`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 IPR2022-01249
`Patent 9,019,946 B1
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`PETITIONER’S OBJECTIONS TO EVIDENCE
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`SUBMITTED WITH PATENT OWNER’S PRELIMINARY RESPONSE
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`Pursuant 37 C.F.R. § 42.64(b), Petitioner objects to evidence submitted by
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`Proceeding No.: IPR2022-01249
`Attorney Docket: 39843-0126IP1
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`
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`Patent Owner during the preliminary, pre-institution stage of this IPR, which was
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`instituted on January 24, 2023. Specifically, Petitioner objects to the following
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`exhibits submitted by Patent Owner for the bases noted below:
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`Exhibit
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`EX-2002
`Declaration of Professor Todor V.
`Cooklev, Ph.D.
`
`
`EX-2006
`ElectronicsTutorials, The
`Multiplexer,
`WWW.ELECTRONICS-
`TUTORIALS.WS,
`https://www.electronics-
`
`Objections
`FRE 401/402/403/702: This exhibit is
`inadmissible because Dr. Cooklev’s
`opinions are conclusory, are based on
`improper assumptions about the facts and
`legal conclusions in this IPR, do not
`disclose underlying facts or data in
`support of those opinions, and are
`unreliable. Further, it has not been shown
`that Dr. Cooklev is qualified to testify
`competently regarding the matters the
`opinions are said to address. In addition,
`the opinions in this Declaration are
`irrelevant, beyond the proper scope of the
`arguments, risk causing confusion or a
`waste of time, and of minimal probative
`value. Moreover, the Declaration
`references several portions of the exhibits
`objected below, and thus Petitioner objects
`to any portions of EX-2002 that reference
`or rely upon information contained in the
`exhibits objected to below and for the
`same bases articulated below.
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`FRE 901 (Authentication): This exhibit
`is inadmissible for lack of proper
`authentication. Patent Owner has not
`presented evidence sufficient to support a
`finding that the exhibit is what it is
`purported to be.
`
`
`1
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`
`
`tutorials.ws/combination/comb_2.ht
`ml (last visited Oct. 26, 2022)
`
`EX-2007
`TexasInstruments, 74HC153 Data
`Sheet, Dec. 1982, revised Feb.
`2022, WWW.TI.COM,
`https://www.ti.com/lit/gpn/sn74hc1
`53
`
`
`EX-2008
`Lee Stanton, What is the Difference
`Between a Landline and a Mobile
`Phone Number?, WWW.ALPHR.COM,
`Feb. 22, 2022,
`https://www.alphr.com/difference-
`landline-mobile-phone-number/
`
`
`Proceeding No.: IPR2022-01249
`Attorney Docket: 39843-0126IP1
`FRE 801-802 (Hearsay): This exhibit
`contains inadmissible hearsay cited for the
`truth of the statements contained therein.
`Patent Owner has identified no applicable
`hearsay exception for the statements in the
`exhibit.
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`FRE 401/402/403 (Relevancy): This
`exhibit is inadmissible as irrelevant
`because, among other things, it has not
`been shown to qualify as prior art.
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`FRE 901 (Authentication): This exhibit
`is inadmissible for lack of proper
`authentication. Patent Owner has not
`presented evidence sufficient to support a
`finding that the exhibit is what it is
`purported to be.
`
`FRE 801-802 (Hearsay): This exhibit
`contains inadmissible hearsay cited for the
`truth of the statements contained therein.
`Patent Owner has identified no applicable
`hearsay exception for the statements in the
`exhibit.
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`FRE 401/402/403 (Relevancy): This
`exhibit is inadmissible as irrelevant
`because, among other things, it has not
`been shown to qualify as prior art.
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`FRE 901 (Authentication): This exhibit
`is inadmissible for lack of proper
`authentication. Patent Owner has not
`presented evidence sufficient to support a
`finding that the exhibit is what it is
`purported to be.
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`2
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`
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`Proceeding No.: IPR2022-01249
`Attorney Docket: 39843-0126IP1
`FRE 801-802 (Hearsay): This exhibit
`contains inadmissible hearsay cited for the
`truth of the statements contained therein.
`Patent Owner has identified no applicable
`hearsay exception for the statements in the
`exhibit.
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`FRE 401/402/403 (Relevancy): This
`exhibit is inadmissible as irrelevant
`because, among other things, it has not
`been shown to qualify as prior art.
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`FRE 901 (Authentication): This exhibit
`is inadmissible for lack of proper
`authentication. Patent Owner has not
`presented evidence sufficient to support a
`finding that the exhibit is what it is
`purported to be.
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`FRE 801-802 (Hearsay): This exhibit
`contains inadmissible hearsay cited for the
`truth of the statements contained therein.
`Patent Owner has identified no applicable
`hearsay exception for the statements in the
`exhibit.
`
`FRE 401/402/403 (Relevancy): This
`exhibit is inadmissible as irrelevant
`because, among other things, it has not
`been shown to qualify as prior art.
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`FRE 901 (Authentication): This exhibit
`is inadmissible for lack of proper
`authentication. Patent Owner has not
`presented evidence sufficient to support a
`finding that the exhibit is what it is
`purported to be.
`
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`3
`
`EX-2009
`FOCUS LCDs, Serial Vs. Parallel,
`LCD RESOURCES,
`https://focuslcds.com/serial-vs-
`parallel/ (last visited Oct. 19, 2022)
`
`
`EX-2010
`Techopedia, Serial Interface,
`WWW.TECHOPEDIA.COM, Nov. 4,
`2014,
`https://www.techopedia.com/definit
`ion/9312/serial-interface
`
`
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`Proceeding No.: IPR2022-01249
`Attorney Docket: 39843-0126IP1
`FRE 801-802 (Hearsay): This exhibit
`contains inadmissible hearsay cited for the
`truth of the statements contained therein.
`Patent Owner has identified no applicable
`hearsay exception for the statements in the
`exhibit.
`
`FRE 401/402/403 (Relevancy): This
`exhibit is inadmissible as irrelevant
`because, among other things, it has not
`been shown to qualify as prior art.
`
`FRE 901 (Authentication): This exhibit
`is inadmissible for lack of proper
`authentication. Patent Owner has not
`presented evidence sufficient to support a
`finding that the exhibit is what it is
`purported to be.
`
`FRE 801-802 (Hearsay): This exhibit
`contains inadmissible hearsay cited for the
`truth of the statements contained therein.
`Patent Owner has identified no applicable
`hearsay exception for the statements in the
`exhibit.
`
`FRE 401/402/403 (Relevancy): This
`exhibit is inadmissible as irrelevant
`because, among other things, it has not
`been shown to qualify as prior art.
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`FRE 106/1001: This exhibit is incomplete
`and is not a copy which accurately
`reproduces the original.
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`FRE 901 (Authentication): This exhibit
`is inadmissible for lack of proper
`authentication. Patent Owner has not
`presented evidence sufficient to support a
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`4
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`EX-2011
`Excerpts from The Authoritative
`Dictionary of IEEE Standards
`Terms, Seventh Edition (2000)
`
`EX-2012
`Jonathan Valvano et al., Chapter
`11: Serial Interfacing, EMBEDDED
`SYSTEMS – SHAPE THE WORLD,
`
`
`
`https://users.ece.utexas.edu/~valvan
`o/Volume1/E-
`Book/C11_SerialInterface.htm (last
`visited Oct. 20, 2022)
`
`
`EX-2013
`Steve Goldband, Input and output
`for microprocessors, Behavior
`Research Methods &
`Instrumentation, 1978, Vol. 10, No.
`2, pp. 249-253
`
`
`Proceeding No.: IPR2022-01249
`Attorney Docket: 39843-0126IP1
`finding that the exhibit is what it is
`purported to be.
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`FRE 801-802 (Hearsay): This exhibit
`contains inadmissible hearsay cited for the
`truth of the statements contained therein.
`Patent Owner has identified no applicable
`hearsay exception for the statements in the
`exhibit.
`
`FRE 401/402/403 (Relevancy): This
`exhibit is inadmissible as irrelevant
`because, among other things, it has not
`been shown to qualify as prior art.
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`FRE 901 (Authentication): This exhibit
`is inadmissible for lack of proper
`authentication. Patent Owner has not
`presented evidence sufficient to support a
`finding that the exhibit is what it is
`purported to be.
`
`FRE 801-802 (Hearsay): This exhibit
`contains inadmissible hearsay cited for the
`truth of the statements contained therein.
`Patent Owner has identified no applicable
`hearsay exception for the statements in the
`exhibit.
`
`FRE 401/402/403 (Relevancy): This
`exhibit is inadmissible as irrelevant
`because, among other things, it has not
`been shown to qualify as prior art.
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`These objections have been timely filed and are being concurrently served on
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`the Patent Owner.
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`5
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`Dated February 7, 2023
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`Proceeding No.: IPR2022-01249
`Attorney Docket: 39843-0126IP1
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`Respectfully submitted,
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`
`
`/Jeremy J. Monaldo/
`Jeremy J. Monaldo, Reg. No. 58,680
`Attorney for Petitioner
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`6
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`Proceeding No.: IPR2022-01249
`Attorney Docket: 39843-0126IP1
`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e), the undersigned certifies that on February 7,
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`2023, a complete and entire copy of this Petitioner’s Objections to Evidence
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`Submitted with Patent Owner’s Preliminary Response was provided by email, to
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`the Patent Owner, by serving the correspondence addresses of record as follows:
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`Rex Hwang
`Todd Martin
`SKIERMONT DERBY LLP
`633 West 5th Street, Suite 5800
`Los Angeles, CA 90071
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`Philip J. Graves
`Greer N. Shaw
`GRAVES & SHAW LLP
`355 S. Grand Ave., Suite 2450
`Los Angeles, CA 90071
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`Email: rhwang@skiermontderby.com
`tmartin@skiermontderby.com
`pgraves@gravesshaw.com
`gshaw@gravesshaw.com
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`/Diana Bradley/
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`Diana Bradley
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(858) 678-5667
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`7
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