`By: Nicholas C. Kliewer (nkliewer@bcpc-law.com)
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`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
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`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`Tel: 214.785.6670
`Fax: 214.786.6680
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`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 PETITIONER’S DEMONSTRATIVES
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Case IPR2016-01220
`Patent 9,007,420
`Pursuant to the Board’s Order of July 26, 2017, Patent Owner Securus
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`Technologies, Inc. (“Patent Owner” or “Securus”) files these objections to
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`Petitioner’s oral argument demonstratives previously served on Patent Owner.
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`Objection No. 1 (to Petitioner’s Demonstrative Slide 2)
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`Patent Owner objects to Slide 2 on the basis that it is prejudicial and
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`misleading in mischaracterizing the Petition and includes factually inaccurate
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`representation of the term “electronic visitation session.” Specifically, Slide 2
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`includes argument regarding “electronic visitation” not discussed at Petition, 1, 14,
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`or referred to in Figs. 2, 7. Further, Petition and Reply do not rely on Figure 7 and
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`appears to represent new argument.
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`Objection No. 2 (to Petitioner’s Demonstrative Slide 3)
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`Patent Owner objects to Slide 3 on the basis that it is prejudicial and
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`misleading in mischaracterizing the Petition and includes new argument regarding
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`the Claim 1 and Figure 5. Specifically, Slide 3 includes a comparison between
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`Figure 5 and Claim 1 that is not part of the record.
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`Objection No. 3 (to Petitioner’s Demonstrative Slide 13)
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`Patent Owner objects to Slide 13 on the grounds that it includes new
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`citations and argument not represented in the Petition or Petitioner’s Reply
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`regarding the plain meaning of “actual geometry of the face” and “actual face.”
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`
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`Case IPR2016-01220
`Patent 9,007,420
`Objection No. 4 (to Petitioner’s Demonstrative Slide 23)
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`Patent Owner objects to Slide 23 on the basis that it is prejudicial and
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`misleading in mischaracterizing the Petition and includes new argument regarding
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`the “claimed request.”
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`Dated: August 4, 2017
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`Respectfully submitted,
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`Nicholas C. Kliewer
`Attorney for Patent Owner
`Registration No. 72,480
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`
`
`
`Case IPR2016-01220
`Patent 9,007,420
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`CERTIFICATE OF SERVICE
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`
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`The undersigned hereby certifies that this document has been served via
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`electronic mail on August 4, to Petitioner via counsel, Michael D. Specht, at
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`mspecht-PTAB@skgf.com and
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`Joseph E. Mutschelknaus, at
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`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 p. 60.
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`Nicholas C. Kliewer
`Attorney for Patent Owner
`Registration No. 72,480
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
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