`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.,
`Petitioners
`v.
`GUI Global Products, Ltd., D/B/A Gwee,
`Patent Owner
`
`Case IPR2021-00338
`U.S. Patent No. 10,589,320
`
`PETITIONERS’ OBJECTIONS TO EVIDENCE SUBMITTED WITH
`PATENT OWNER’S RESPONSE
`
`
`
`Patent No. 10,589,320
`IPR2021-00338
`
`Pursuant to 37 C.F.R. § 42.64(b), Petitioners hereby object to the following
`
`evidence submitted by Patent Owner in their Patent Owner’s Response filed in
`
`IPR2021-00338 on October 5, 2021. These objections are timely filed pursuant to
`
`37 C.F.R. § 42.64(b)(1).
`
`Evidence
`
`Ex. 2003
`
`Objections
`
`FRE 401, 402, 403: The transcript of
`
`Kiaei, Sayfe Deposition Transcript for
`
`the deposition of Dr. Kiaei in
`
`Case IPR 2021-00335
`
`IPR2021-00335 (“the -00335
`
`proceeding”) is not relevant to this
`
`proceeding. Further, any probative
`
`value associated with Exhibit 2003 is
`
`substantially outweighed by a danger
`
`of confusing the issues. The parties’
`
`agreement to use of Dr. Kiaei’s
`
`deposition transcript for the
`
`IPR2021-00336, -00337, and -00338
`
`proceedings in the -00335 proceeding
`
`does not extend to the use of the
`
`deposition transcript from the -00335
`
`1
`
`
`
`Patent No. 10,589,320
`IPR2021-00338
`
`proceeding in the -00336, -00337,
`
`and -00338 proceedings.
`
`Date: October 12, 2021
`
`Respectfully submitted,
`
`/Ali R. Sharifahmadian/
`Ali R. Sharifahmadian, Lead Counsel
`Reg. No. 48,202
`
`2
`
`
`
`Patent No. 10,589,320
`IPR2021-00338
`
`Certificate of Service
`
`The undersigned hereby certifies that a copy of PETITIONERS’ OBJECTIONS TO
`
`EVIDENCE SUBMITTED WITH PATENT OWNER’S RESPONSE was served on
`
`October 12, 2021 by filing this document through the PTAB E2E System as well as by
`
`delivering a copy via email directed to the attorneys of record for Patent Owner at the
`
`following addresses:
`
`jedmonds@ip-lit.com
`tek.fahmi@ascendalaw.com
`sschlather@ip-lit.com
`
`The parties have agreed to electronic service in this proceeding.
`
`Dated: October 12, 2021
`
`/Ali R. Sharifahmadian/
`Ali R. Sharifahmadian
`
`3
`
`