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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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`MEDTRONIC, INC., AND MEDTRONIC VASCULAR, INC.
`Petitioners,
`
`v.
`
`TELEFLEX INNOVATIONS S.A.R.L.
`Patent Owner.
`
`
`
`
`Case IPR2020-01343
`Patent RE46,116
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`PATENT OWNER’S OBJECTIONS TO EVIDENCE
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`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner hereby submits its notice
`
`of objections to certain evidence that Petitioner submitted in connection with
`
`IPR2020-01343.
`
`Exhibit
`Number
`1005
`
`Objections
`
`Patent Owner objects to Exhibit 1005 to the extent Dr. Brecker has
`not disclosed materials considered other than those referenced in his
`declaration. See 37 C.F.R. §§ 42.65(a) and (b).
`
`FRE 702, 703, 37 C.F.R. §§ 42.65:
`
`¶¶ 17-18, 21, 28, 31, 37, 48, 50-54, 89, 92-95, 97, 101-109, 112-114,
`117, 119, 121, 126-129, 139, 153, 158, 161, 164-166, 172-174, 176-
`181, 184-185, 188, 190, 192-194, 201, 205-208, 212-214, 220, 222,
`226-232, 234-238, 240-243, 245-246, 250-258, 262, 266, 269, 271-
`274, 276, 279-284, 287-294, 297-298, 301-306, 308-316, 318-322 are
`not based on sufficient facts and data and do not reliably apply facts
`and data using scientific principles.
`
`
`FRE 401, 402, 403:
`
`Sections IX.B and X.B-C are not relevant because the Itou reference
`is not prior art; to the extent Sections IX.B and X.B-C are relevant,
`their probative value is outweighed by the danger of causing unfair
`prejudice and confusing the issues.
`
`¶¶ 37, 45, and 49 are not relevant; to the extent they are relevant, their
`probative value is outweighed by the danger of causing unfair
`prejudice and confusing the issues because they lack support for the
`contentions for which they are cited and improperly characterize the
`understanding of a POSITA.
`
`¶¶ 104-106 are not relevant; to the extent they are relevant, their
`probative value is outweighed by the danger of causing unfair
`prejudice and confusing the issues because they lack support for the
`
`1
`
`
`
`contentions for which they are cited and improperly characterize the
`teachings of Kontos.
`
` 109 contains irrelevant statements; to the extent such statements are
`relevant, their probative value is outweighed by the danger of causing
`unfair prejudice and confusing the issues because they lack support
`for the contentions for which they are cited and improperly
`characterize the teachings of Ressemann.
`
`¶¶ 113-117 are not relevant; to the extent they are relevant, their
`probative value is outweighed by the danger of causing unfair
`prejudice and confusing the issues because they lack support for the
`contentions for which they are cited and improperly characterize the
`teachings of Kataishi.
`
` ¶
`
` ¶
`
` 118 is not relevant; to the extent it is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice and confusing
`the issues because it lacks support for the contentions for which it is
`cited and improperly characterizes the teachings of Enger.
`
`¶¶ 37, 126-129, 139 contain irrelevant statements; to the extent they
`are relevant, their probative value is outweighed by the danger of
`causing unfair prejudice and confusing the issues because they lack
`support and/or context for the contentions for which they are cited
`and improperly characterize the teachings of the ’116 and/or ’850
`patents.
`
`
`FRE 702, 703, 704:
`
`¶¶ 17-18, 21, 31, 179-180, 192-193, 205-207, 227, 231, 238, 242-243,
`245-246, 252-256, 258, 272, 274, 279-283, 288, 294, 298, 303-304,
`309, 314-316, 318-319, 321-322 and Headings X, X.A-C state
`improper legal conclusions.
`
`Patent Owner additionally objects to Exhibit 1005 under FRE 802
`(hearsay) to the extent that Patent Owner does not have the
`opportunity to cross-examine Dr. Brecker regarding his declaration.
`35 U.S.C. § 102: The exhibit is not prior art.
`
`1007
`
`2
`
`
`
`
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`
`FRE 106: This document is incomplete.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 106: This document is incomplete.
`FRE 901, 902: This document has not been authenticated.
`
`35 U.S.C. § 311: This document does not qualify as a printed
`publication.
`
`FRE 802: This document is hearsay
`FRE 901, 902: This document has not been authenticated.
`
`
`3
`
`1011
`
`1016
`
`1017
`
`1021
`1022
`
`1023
`
`
`
`1024
`
`1026
`
`1027
`
`1030
`
`1031
`
`35 U.S.C. § 311: This document does not qualify as a printed
`publication.
`
`FRE 802: This document is hearsay
`FRE 901, 902: This document has not been authenticated.
`
`35 U.S.C. § 311: This document does not qualify as a printed
`publication.
`
`FRE 802: This document is hearsay
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`
`FRE 802: This document is hearsay.
`
`4
`
`
`
`1034
`
`1036
`
`1037
`
`1038
`
`1039
`
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`
`FRE 802: This document is hearsay.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`
`FRE 802: This document is hearsay.
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`
`FRE 802: This document is hearsay.
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`
`FRE 802: This document is hearsay.
`
`5
`
`
`
`1042
`
`1044
`
`1045
`
`Patent Owner objects to Exhibit 1042 to the extent Dr. Hillstead has
`not disclosed materials considered other than those referenced in his
`declaration. See 37 C.F.R. §§ 42.65(a) and (b).
`
`FRE 702, 703, 37 C.F.R. §§ 42.65:
`
`¶¶ 12, 19, 25, 32, 34, 36-41, 53, 55, 58-72, 76-77, 80-81, 84-98, 100-
`102, 106, 109, 112-114, 116-119, 121 are not based on sufficient
`facts and data and do not reliably apply facts and data using scientific
`principles.
`
`FRE 401, 402, 403:
`
`Exhibit 1042 is not relevant because the Itou reference is not prior art;
`to the extent Exhibit 1042 is relevant, its probative value is
`outweighed by the danger of causing unfair prejudice and confusing
`the issues.
`
`FRE 702, 703, 704:
`
`¶¶ 19, 58-59, 63, 69-70, 72, 81, 90-92, 95-98, 109, 113, 116-119 state
`improper legal conclusions.
`
`
`Patent Owner additionally objects to Exhibit 1042 under FRE 802
`(hearsay) to the extent that Patent Owner does not have the
`opportunity to cross-examine Dr. Hillstead regarding his declaration.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`
`6
`
`
`
`1047
`
`1048
`
`1049
`
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`
`FRE 802: This document is hearsay.
`
`FRE 901, 902: This document has not been authenticated.
`
`35 U.S.C. § 311: This document does not qualify as a printed
`publication.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`
`FRE 802: This document is hearsay.
`
`FRE 901, 902: This document has not been authenticated.
`
`35 U.S.C. § 311: This document does not qualify as a printed
`publication.
`
`7
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`
`
`1052
`
`1056
`
`1057
`
`1058
`
`1059
`
`1060
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`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`
`FRE 802: This document is hearsay.
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`
`8
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`
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`1063
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`1064
`
`1066
`
`1067
`
`1068
`
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`
`9
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`
`
`1069
`
`1073
`
`1074
`
`1076
`
`1077
`
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`
`FRE 106: This document is incomplete.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`
`35 U.S.C. § 102: The exhibit is not prior art.
`
`FRE 802: This document is hearsay.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`
`10
`
`
`
`1079
`
`1080
`
`1081
`
`1083
`
`1084
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`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`
`FRE 106: This document is incomplete.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 106, 1002: This document is incomplete. This document has
`been modified.
`
`FRE 401, 402, 403: In view of the Board’s Institution Decision, this
`document is irrelevant and inadmissible under Rule 402. To the
`extent it may be relevant, its probative value is outweighed by the
`danger of causing unfair prejudice, confusing the issues, causing
`undue delay, wasting time, or needlessly presenting cumulative
`evidence, and therefore it is inadmissible under Rule 403. The exhibit
`is not cited in the Petition or either expert declaration (Exs. 1005,
`1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`
`11
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`
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`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`
`FRE 106: This document is incomplete.
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`
`1088
`
`1093
`
`1095
`
`1096
`
`1097
`
`12
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`
`
`1098
`
`1099
`
`1108
`
`1114-
`1116
`
`1118
`
`1120
`
`
`
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`FRE 403: To the extent this document may be relevant, its probative
`value is outweighed by the danger of causing unfair prejudice,
`confusing the issues, causing undue delay, wasting time, or
`needlessly presenting cumulative evidence, and therefore the
`document is inadmissible under Rule 403.
`
`FRE 106: This document is incomplete.
`FRE 401, 402, 403: In view of the Board’s Institution Decision, these
`references are irrelevant and inadmissible under Rule 402. To the
`extent they are relevant, their probative value is outweighed by the
`danger of causing unfair prejudice, confusing the issues, causing
`undue delay, wasting time, or needlessly presenting cumulative
`evidence, and therefore they are inadmissible under Rule 403.
`FRE 401, 402, 403: This exhibit is not relevant. To the extent this
`document is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore the document is inadmissible under Rule 403. The
`exhibit is not cited in the Petition or either expert declaration (Exs.
`1005, 1042).
`FRE 401, 402, 403: In view of the Board’s Institution Decision, this
`document is irrelevant and inadmissible under Rule 402. To the
`extent it is relevant, its probative value is outweighed by the danger
`of causing unfair prejudice, confusing the issues, causing undue
`delay, wasting time, or needlessly presenting cumulative evidence,
`and therefore it is inadmissible under Rule 403.
`
`13
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`Dated: March 10, 2021.
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`Respectfully submitted,
`
`
`
`/J. Derek Vandenburgh /
`J. Derek Vandenburgh (Lead Counsel)
`Registration No. 32,179
`Carlson, Caspers, Vandenburgh
` & Lindquist, P.A.
`225 South Sixth Street, Suite 4200
`Minneapolis, MN 55402
`Telephone: (612) 436-9600
`Facsimile: (612) 436-9650
`Email:
`DVandenburgh@carlsoncaspers.com
`
`Lead Counsel for Patent Owner
`
`14
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`
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`CERTIFICATION OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e) and the agreement of the parties, the
`
`
`
`undersigned certifies that on March 10, 2021, a true and correct copy of the
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`foregoing Patent Owner’s Objections to Evidence was served via electronic mail
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`upon the following:
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`
`
`Cyrus A. Morton (Reg. No. 44,954)
`Sharon Roberg-Perez (Reg. No. 69,600)
`Christopher A. Pinahs (Reg. No. 76,375)
`Robins Kaplan LLP
`800 LaSalle Avenue, Suite 2800
`Minneapolis, MN 55401
`Phone: 349-8500
`Fax: 612-339-4181
`Email: Cmorton@robinskaplan.com
`Email: Sroberg-perez@robinskaplan.com
`Email: Cpinahs@robinskaplan.com
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`/J. Derek Vandenburgh/
`J. Derek Vandenburgh (Lead Counsel for Patent Owner)
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`15
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