler.com
`Michael B. Ray
`mray-PTAB@sternekessler.com
`Jonathan Tuminaro
`jtuminar-PTAB@sternekessler.com
`PTAB@sternekessler.com
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`/s/Jing H. Cherng
`Jing H. Cherng
`Reg. No. 68,144
`Counsel for Patent Owner
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`Date: March 20, 2020
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`-7-
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