`By:
`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
`
`Daniel F. Olejko (dolejko@bcpc-law.com)
`
`Nicholas C Kliewer (nkliewer@bcpc-law.com)
`
`Bragalone Conroy PC
`
`2200 Ross Ave.
`
`Suite 4500 – West
`
`Dallas, TX 75201
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`Tel: 214.785.6670
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`Fax: 214.786.6680
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GLOBAL TEL*LINK CORPORATION,
`Petitioner,
`
`v.
`
`SECURUS TECHNOLOGIES, INC.,
`Patent Owner.
`
`
`Case IPR2016-01220
`U.S. Patent No. 9,007,420
`
`
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`PATENT OWNER’S OBJECTIONS TO EVIDENCE
`UNDER 37 C.F.R. § 42.64(B)(1)
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
`
`
`Case IPR2016-01220
`Patent 9,007,420
`Patent Owner Securus Technologies, Inc. (“Securus”) hereby files the
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`following objections to evidence under the Federal Rules of Evidence (“FRE”) and
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`37 C.F.R. § 42.62(b)(1) to the admissibility of the following evidence submitted by
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`Global Tel*Link Corporation (“Petitioner”) in support of its Petitioner’s Reply
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`(Paper 19).
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`Securus objects to and may seek the exclusion of the following documents:
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`Exhibit No. Description
`1021
`Toderici et al., “Bidirectional relighting for 3D-aided 2D Face
`Recognition,” Proceedings from IEEE Computer Vision and
`Pattern Recognition, 13-18 June 2010, San Francisco, CA
`(“Toderici ”)
`
`
`Exhibit 1021 – Toderici
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`Patent Owner objects to Toderici under 35 U.S.C. § 311(b) because it does
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`not appear to be admissible as prior art under 35 U.S.C. § 102 or 103. For example,
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`there is no admissible evidence demonstrating that Toderici was actually published
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`or publicly accessible before the priority date of the challenged patent claims.
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`Patent Owner objects to Toderici as not properly authenticated under Federal
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`Rule of Evidence 901. There is no evidence that Toderici is authentic nor that the
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`document is self-authenticating under Federal Rule of Evidence 902.
`
`Patent Owner objects to Toderici under Federal Rules of Evidence 401-403
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`because its probative value is substantially outweighed by the danger of unfair
`
`prejudice, confusing the issues, unduly delay, wasting time, or needlessly
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`1
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`
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`Case IPR2016-01220
`Patent 9,007,420
`presenting cumulative evidence. For example, Toderici is not prior art and it is
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`highlighted in a confusing manner.
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`Patent Owner objects to Toderici as inadmissible hearsay under Federal
`
`Rules of Evidence 801 and 802 that does not fall under any hearsay exception,
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`including those of Federal Rules of Evidence 803, 804, 805, or 807.
`
`Patent Owner objects to Toderici as not being an original document under
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`Federal Rule of Evidence 1002, an authentic duplicate under Federal Rule of
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`Evidence 1003, nor a document that falls under any exceptions to the original-
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`document requirement, including those of Federal Rule of Evidence 1004.
`
`Patent Owner objects to Toderici because it does not comply with the
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`marking requirements under 37 CFR § 42.63(d)(2)(i).
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`
`
`Date: June 29, 2017
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`Respectfully submitted,
`
`
`/Nicholas Kliewer/
`
`Nicholas C Kliewer
`Attorney for Patent Owner
`Registration No. 72,480
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`
`2
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`
`
`Case IPR2016-01220
`Patent 9,007,420
`
`CERTIFICATE OF SERVICE
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`
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`The undersigned hereby certifies that document was served via electronic mail
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`on June 29, 2017, to Petitioner via counsel, mspecht-PTAB@skgf.com, jmutsche-
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`PTAB@skgf.com, and PTAB@skgf.com, pursuant to Petitioner’s consent in its
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`Petition at page 60.
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`/Nicholas Kliewer/
`
`Nicholas C Kliewer
`Attorney for Patent Owner
`Registration No. 72,480
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`
`3
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`
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