`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD., MICRON TECHNOLOGY, INC.,
`MICRON SEMICONDUCTOR PRODUCTS, INC., and
`MICRON TECHNOLOGY TEXAS LLC, †
`
`Petitioners,
`v.
`NETLIST, INC.,
`Patent Owner
`
`IPR2022-00996
`Patent 11,016,918
`
`PETITIONER’S OBJECTIONS TO PATENT OWNER’S EVIDENCE
`SUBMITTED WITH PATENT OWNER’S SUR-REPLY
`
`† Micron Technology, Inc., Micron Semiconductor Products, Inc., and Micron
`Technology Texas LLC filed a motion for joinder and a petition in IPR2023-00406
`and have been joined as petitioners in this proceeding.
`
`
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner Samsung Electronics Co.,
`
`Ltd. (“Samsung”) objects to the following evidence submitted by Patent Owner
`
`Netlist, Inc. (“Netlist”) with the Sur-Reply Response (Paper No. 31).
`
`Evidence
`Material attributed to:
`https://www.pcmag.com/
`encyclopedia/term/main-
`memory#:~:text=Main%2
`0memory%20is%20the%
`20primary,to%20the%20
`capacity%20of%20RAM
`(Sur-Reply p. 1, n. 2)
`
`Material attributed to:
`https://upload.wikimedia.
`org/wikipedia/commons/e
`/ef/IRAM13a.JPG
`(Sur-Reply p. 24)
`
`Material attributed to:
`https://www.youtube.com
`/watch?v=bYbCYgYZVT
`8&t=147s
`(Sur-Reply p. 26)
`
`Objection(s)
`Samsung objects under 37 C.F.R. § 42.63(a) to
`Netlist attempting to submit supporting evidence
`without filing the evidence in the form of an exhibit.
`
`Samsung also objects to this evidence under 37
`C.F.R. § 42.23 because a sur-reply may not be
`accompanied by new evidence other than deposition
`transcripts of cross-examination of any reply
`witness. This website is not a deposition transcript
`of cross-examination of a reply witness.
`Samsung objects under 37 C.F.R. § 42.63(a) to
`Netlist attempting to submit supporting evidence
`without filing the evidence in the form of an exhibit.
`
`Samsung also objects to this evidence under 37
`C.F.R. § 42.23 because a sur-reply may not be
`accompanied by new evidence other than deposition
`transcripts of cross-examination of any reply
`witness. This website is not a deposition transcript
`of cross-examination of a reply witness.
`Samsung objects under 37 C.F.R. § 42.63(a) to
`Netlist attempting to submit supporting evidence
`without filing the evidence in the form of an exhibit.
`
`Samsung also objects to this evidence under 37
`C.F.R. § 42.23 because a sur-reply may not be
`accompanied by new evidence other than deposition
`transcripts of cross-examination of any reply
`witness. This website is not a deposition transcript
`of cross-examination of a reply witness.
`
`2
`
`
`
`Dated: August 11, 2023
`
`/Eliot D. Williams/
`Eliot D. Williams, Reg. #50,822
`BAKER BOTTS L.L.P.
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`T: (650) 739-7511
`F: (650) 739-7611
`
`Theodore W. Chandler
`Reg. No. 50,319
`BAKER BOTTS L.L.P.
`1801 Century Park East
`Suite 2400
`Los Angeles, CA 90067
`T: (213) 202-5702
`F: (213) 202-5732
`
`Ferenc Pazmandi
`Reg. No. 66,216
`BAKER BOTTS L.L.P.
`101 California Street
`Suite 3200
`San Francisco, CA 94111
`T: (415) 291-6255
`F: (415) 291-6355
`
`Brianna L. Potter
`Reg. No. 76,748
`BAKER BOTTS L.L.P.
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`T: (650) 739-7556
`F: (650) 739-7656
`
`Counsel for Petitioner
`Samsung Electronics Co., Ltd.
`
`3
`
`
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), I certify that on this 11th day of August,
`
`2023, Petitioner’s Objections to Patent Owner’s Evidence Submitted With
`
`Patent Owner’s Sur-Reply was served by email on the following counsel for
`
`Patent Owner and Micron:
`
`Hong Annita Zhong (Reg. No. 66,530)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`Phone: (310) 277-1010
`Fax: (310) 203-7199
`Email: hzhong@irell.com
`NetlistIPR@irell.com
`Juan C. Yaquian
`WINSTON & STRAWN LLP
`800 Capital Street, Suite 2400
`Houston, TX 77002-2925
`Tel. (713) 651-2600
`Fax. (713) 651-2700
`Email: JYaquian@winston.com;
`Winston-IPR-Netlist@winston.com
`
`Jason Sheasby (not admitted)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067
`Phone: (310) 277-1010
`Fax: (310) 203-7199
`Email: jsheasby@irell.com
`
`Michael R. Rueckheim (not admitted)
`WINSTON & STRAWN LLP
`255 Shoreline Drive, Suite 520
`Redwood City, California 94065
`Phone: (650) 858-6500
`Fax: (650) 858-6550
`Email: mrueckheim@winston.com;
`Winston-IPR-Netlist@winston.com
`
`Dated: August 11, 2023
`
`/Eliot D. Williams/
`Eliot D. Williams, Reg. #50,822
`BAKER BOTTS L.L.P.
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`T: (650) 739-7511
`F: (650) 739-7611
`Counsel for Petitioner Samsung
`Electronics Co., Ltd.
`
`4
`
`
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