`Filed: December 21, 2021
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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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`QUALCOMM INCORPORATED and
`ZYXEL COMMUNICATIONS CORPORATION1,
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`Petitioners,
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`v.
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`UNM RAINFOREST INNOVATIONS,
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`Patent Owner.
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`PTAB Case No. IPR2021-00375
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`Patent No. 8,265,096 B2
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`UNM RAINFOREST INNOVATIONS’ RESPONSE
`TO PETITIONER’S OBJECTIONS TO EVIDENCE
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`1 ZyXEL Communications Corporation was joined as a petitioner in this
`proceeding based on a petition and motion for joinder filed in IPR2021-00734,
`which were granted.
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`Patent Owner UNM Rainforest Innovations filed the final certified transcript
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`of the deposition of Dr. Sumit Roy as Exhibit EX2015 on December 20, 2021.
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`Accordingly, the evidentiary objection raised on December 14, 2021 has been
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`cured. 37 C.F.R. § 42.64(b)(2).
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`Dated: December 21, 2021
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`Respectfully submitted,
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`/s/ Jay P. Kesan
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`Jay P. Kesan, Reg. No. 37,488
`DIMUROGINSBERG, PC
`DGKEYIP GROUP
`1750 Tysons Blvd. Suite 1500
`Tysons Corner, VA 22102
`jkesan@dimuro.com
`Telephone: (703) 289-5118
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`Alfonso Chan, Reg. No. 45,964
`SHORE CHAN LLP
`901 Main Street, Suite 3300
`Dallas, TX 75202
`achann@shorechan.com
`Telephone: (214) 593-9110
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`Attorneys for Patent Owner
`UNM RAINFOREST INNOVATIONS
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. §§ 42.6(e)(4) and 42.25(b), the undersigned certifies
`that on December 21, 2021, a complete copy of Patent Owner UNM Rainforest
`Innovations’ Response to Petitioner’s Objections to Evidence was filed
`electronically through the Patent Trial and Appeal Board’s PTABE2E System and
`provided, via electronic service, to the Petitioner by serving the correspondence
`address of record.
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`Dated: December 21, 2021
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`/s/ Jay P. Kesan
`Jay P. Kesan
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