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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD. AND SAMSUNG ELECTRONICS
`AMERICA, INC.,
`
`Petitioners,
`
`v.
`
`GUI GLOBAL PRODUCTS, LTD.,
`
`Patent Owner.
`
`Case IPR2021-00335
`
`U.S. Patent No. 10,259,020
`
`Patent Owner’s Objections to Evidence Submitted With the Petition for Inter
`Partes Review of U.S. Patent No. 10,259,020
`
`
`
`IPR2021-00335
`U.S. Patent No. 10,259,020
`
`Pursuant to 37 C.F.R. § 42.64(b), Patent Owner hereby objects to the
`
`following evidence submitted by Petitioners with their Petition filed in IPR2021-
`
`00470 on December 29, 2020. These objections are timely filed pursuant to 37
`
`C.F.R. § 42.64(b)(1).
`
`Evidence
`Ex. 1012
`Korean Patent Publication 10-2008-
`0093178 to Koh et al.
`
`Ex. 1023
`A Dictionary of Chemistry, 5th ed.
`(2004)
`
`
`
`
`1
`
`Objections
`37 CFR § 42.63(b): The Declaration
`does not comply with 37 CFR §
`42.63(b). It does not state that the
`Declarant is fluent in Korean or
`English, or that the translation is in fact
`accurate or complete. It merely states
`that the Declarant is “well-versed” in
`English and Korean, and alleges
`accuracy and completeness “to the best
`of my knowledge.”
`FRE 602: For the reasons stated above,
`the Declaration does not sufficiently
`show that the witness has personal
`knowledge of the matters stated
`therein.
`FRE 901, 902: Exhibit 1023 is not self-
`authenticating under FRE 902, and
`Petitioners have not produced evidence
`
`
`
`IPR2021-00335
`U.S. Patent No. 10,259,020
`
`
`Objections
`sufficient to support a finding that it is
`what Petitioners say it is.
`FRE 901, 902: Exhibit 1028 is not self-
`authenticating under FRE 902, and
`Petitioners have not produced evidence
`sufficient to support a finding that it is
`what Petitioners say it is.
`FRE 401, 402, 403: As applied by
`Petitioners, Exhibit 1028 is not relevant to
`this proceeding. Further, any probative
`value associated with Exhibit 1028 is
`substantially outweighed by a danger of
`confusing the issues.
`FRE 802: Petitioners are apparently
`attempting to use Exhibit 1028 for the truth
`of the matters asserted therein. Exhibit
`1028 is thus hearsay, and as no hearsay
`exception applies, it is inadmissible.
`FRE 901, 902: Exhibit 1029 is not self-
`authenticating under FRE 902, and
`Petitioners have not produced evidence
`sufficient to support a finding that it is
`what Petitioners say it is.
`FRE 401, 402, 403: As applied by
`Petitioners, Exhibit 1029 is not relevant to
`
`Evidence
`
`Ex. 1028
`Bluetooth Hands-Free Profile, rev.
`10r00 (November 25, 2005)
`
`
`Ex. 1029
`Bluetooth Audio/Video Remote Control
`Profile, rev. 13 (April 16, 2007)
`
`
`
`2
`
`
`
`Evidence
`
`IPR2021-00335
`U.S. Patent No. 10,259,020
`
`
`Objections
`this proceeding. Further, any probative
`value associated with Exhibit 1029 is
`substantially outweighed by a danger of
`confusing the issues.
`FRE 802: Petitioners are apparently
`attempting to use Exhibit 1029 for the truth
`of the matters asserted therein. Exhibit
`1029 is thus hearsay, and as no hearsay
`exception applies, it is inadmissible.
`
`Date: July 19, 2021
`
`Respectfully submitted,
`
`
`/ John J. Edmonds /
`John J. Edmonds, Reg. No. 56,184
`EDMONDS & SCHLATHER, PLLC
`2501 Saltus Street
`Houston, TX 77003
`P: 713-364-5291
`F: 713-224-6651
`E: jedmonds@ip-lit.com
`
`Counsel for Patent Owner
`
`
`
`
`3
`
`
`
`
`
`
`
`
`
`
`
`
`
`IPR2021-00335
`U.S. Patent No. 10,259,020
`
`
`CERTIFICATE OF SERVICE
`
`
`The undersigned hereby certifies that a copy of the foregoing
`Patent Owner’s Objections to Evidence Submitted With the Petition
`for Inter Partes Review of U.S. Patent No. 10,259,020
`was served on July 19, 2021, by filing this document though the PTAB E2E
`System as well as by delivering a copy via email directed to the attorneys of record
`for the Petitioner at the following addresses:
`
`ali.sharifahmadian@arnoldporter.com
`jin.park@arnoldporter.com
`chris.moulder@arnoldporter.com
`mark.patrick@arnoldporter.com
`
`The parties have agreed to electronic service in this proceeding.
`
`Dated: July 19, 2021
`
`/ John J. Edmonds /
`John J. Edmonds
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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