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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`QUALCOMM INCORPORATED,
`Petitioner,
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`UNM RAINFOREST INNOVATIONS,
`Patent Owner.
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`PTAB Case No. IPR2021-00375
`Patent No. 8,265,096 B2
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`UNM RAINFOREST INNOVATIONS’ RESPONSE TO
`PETITIONER’S OBJECTIONS TO EVIDENCE (PAPER 33)
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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 Dec. 20, 2021. All
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`citations to the rough transcript (EX2014) will be replaced with citations to the
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`final transcript (EX2015), including in Papers 27, 28, and 31. Accordingly, the
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`evidentiary objection raised on Dec. 23, 2021 (Paper 33), will be cured. 37 C.F.R.
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`§ 42.64(b)(2).
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`Paper 33 further raises Petitioner’s objection that “the deposition transcript
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`submitted as Ex. 2015 has not been read and signed by the witness.” Patent Owner
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`has reached out to Petitioner regarding when Petitioner will provide and file the
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`deposition transcript as read and signed by the witness as well as a related errata
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`sheet—if any—and will expediently file the appropriate materials when they are
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`received from Petitioner.
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`Dated: December 30, 2021
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`Respectfully submitted,
`/s/ Jay P. Kesan
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`Jay P. Kesan, Reg. No. 37,488
`Cecil E. Key
`DIMUROGINSBERG, PC
`DGKEYIP GROUP
`1750 Tyson’s Blvd. Suite 1500
`Tysons Corner, VA 22102
`jkesan@dimuro.com
`ckey@dimuro.com
`Telephone: (703) 289-5118
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`Ari Rafilson, Reg. No. 58,693
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`Shore Chan DePumpo LLP
`901 Main Street, Suite 3300
`Dallas, TX 75202
`arafilson@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), the undersigned certifies that on
`December 30, 2021, a complete copy of this document 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 30, 2021
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`/s/ Jay P. Kesan
`Jay P. Kesan
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