`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`
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`APPLIED MATERIALS, INC.
`Petitioner,
`
`v.
`
`DEMARAY LLC
`Patent Owner.
`
`
`___________________
`
`Case IPR2021-00103
`Patent No. 7,544,276
`___________________
`
`
`
`PATENT OWNER’S OBJECTIONS TO EVIDENCE FILED WITH
`PETITION PURSUANT TO 37 C.F.R. § 42.64(b)(1)
`
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`
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313
`
`10949947
`
`
`
`
`
`
`Case IPR2021-00103
`Patent No. 7,544,276
`Pursuant to 37 C.F.R. § 42.64(b)(1) and the Federal Rules of Evidence
`
`(“FRE”), Patent Owner hereby submits the following objections to certain
`
`exhibits filed with Petitioner’s Petition for Inter Partes Review of U.S. Patent
`
`No. 7,544,276.
`
`Exhibit 1024 (Pinnacle Plus+ 10KW (325-650 Vdc) Master/Slave AE
`Bus, DeviceNet, MDXL User, UHF Output User Manual)
`Patent Owner objects to Ex. 1024 as not properly authenticated under
`
`FRE 901 and 902. Ex. 1024 contains no identification of an author, a recipient,
`
`or the genuineness of its contents, and is further unaccompanied by testimony
`
`attesting to its authenticity. Patent Owner further objects to Ex. 1024 as
`
`irrelevant under FRE 401. Patent Owner further objects to Ex. 1024 as
`
`inadmissible hearsay under FRE 801 and 802 that does not fall within any
`
`exceptions.
`
`Exhibit 1025 (The Advanced Energy MDX Magnetron Drive,
`Advanced Energy Industries, Inc.)
`Patent Owner objects to Ex. 1025 as not properly authenticated under
`
`FRE 901 and 902. Ex. 1025 contains no identification of an author, a recipient,
`
`or the genuineness of its contents, and is further unaccompanied by testimony
`
`attesting to its authenticity. Patent Owner further objects to Ex. 1025 as
`
`irrelevant under FRE 401. Patent Owner further objects to Ex. 1025 as
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`inadmissible hearsay under FRE 801 and 802 that does not fall within any
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`exceptions.
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`10949947
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`- 1 -
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`Case IPR2021-00103
`Patent No. 7,544,276
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`Exhibit 1026 (Pinnacle 10x6 kW DeviceNet, MDXL User 5702063-C,
`User Manual)
`Patent Owner objects to Ex. 1026 as not properly authenticated under
`
`FRE 901 and 902. Ex. 1026 contains no identification of an author, a recipient,
`
`or the genuineness of its contents, and is further unaccompanied by testimony
`
`attesting to its authenticity. Patent Owner further objects to Ex. 1026 as
`
`irrelevant under FRE 401. Patent Owner further objects to Ex. 1026 as
`
`inadmissible hearsay under FRE 801 and 802 that does not fall within any
`
`exceptions.
`
`Exhibit 1062 (Pinnacle 20 kW DeviceNet, MDXL User 5702199-A,
`User Manual)
`Patent Owner objects to Ex. 1062 as not properly authenticated under
`
`FRE 901 and 902. Ex. 1062 contains no identification of an author, a recipient,
`
`or the genuineness of its contents, and is further unaccompanied by testimony
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`attesting to its authenticity. Patent Owner further objects to Ex. 1062 as
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`irrelevant under FRE 401. Patent Owner further objects to Ex. 1062 as
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`inadmissible hearsay under FRE 801 and 802 that does not fall within any
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`exceptions.
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`Exhibit 1065 (Pinnacle Plus Pulsed DC Power Supply Data Sheet)
`Patent Owner objects to Ex. 1065 as not properly authenticated under
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`FRE 901 and 902. Ex. 1065 contains no identification of an author, a recipient,
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`or the genuineness of its contents, and is further unaccompanied by testimony
`- 2 -
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`10949947
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`attesting to its authenticity. Patent Owner further objects to Ex. 1065 as
`
`Case IPR2021-00103
`Patent No. 7,544,276
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`irrelevant under FRE 401. Patent Owner further objects to Ex. 1065 as
`
`inadmissible hearsay under FRE 801 and 802 that does not fall within any
`
`exceptions.
`
`Exhibit 1066 (Advanced Energy Industries, Inc. SEC 10-K)
`Patent Owner objects to Ex. 1066 as not properly authenticated under
`
`FRE 901 and 902. Ex. 1066 contains no identification of an author, a recipient,
`
`or the genuineness of its contents, and is further unaccompanied by testimony
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`attesting to its authenticity. Patent Owner objects to Ex. 1066 as inadmissible
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`hearsay under FRE 801 and 802 that does not fall within any exceptions.
`
`Exhibit 1067 (Pinnacle Plus 10kW User 5702269-B, User Manual)
`Patent Owner objects to Ex. 1067 as not properly authenticated under
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`FRE 901 and 902. Ex. 1067 contains no identification of an author, a recipient,
`
`or the genuineness of its contents, and is further unaccompanied by testimony
`
`attesting to its authenticity. Patent Owner further objects to Ex. 1067 as
`
`irrelevant under FRE 401. Patent Owner further objects to Ex. 1067 as
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`inadmissible hearsay under FRE 801 and 802 that does not fall within any
`
`exceptions.
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`Dated: May 25, 2021
`
`Respectfully submitted,
`
`
`
`
`10949947
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`
`Hong Zhong
`H. Annita Zhong, Reg. No. 66,530
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`- 3 -
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`CERTIFICATE OF SERVICE
`
`Case IPR2021-00103
`Patent No. 7,544,276
`
`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on May 25,
`
`2021, a copy of the foregoing document PATENT OWNER’S
`
`OBJECTIONS TO EVIDENCE FILED WITH PETITION PURSUANT
`
`TO 37 C.F.R. § 42.64(b)(1) was served, by electronic mail, as agreed to by the
`
`parties, upon the following:
`
`PAUL HASTINGS LLP
`
`Naveen Modi, Reg. No. 46,224
`PH-Applied_Materials-Demaray-IPR@paulhastings.com
`
`Joseph E. Palys, Reg. No. 46,508
`PH-Applied_Materials-Demaray-IPR@paulhastings.com
`
`Howard Herr (pro hac admission to be requested)
`PH-Applied_Materials-Demaray-IPR@paulhastings.com
`
`
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`By: /Susan M. Langworthy/
` Susan M. Langworthy
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`10949947
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