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`IPR2021-00972
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`U.S. Patent No. 10,638,941
`PATENT OWNER’S OBJECTIONS
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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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`APPLE, INC.,
`Petitioner,
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`v.
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`ALIVECOR, INC.,
`Patent Owner
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`IPR2021-00972
`U.S. Patent No. 10,638,941
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`PATENT OWNER’S OBJECTIONS TO PETITIONER’S EVIDENCE
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`IPR2021-00972
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`U.S. Patent No. 10,638,941
`PATENT OWNER’S OBJECTIONS
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`I.
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`INTRODUCTION
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner AliveCor Inc. (“Patent
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`Owner”), submits the following objections to Petitioner Apple Inc.’s (“Petitioner”)
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`Exhibits . As required by 37 C.F.R. § 42.62, Patent Owner’s objections below apply
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`the Federal Rules of Evidence (“FRE”).
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`II. OBJECTIONS
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`a. Objections to Exhibits 1060-1068; 1074-1080; 1085
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`Patent Owner objects to these exhibits under 37 CFR §42.23(b). The Exhibits
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`present new evidence that is outside the scope of the Petition, are not in response to
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`arguments made in Patent Owner’s Response, and are all evidence Petitioner knew
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`of or should have known of at the time of filing its Petition. Likewise, Patent Owner
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`objects to these exhibits under Fed. R. Evid. 401-403. For example, these exhibits
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`are irrelevant, prejudicial, confusing, and/or time-wasting and/or cumulative.
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`b. Objections to Exhibits 1072-1073; 1081-1084
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`Patent Owner objects to these exhibits under 37 CFR §42.23(b). The Exhibits
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`present new evidence that is outside the scope of the Petition, are not in response to
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`arguments made in Patent Owner’s Response, and are all evidence Petitioner knew
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`of or should have known of at the time of filing its Petition. Likewise, Patent Owner
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`objects to these exhibits under Fed. R. Evid. 401-403. For example, these exhibits
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`IPR2021-00972
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`U.S. Patent No. 10,638,941
`PATENT OWNER’S OBJECTIONS
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`are irrelevant, prejudicial, confusing, and/or time-wasting and/or cumulative. Patent
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`Owner further objects to these exhibits under FRE 801 and 802 because they are
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`inadmissible hearsay.
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`Date: June 29, 2022
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` By: /Jim Glass/
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`James M. Glass (Reg. No. 46,729)
`QUINN EMANUEL URQUHART &
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`SULLIVAN LLP
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`IPR2021-00972
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`U.S. Patent No. 10,638,941
`PATENT OWNER’S OBJECTIONS
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`CERTIFICATE OF SERVICE (37 C.F.R. §§ 42.6(E), 42.105(A))
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`The undersigned hereby certifies that the foregoing document was served in
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`its entirety on June 29, 2022 upon the following parties via Electronic Mail.
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`W. Karl Renner Jeremy J. Monaldo
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`IPR50095-0032IP1@fr.com
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`PTABInbound@fr.com
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`axf-ptab@fr.com
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`monaldo@fr.com
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`Date: June 29, 2022
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` By: /Jim Glass/
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`James M. Glass (Reg. No. 46,729)
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