`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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`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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`Patent Owner in their Patent Owner’s Response filed May 26, 2023. Specifically,
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`Petitioner objects to the following exhibits submitted by Patent Owner for the bases
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`noted below:
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`Exhibit
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`EX-2023
`Additional Excerpts from The
`Authoritative Dictionary of IEEE
`Standards Terms, Seventh Edition
`(2000) [IEEE-Dictionary]
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`EX-2024
`Benj Edwards, The Golden Age of
`PDAs, PC Magazine, Nov. 20,
`2018,
`https://www.pcmag.com/news/the-
`golden-age-of-pdas [PCMagazine]
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`Objections
`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 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 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 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 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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`1
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`EX-2025
`Jeremy Reimer, Remembering
`Apple’s Newton, 30 Years On, Ars
`Technica, June 1, 2022,
`https://arstechnica.com/gadgets/202
`2/06/remembering-applesnewton-
`30-years-on/ [Ars-Technica]
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`EX-2027
`Excerpts from Newton’s Telecom
`Dictionary, 16th Edition (2000)
`[Newton’s-Telecom-Dictionary]
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`Proceeding No.: IPR2022-01249
`Attorney Docket: 39843-0126IP1
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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 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 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 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 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 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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`2
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`EX-2031
`Microsoft Computer Dictionary
`[Microsoft Computer Dictionary]
`(3rd ed. 1997)
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`EX-2032
`Newton’s Telecom Dictionary
`[Newton’s Telecom Dictionary]
`(12th ed. 1997)
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`Proceeding No.: IPR2022-01249
`Attorney Docket: 39843-0126IP1
`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 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 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 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 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 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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`3
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`EX-2033
`Todor Cooklev, et al., Modern
`Communication Systems, Ch. 2-7.
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`Proceeding No.: IPR2022-01249
`Attorney Docket: 39843-0126IP1
`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 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 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 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 106/1001: This exhibit is incomplete
`and is not a copy which accurately
`reproduces the original.
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`4
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`Proceeding No.: IPR2022-01249
`Attorney Docket: 39843-0126IP1
`These objections have been timely filed and are being concurrently served on
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`the Patent Owner.
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`Dated June 5, 2023
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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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`5
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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 June 5,
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`2023, a complete and entire copy of this Petitioner’s Objections to Evidence was
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`provided by email, to the Patent Owner, by serving the correspondence addresses
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`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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`6
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