`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________
`
`
`SAMSUNG ELECTRONICS CO., LTD.,
`Petitioner
`
`v.
`
`MEMORYWEB, LLC,
`Patent Owner
`
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2022-00222
`Patent 10,621,228
`
`
`
`
`
`
`
`
`
`
`
`
`PETITIONER’S OBJECTIONS TO EVIDENCE
`
`
`
`
`
`
`
`Proceeding No. IPR2022-00222
`Attorney Docket No. 39843-0117IP1
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner, Samsung Electronics Co.,
`
`
`
`
`Ltd., (“Petitioner”), hereby submits its notice of objections to certain evidence that
`
`Patent Owner, Memory Web LLC, (“Patent Owner”), served on June 30, 2023 in
`
`connection with IPR2022-00222.
`
`Description
`No.
`2028 Unified Patents, LLC v.
`MemoryWeb, LLC, IPR2021-
`01413, Petitioner’s Motion to Seal
`and For Entry of Protective Order
`(Paper 10)
`2029 Unified Patents, LLC v.
`MemoryWeb, LLC, IPR2021-
`01413, Petitioner’s Updated
`Mandatory Notices (Paper 57)
`2030 Unified Patents, LLC v.
`MemoryWeb, LLC, IPR2021-
`01413, Final Written Decision
`(Public Version) (Paper 67)
`2031 Unified Patents, LLC v.
`MemoryWeb, LLC, IPR2021-
`01413, Decision Granting Director
`Review (Public Version) (Paper
`76)
`2038 Unified Patents, LLC v.
`MemoryWeb, LLC, IPR2021-
`01413, Order Identifying Real
`Party in Interest (Public Version)
`(Paper 79)
`
`Objections
`These exhibits are papers and
`decisions rendered in a different
`IPR proceeding that did not
`involve Petitioner. These exhibits
`do not constitute evidence and
`should be excluded. Petitioner
`also objects to the use of filings
`and decisions from another
`proceeding that did not involve
`Petitioner to preserve due process.
`
`FRE 401/402/403 (Relevancy):
`These exhibits are inadmissible as
`irrelevant and prejudicial because,
`among other things, they relate to
`an improper RPI determination
`that has been vacated.
`
`FRE 801-802 (Hearsay): These
`exhibits contain inadmissible
`hearsay cited for the truth of the
`statements contained therein.
`Patent Owner has identified no
`applicable hearsay exception for
`the statements in these exhibits.
`
`
`
`
`
`
`
`1
`
`
`
`
`
`Dated July 10, 2023
`
`
`
`
`
`
`
`(Control No. IPR2022-00222)
`
`
`
`Proceeding No. IPR2022-00222
`Attorney Docket No. 39843-0117IP1
`
`
`
`
`
`
`
`/Jeremy J. Monaldo/
`W. Karl Renner, Reg. No. 41,265
`Jeremy J. Monaldo, Reg. No. 58,680
`Hyun Jin In, Reg. No. 70,014
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`T: 202-783-5070
`F: 877-769-7945.
`
`Attorneys for Petitioner
`
`2
`
`
`
`
`
`Proceeding No. IPR2022-00222
`Attorney Docket No. 39843-0117IP1
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §§42.6(e), the undersigned certifies that on July 10,
`
`2023 a complete and entire copy of this Petitioner’s Objections to Evidence was
`
`provided via email to the Patent Owner by serving the correspondence email
`
`address of record as follows:
`
`Jennifer Hayes
`George Dandalides
`Matthew A. Werber
`Nixon Peabody LLP
`300 South Grand Avenue, Suite 4100
`Los Angeles, CA 90071-3151
`
`Email: jenhayes@nixonpeabody.com
`gdandalides@nixonpeabody.com
`mwerber@nixonpeabody.com
`
`
`
`
`
`
`
`
`/Kristyn Waldhauser/
`Kristyn Waldhauser
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(612) 638-5731
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`3
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
