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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE, INC.,
`
`Petitioner,
`
`v.
`
`GUI GLOBAL PRODUCTS, LTD.,
`
`Patent Owner.
`
`Case IPR2021-00470
`
`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
`
`
`
`IPR2021-00470
`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. These objections are timely filed pursuant to 37 C.F.R. § 42.64(b)(1).
`
`Evidence
`Exhibit 1004
`Certified English Translation of
`French Patent Publication No.
`FR2912858 to Bohbot
`
`Exhibit 1006
`Certified English Translation of
`Chinese Patent Publication No.
`CN201114710Y to Li et al.
`
`Exhibit 1020
`Certified English Translation of
`European Patent Publication
`No. EP2037661 to Ponticelli et al.
`
`Objections
`37 CFR § 42.63(b): The Declaration
`does not comply with 37 CFR §
`42.63(b). It does not state that the
`translation is in fact true, full and
`accurate. It merely alleges such matters
`“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.
`37 CFR § 42.63(b): The Declaration
`does not comply with 37 CFR §
`42.63(b). It does not state that the
`translation is in fact true, full and
`accurate. It merely alleges such matters
`“to the best of my knowledge.” Further,
`the declarant alleges translation of a
`“French document.”
`
`
`FRE 602: For the reasons stated above,
`the Declaration does not sufficiently
`show that the witness has personal
`knowledge of the matters stated therein.
`37 CFR § 42.63(b): The Declaration
`does not comply with 37 CFR §
`42.63(b). It does not state that the
`translation is in fact true, full and
`accurate. It merely alleges such matters
`“to the best of my knowledge.”
`
`
`
`
`1
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`
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`Evidence
`
`Exhibit 1034
`AUDIO/VIDEO REMOTE
`CONTROL PROFILE (Version 1.0
`Adopted), Bluetooth Audio Video
`Working Group
`
`Exhibit 1038
`Voyager 855 Bluetooth Headset—
`User Guide, Plantronics Sound
`Innovation
`
`Exhibit 1039
`Jabra Sport—User Manual, Jabra
`
`Exhibit 1045
`Advantages and Weaknesses of LED
`Application, LEDinside,
`https://web.archive.org....
`
`IPR2021-00470
`U.S. Patent No. 10,259,020
`
`
`Objections
`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: This Exhibit 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, this Exhibit is not relevant
`to this proceeding. Further, any
`probative value associated with this
`Exhibit is substantially outweighed by a
`danger of confusing the issues.
`
`FRE 802: Petitioners are apparently
`attempting to use Exhibit 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: This Exhibit 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 901, 902: This Exhibit 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 901, 902: This Exhibit 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.
`
`
`
`
`2
`
`
`
`Evidence
`
`Next-Generation
`Exhibit 1051
`Stereo Bluetooth Headsets, TechHive,
`https://www.techhive.com...
`
`Exhibit 1066
`Plugfones.com,
`https://web.archive.org/web...
`
`IPR2021-00470
`U.S. Patent No. 10,259,020
`
`
`Objections
`FRE 401, 402, 403: As applied by
`Petitioners, this Exhibit is not relevant
`to this proceeding. Further, any
`probative value associated with this
`Exhibit is substantially outweighed by a
`danger of confusing the issues.
`
`FRE 802: Petitioners are apparently
`attempting to use Exhibit 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: This Exhibit 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, this Exhibit is not relevant
`to this proceeding. Further, any
`probative value associated with this
`Exhibit is substantially outweighed by a
`danger of confusing the issues.
`
`FRE 802: Petitioners are apparently
`attempting to use Exhibit 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: This Exhibit 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.
`
`
`
`
`
`3
`
`
`
`Evidence
`Exhibit 1067
`CES: Hands On with the Kleer
`Wireless Earbuds, Gadget Lab |
`WIRED,
`https://web.archive.org...
`
`IPR2021-00470
`U.S. Patent No. 10,259,020
`
`
`Objections
`FRE 901, 902: This Exhibit 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.
`
`Date: August 27, 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
`
`
`
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`4
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`IPR2021-00470
`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 August 27, 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:
`patrick@fr.com; rizzolo@fr.com; pacheco@fr.com; Leung@fr.com;
`kdarby@fr.com; devoto@fr.com; renner@fr.com
`
`
`The parties have agreed to electronic service in this proceeding.
`
`Dated: August 27, 2021
`
`/ John J. Edmonds /
`John J. Edmonds
`
`
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`5
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