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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 IPR2021-00473
`
`U.S. Patent No. 10,589,320
`
`Patent Owner’s Objections to Evidence Submitted With the Petition for Inter
`Partes Review of U.S. Patent No. 10,589,320
`
`
`
`IPR2021-00473
`U.S. Patent No. 10,589,320
`
`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-
`
`00473. These objections are timely filed pursuant to 37 C.F.R. § 42.64(b)(1).
`
`Evidence
`Exhibit 1020
`Wireless charging mats and receivers
`for your iPhone, iPod, BlackBerry and
`other devices, Powermat,
`https://web.archive.org...
`Exhibit 1021
`Palm | HP® Official Store,
`https://web.archive.org...
`
`Exhibit 1022
`Palm Touchstone Kit Review,
`http://www.palminfocenter.com/news/
`9819/
`palm-touchstone- kit-review/
`Exhibit 1025
`Newton’s Telecom Dictionary (26th
`Expanded and Updated Edition)
`(excerpt)
`
`Exhibit 1026
`Chambers Dictionary of Science and
`Technology (excerpt)
`
`Exhibit 1028
`Lecture 10: Magnetic Force; Magnetic
`Fields; Ampere’s Law, Massachusetts
`Institute of Technology—Department
`of Physics (8.022 Spring 2004)
`
`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.
`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.
`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.
`
`
`
`
`1
`
`
`
`Evidence
`
`Exhibit 1031
`Inclusive design and human factors:
`designing mobile phones for older
`users (Vol. 4, No. 3), PsychNology
`Journal
`
`Exhibit 1032
`Inductive Power Transmission,
`Wireless Power Consortium,
`https://web.archive.org...
`
`Exhibit 1034
`AUDIO/VIDEO REMOTE
`CONTROL PROFILE (Version 1.0
`Adopted), Bluetooth Audio Video
`Working Group
`
`IPR2021-00473
`U.S. Patent No. 10,589,320
`
`
`Objections
`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.
`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
`
`
`
`2
`
`
`
`Evidence
`
`Exhibit 1038
`Voyager 855 Bluetooth Headset—
`User Guide, Plantronics Sound
`Innovation
`
`Exhibit 1039
`Jabra Sport—User Manual, Jabra
`
`Exhibit 1040
`Plantronics Discovery 975—User
`Guide, Plantronics
`
`Exhibit 1041
`Plantronics Discovery 975 Storage
`Case & Charger 79413-02,
`https://web.archive.org...
`
`Exhibit 1045
`Advantages and Weaknesses of LED
`Application, LEDinside,
`https://web.archive.org....
`
`IPR2021-00473
`U.S. Patent No. 10,589,320
`
`
`Objections
`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.
`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 401, 402, 403: As applied by
`Petitioners, this Exhibit is not relevant
`to this proceeding. Further, any
`probative value associated with this
`
`
`
`3
`
`
`
`Evidence
`
`Exhibit 1049
`Plastics in Electrical and Electronic
`Applications, BPF: British Plastics
`Federation, https://web.archive.org...
`
`Next-Generation
`Exhibit 1051
`Stereo Bluetooth Headsets, TechHive,
`https://www.techhive.com...
`
`IPR2021-00473
`U.S. Patent No. 10,589,320
`
`
`Objections
`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 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.
`
`
`
`4
`
`
`
`Evidence
`Exhibit 1052
`Motorola Elite Sliver—User Guide,
`Motorola
`
`Exhibit 1054 Magnetic Closures For
`Packaging, Adams Magnetic Products,
`https://www.adamsmagnetic.com/blog
`s...
`
`Exhibit 1056
`MacBook Air shells and sleeves
`Review, Macworld,
`https://web.archive.org...
`
`Exhibit 1057
`Applications for Hall Effect IC
`Switches in Portable Applications,
`ROHM Semiconductor
`
`Exhibit 1058
`ASTM Dictionary of Engineering
`Science & Technology (10th Edition),
`ASTM Committee E02 on
`Terminology (excerpt)
`Exhibit 1066
`Plugfones.com,
`https://web.archive.org/web/20110820
`072700/https://www.plug fones.com/
`
`Exhibit 1067
`
`IPR2021-00473
`U.S. Patent No. 10,589,320
`
`
`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.
`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.
`
`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
`
`
`
`5
`
`
`
`Evidence
`CES: Hands On with the Kleer
`Wireless Earbuds, Gadget Lab |
`WIRED,
`https://web.archive.org...
`
`IPR2021-00473
`U.S. Patent No. 10,589,320
`
`
`Objections
`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
`
`
`
`
`6
`
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`
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`
`
`
`
`
`
`
`
`IPR2021-00473
`U.S. Patent No. 10,589,320
`
`
`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. 10,589,320
`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
`
`
`
`
`
`
`
`