`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., and APPLE INC.,
`Petitioner
`
`v.
`
`SMART MOBILE TECHNOLOGIES LLC,
`Patent Owner
`____________
`
`Case IPR2022-01249
`Patent 9,019,946 B1
`____________
`PATENT OWNER’S OBJECTIONS TO PETITIONER’S
`DEMONSTRATIVE EXHBITS
`
`
`
`
`
`
`
`
`
`Patent Owner hereby submits its objections to Petitioner’s demonstrative
`
`exhibits.
`
`Slide 80:
`
`The statement boxed in red is a portion of Petitioner’s expert declaration
`
`(Exhibit 1051, [60]) which was improperly incorporated by reference into
`
`Petitioner’s Reply (at 23), and for the first time maps the claims’ “multiplexed”
`
`signals to the functionality of “application server 710” on Bernard’s PDA, in
`
`contrast to the Petition (at 32-39) and the Reply (at 22-25) which expressly mapped
`
`that functionality to the “communication server 750” on Bernard’s cradle.
`
`
`
`- 1 -
`
`
`
`
`
`Slides 86 and 95:
`
`The statement boxed in red is Petitioner’s expert declaration (Exhibit 1051,
`
`[74]) providing approximately 100 words of numerical analysis based on Exhibit
`
`1059, both of which are incorporated by reference in Petitioner’s Reply and not
`
`discussed there in any meaningful way, if at all. See Sur-Reply, 30.
`
`
`
`- 2 -
`
`
`
`Dr. Jensen
`
`17:51-59, Figure 10; EX-1035, 47:15-21. Indeed.
`
`EX-1051 (2"4 Jensen Decl.), [73]
`
`74.
`
`For example, RS-485 is a serial standardreleased before 1999. EX-
`
`1058. 1. This standard accommodates data rates of up to
`
`id. IEEE
`
`802.11 WLAN(1997) supported up to 2
`
`e
`
`and 802.11b WLAN (1999)
`
`supported up to 11 Mbit/second, althoughthe rate that an application would see
`
`was lower, as some ofthis bandwidth was usedfor the radio networking packet
`headers. EX-1059, 1, 3. GPRS, a cellular standard for data over the GSMnetwork,
`accommodateddata rates of
`56-
`
`
`
`Sufficient Motivation Exists For Combining Yegoshin
`and Bernard
` Petitioner's Reply, 29-30
`
`
`EX-1060, 1
`FISH.
`
`EX-1051 (2"4 Jensen Decl.), [74]
`
`96
`
`
`
`- 3 -
`
`
`
`Dated: October 24, 2023
`
`
`
`
`
`
`
`Respectfully Submitted,
`
`/Philip J. Graves/
`Philip J. Graves (Pro Hac Vice)
`Greer N. Shaw (Pro Hac Vice)
`GRAVES & SHAW LLP
`355 S. Grand Ave., Suite 2450
`Los Angeles, CA 90071
`Tel: (213) 214-5101
`Back-Up Counsel for Patent Owner
`
`Rex Hwang (Reg. No. 56,206)
`SKIERMONT DERBY LLP
`633 West 5th Street, Suite 5800
`Los Angeles, CA 90071
`P: 213-788-4500/F: 213-788-4545
`Lead Counsel for Patent Owner
`
`Todd Martin (Reg. No. 78,642)
`SKIERMONT DERBY LLP
`1601 Elm Street, Suite 4400
`Dallas, TX 75201
`P: 214-978-6600/F: 214-978-6621
`Back-Up Counsel for Patent Owner
`
`
`- 4 -
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), I certify that I caused to be served on the
`
`counsel for Petitioner a true and correct copy of the foregoing Patent Owner’s
`
`Objections to Petitioner’s Demonstrative Exhibits, by electronic means on October
`
`24, 2023, by delivering a copy via electronic mail to the attorneys of record for the
`
`Petitioner as follows:
`
`W. Karl Renner
`IPR39843-0126IP1@fr.com
`Jeremy J. Monaldo
`jjm@fr.com
`Hyun Jin In
`in@fr.com
`Sangki Park
`spark@fr.com
`Aamir A. Kazi
`kazi@fr.com
`Christopher O. Green
`cgreen@fr.com
`PTABInbound@fr.com
`axf-ptab@fr.com
`
`Andrew S. Ehmke
`andy.ehmke.ipr@haynesboone.com
`Clint S. Wilkins
`clint.wilkins.ipr@haynesboone.com
`
`
`Dated: October 24, 2023
`
`
`
`Respectfully Submitted,
`
`/Philip J. Graves/
`Philip J. Graves (Pro Hac Vice)
`Counsel for Patent Owner
`
`
`
`
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
