`
`Filed on behalf of: Meta Platforms, Inc.
`
`
`
`
`
`Filed: August 31, 2023
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`META PLATFORMS, INC.
`Petitioner,
`
`v.
`
`ANGEL TECHNOLOGIES GROUP LLC,
`Patent Owner.
`__________________
`Case No. IPR2023-00058
`U.S. Patent No. 9,959,291
`__________________
`
`PETITIONER’S OBJECTIONS TO PATENT OWNER’S EVIDENCE
`
`
`
`
`
`
`
`
`
`IPR2023-00058 (USP 9,959,291)
`
`
` Petitioner’s Objections to Evidence
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner Meta Platforms, Inc.
`
`(“Petitioner”) submits the following objections to evidence submitted by Patent
`
`Owner Angel Technologies Group LLC (“Patent Owner”). Petitioner’s objections
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`apply equally to Patent Owner’s reliance on this evidence in any subsequently filed
`
`documents or further proceedings in this matter. These objections are timely, having
`
`been filed and served within five business days of service. Notwithstanding these
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`objections, Petitioner expressly reserves the right to rely on any evidence submitted
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`by Patent Owner, including on the ground that such evidence constitutes a party
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`admission.
`
`Objections
`
`Exhibit 2021
`Petitioner objects to this exhibit as inadmissible hearsay under FRE 801 and
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`802 not falling under any exception, and as improper expert testimony under
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`FRE 702 and 703, to the extent it impermissibly acts as a conduit for hearsay,
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`including the hearsay objected to herein, and does not rely on the kinds of facts or
`
`data that experts in the relevant field would reasonably rely on in forming an opinion
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`on the subject without providing the underlying facts, data, and other required
`
`disclosures.
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`Petitioner further objects to this exhibit for lack of foundation and lack of
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`personal knowledge under FRE 602, and as improper lay testimony under FRE 701,
`
`
`
`1
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`
`
`IPR2023-00058 (USP 9,959,291)
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`to the extent it offers testimony in areas outside of Dr. Saber’s area of expertise or
`
` Petitioner’s Objections to Evidence
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`fails to properly provide the underlying facts, data, and other required disclosures.
`
`
`
`Dated: August 31, 2023
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`
`
`Respectfully submitted,
`
`
`
`
`By: /Lisa K. Nguyen/
`Lisa K. Nguyen (Reg. No. 58,018)
`lisa.nguyen@allenovery.com
`Allen & Overy LLP
`550 High Street
`Palo Alto, CA 94301
`Telephone: (650) 388-1724
`
`Counsel for Petitioner
` Meta Platforms, Inc.
`
`
`
`2
`
`
`
`IPR2023-00058 (USP 9,959,291)
`
`
` Petitioner’s Objections to Evidence
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a true and correct copy of Petitioner’s
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`Objections to Patent Owner’s Evidence was served via electronic email on Patent
`
`Owner’s counsel of record listed below, pursuant to its Mandatory Notices, on
`
`August 31, 2023:
`
`Scott W. Hejny
`Reg. No. 45,882
`McKool Smith, P.C.
`300 Crescent Court, Suite 1500
`Dallas, TX 75201
`Telephone: (214) 978-4000
`Facsimile: (214) 978-4044
`shejny@mckoolsmith.com
`
`
`Eliza Beeney
`(pro hac vice)
`McKool Smith, P.C.
`One Manhattan West
`395 9th Avenue, 50th Floor
`New York, NY 10001
`Telephone: (212) 402-9818
`ebeeney@mckoolsmith.com
`
`
`
`
`
`Elizabeth Bernard
`Reg. No. 51,465
`Arvind Jairam
`Reg. No. 62,759
`McKool Smith, P.C.
`1999 K St. NW, Suite 600
`Washington, DC 20006
`Telephone: (202) 370-8300
`EBernard@mckoolsmith.com
`ajairam@mckoolsmith.com
`
`Kaylee Hoffner
`(pro hac vice)
`McKool Smith, P.C.
`600 Travis Street, Suite 7000
`Houston, TX 77002
`Telephone: (713) 485-7320
`khoffner@mckoolsmith.com
`
`
`By: /Lisa K. Nguyen/
`Lisa K. Nguyen (Reg. No. 58,018)
`lisa.nguyen@allenovery.com
`Allen & Overy LLP
`550 High Street
`Palo Alto, CA 94301
`Telephone: (650) 388-1724
`
`Counsel for Petitioner
`Meta Platforms, Inc.
`
`
`
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