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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`Apple Inc., Google Inc. and Motorola Mobility LLC,
`
`Petitioners,
`
`v.
`
`Arendi S.A.R.L.,
`
`Patent Owner.
`
`____________
`
`Case No. IPR2014-00208
`
`Patent No. 7,917,843
`
`____________
`
`PATENT OWNER ARENDI S.A.R.L.’S OBJECTIONS TO EVIDENCE
`
`PURSUANT TO 37 C.F.R. § 42.64
`
`
`
`
`
`
`
`1
`
`

`
`Pursuant to 37 C.F.R. §42.64(b)(1), the undersigned, on behalf of Patent
`
`Owner Arendi S.A.R.L. (“Arendi” or “Patent Owner”) hereby submits the
`
`following objections to Exhibit 1013.
`
`Exhibit 1013 is the Deposition of Daniel A. Menascé. He is petitioners’
`
`expert declarant. Petitioners’ Reply makes absolutely no mention of and no
`
`reference to any testimony in Exhibit 1013. Patent Owner objects to the deposition
`
`on the grounds that it is not relevant to this IPR trial. To the extent, Menascé’s
`
`testimony constitutes supplemental information, it could have been submitted in a
`
`timely manner in the form of a declaration within one month of the date this trial
`
`was instituted. Petitioners did not file a motion to submit supplemental
`
`information. Moreover, in the absence of mention of the deposition in the Reply, it
`
`is confirmed that any information in the transcript is of little or no relevance and
`
`necessarily fails to meet the interests-of-justice standard for late submission.
`
`These objections are being timely served within 5 business days of service
`
`of the Petitioners Reply and its associated exhibit.
`
`2
`
`
`
`

`
`Date: November 18, 2014 Respectfully submitted,
`
` /Robert M. Asher, #30,445 /
`
`
`
`
`
` Robert M. Asher
`Registration No. 30,445
`Bruce D. Sunstein
`Registration No. 27,234
`Dorothy Wu
`Registration No. 69,535
`Sunstein Kann Murphy & Timbers LLP
`125 Summer Street
`Boston, MA 02110
`Tel: (617) 443-9292
`Fax: (617) 443-0004
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`3
`
`

`
`CERTIFICATE OF SERVICE
`
` It is certified that on November 18, 2014, copies of the PATENT OWNER
`
`ARENDI S.A.R.L.’s OBJECTIONS TO EVIDENCE PURSUANT TO 37 C.F.R. §
`
`42.64 have been served on Petitioners as provided in 37 C.F.R. § 42.6(e) via
`
`electronic mail transmission addressed to the persons at the following addresses:
`
`LEAD COUNSEL FOR PETITIONER
`APPLE INC.
`
`DAVID L. FEHRMAN
`dfehrman@mofo.com
`Registration No. 28,600
`MORRISON & FOERSTER LLP
`707 Wilshire Blvd., Suite 6000
`Los Angeles, CA 90017-3543
`Tel: (213) 892-5601
`Fax: (213) 892-5454
`
`LEAD COUNSEL FOR
`PETITIONERS MOTOROLA
`MOBILITY, LLC and GOOGLE INC.
`
`MATTHEW A. SMITH
`smith@turnerboyd.com
`Registration No. 49,003
`TURNER BOYD LLP
`2570 W. El Camino Real, Suite 380
`Mountain View, CA 94040
`Tel: (650) 265-6109
`Fax: (650) 521-5931
`
`
`BACK-UP COUNSEL FOR
`PETITIONER APPLE INC.
`
`MEHRAN ARJOMAND
`marjomand@mofo.com
`Registration No. 48,231
`MORRISON & FOERSTER LLP
`707 Wilshire Blvd., Suite 6000
`Los Angeles, CA 90017-3543
`Tel: (213) 892-5630
`Fax: (213) 892-5454
`
`BACK-UP COUNSEL FOR
`PETITIONERS MOTOROLA
`MOBILITY, LLC and GOOGLE INC.
`
`ZHUANJIA GU
`gu@turnerboyd.com
`Registration No. 51,758
`TURNER BOYD LLP
`2570 W. El Camino Real, Suite 380
`Mountain View, CA 94040
`Tel: (650) 265-6109
`Fax: (650) 521-5931
`
`JULIE S. TURNER
`turner@turnerboyd.com
`TURNER BOYD LLP
`2570 W. El Camino Real, Suite 380
`Mountain View, CA 94040
`Tel: (650) 265-6109
`Fax: (650) 521-5931
`and
`kent@turnerboyd.com
`docketing@turnerboyd.com
`
`
`
`4
`
`

`
`
`
`Date: November 18, 2014 /Robert M. Asher, #30,445 /
`
`
`
`
`
`
`
`
`
`
`
`
`
` Robert M. Asher
`Registration No. 30,445
`Sunstein Kann Murphy & Timbers LLP
`125 Summer Street
`Boston, MA 02110
`Tel: (617) 443-9292
`Fax: (617) 443-0004
`
`5

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