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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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`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., and APPLE INC.,
`Petitioner
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`v.
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`SMART MOBILE TECHNOLOGIES LLC,
`Patent Owner
`____________
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`Case IPR2022-01248
`Patent 8,842,653
`____________
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`PATENT OWNER’S OBJECTIONS TO PETITIONER’S
`DEMONSTRATIVE EXHBITS
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`Patent Owner hereby submits its objections to Petitioner’s demonstrative
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`exhibits.
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`Slide 80:
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`The statement boxed in red is a portion of Petitioner’s expert declaration
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`(Exhibit 1051, [40]) which was improperly incorporated by reference into
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`Petitioner’s Reply (at 20), and for the first time maps the claims’ “multiplexed”
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`signals to the functionality of “application server 710” on Bernard’s PDA, in
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`contrast to the Petition (at 31-38) and the Reply (at 18-21) which expressly mapped
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`that functionality to the “communication server 750” on Bernard’s cradle.
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`- 1 -
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`Slides 86 and 95:
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`The statement boxed in red is Petitioner’s expert declaration (Exhibit 1051,
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`[53]) providing approximately 100 words of numerical analysis based on Exhibit
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`1058, both of which are incorporated by reference in Petitioner’s Reply and not
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`discussed there in any meaningful way, if at all. See Sur-Reply, 30-31.
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`- 2 -
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`Date: October 23, 2023
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`Respectfully submitted,
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`/ Parham Hendifar /
`Kenneth J. Weatherwax, Reg. No. 54,528
`Parham Hendifar, Reg. No. 71,470
`LOWENSTEIN & WEATHERWAX LLP
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`- 3 -
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the following documents were served
`by electronic service, by agreement between the parties, on the date signed below:
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`PATENT OWNER’S OBJECTIONS TO PETITIONER’S
`DEMONSTRATIVE EXHBITS
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`
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`The names and address of the parties being served are as follows:
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`W. Karl Renner
`Jeremy J. Monaldo
`Hyun Jin In
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`Sangki Park
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`Aamir A. Kazi
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`Christopher O. Green
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`Andrew S. Ehmke
`Clint S. Wilkins
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`IPR39843-0125IP1@fr.com
`jjm@fr.com
`in@fr.com
`spark@fr.com
`kazi@fr.com
`cgreen@fr.com
`PTABInbound@fr.com
`axf-ptab@fr.com
`andy.ehmke.ipr@haynesboone.com
`clint.wilkins.ipr@haynesboone.com
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`Respectfully submitted,
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` / Colette Woo /
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`Date: October 23, 2023
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