`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TCT MOBILE (US), INC.; TCT MOBILE (US) HOLDINGS, INC.;
`HUIZHOU TCL MOBILE COMMUNICATION CO. LTD.; AND TCL
`COMMUNICATION, INC.,
`Petitioners
`
`v.
`
`FUNDAMENTAL INNOVATION SYSTEMS INTERNATIONAL LLC,
`Patent Owner
`
`U.S. Patent No. 7,834,586
`Issue Date: November 16, 2010
`Title: MULTIFUNCTIONAL CHARGER SYSTEM AND METHOD
`
`Case No. IPR2021-00599
`
`PETITIONERS’ OBJECTIONS TO
`PATENT OWNER’S SUR-REPLY EVIDENCE
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`PO Box 1450
`Alexandria, Virginia 22313–1450
`
`
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioners TCT Mobile (US), Inc.;
`
`TCT Mobile (US) Holdings, Inc.; Huizhou TCL Mobile Communication Co. Ltd.;
`
`and TCL Communication, Inc. hereby object to the below exhibit, cited and relied
`
`upon in Patent Owner’s April 18, 2022 Sur-Reply, on the following grounds. For
`
`each objected-to exhibit, the pertinent Federal Rule of Evidence (“FRE”) or other
`
`rule that gives rise to the objection is provided, along with a brief summary of the
`
`basis for the objection.
`
`Exhibit 2030 – document purported to be excerpts from Dr. Baker’s
`
`district court report. Untimeliness and Beyond the Proper Scope for a Sur-
`
`Reply: Exhibit 2030 is untimely and beyond the proper scope for a sur-reply. The
`
`2019 Trial Practice Guide Update at 73-74 states that a “sur-reply may not be
`
`accompanied by new evidence other than deposition transcripts of the cross-
`
`examination of any reply witness.” Exhibit 2030 accompanies Patent Owner’s
`
`Sur-Reply and is not a deposition transcript of any reply witness.”
`
`Dated: April 25, 2022
`
`Respectfully submitted,
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`
`
`/Jeffrey Johnson/
`By:
`Jeffrey Johnson, Reg. No. 53,078
`Email: 3J6PTABDocket@orrick.com
`609 Main Street, 40th Floor
`Houston, TX 77002-3106
`Main: (713) 658-6400
`Fax: (713) 658-6401
`
`1
`
`
`
`Robert J. Benson (to be admitted pro hac vice)
`Email: R75PTABDocket@orrick.com
`2050 Main Street, Suite 1100
`Irvine, CA 92614-8255
`Main: (949) 567-6700
`Fax: (949) 567-6710
`Jeremy Jason Lang
`USPTO Reg. No. 73,604
`Email: PTABDocketJJL2@orrick.com
`1000 Marsh Road
`Menlo Park, CA 94025-1015
`Main: (650) 614-7400
`Fax: (650) 614-7401
`
`Attorneys for Petitioners
`
`2
`
`
`
`CERTIFICATION OF SERVICE ON PATENT OWNER
`The undersigned certifies that on April 25, 2022, a copy of the foregoing
`
`was served in its entirety by filing through the Patent Trial and Appeal Board End
`
`to End System, as well as via electronic mail, upon the following attorneys of
`
`record for the Patent Owner:
`
`Hong Annita Zhong
`Jason Sheasby
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`
`hzhong@irell.com
`jsheasby@irell.com
`FundamentalIPRs@irell.com
`
`Attorneys for Patent Owner
`Fundamental Innovation Systems International LLC
`
` /Karen Johnson/
` Karen Johnson
`
`
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