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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
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`v.
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`SECURUS TECHNOLOGIES, INC.
`Patent Owner
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`Case IPR2016-01220
`Patent 9,007,420
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`PETITIONER’S OBJECTIONS TO
`PATENT OWNER’S DEMONSTRATIVE SLIDES
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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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`IPR2016-01220
`U.S. Patent No. 9,007,420
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`Pursuant to the Order dated July 26, 2017 (Paper 25), Petitioner Global
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`Tel*Link Corporation (“GTL”) hereby objects to certain demonstrative slides of
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`Patent Owner Securus Technologies, Inc. (“Securus”).
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`GTL objects to the following Securus demonstrative slides as improperly
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`advancing new and/or altered evidence and arguments that go beyond serving as
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`visual aids. GTL objects to:
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`• Slides 11-12, 17, 22, 27, 38, 39, 47, and 49 because the positions
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`Securus takes in these slides are not in the written record and
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`represent an improper, unauthorized surreply; and
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`• Slides 23, 36, and 46 because these slides present new images not in
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`evidence or the written record.
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`More specifically, GTL’s objections are as follows:
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`New arguments amounting to an improper and unauthorized surreply
`I.
`Demonstrative Slides 11-12
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`GTL objects to demonstrative slides 11, because Securus advances a new
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`argument in the left hand box that does not appear in the written record, presenting
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`new arguments and amounting to an improper and unauthorized surreply.
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`- 1 -
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`Demonstrative Slide 17
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`IPR2016-01220
`U.S. Patent No. 9,007,420
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`GTL objects to demonstrative slide 17, because Securus cites new case law
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`(Modine and Canton Bio Med.) that does not appear in the written record,
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`presenting new case law not cited or relied upon in the Petition, Institution
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`Decision, Patent Owner Response, or Petitioner’s Reply, and amounting to an
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`improper and unauthorized surreply.
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`Demonstrative Slides 22, 38-39, and 49
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`GTL objects to demonstratives slides 22, 38-39, and 49, because Securus
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`advances new arguments in the top and bottom boxes with blue text that do not
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`appear in the written record, presenting new arguments, and amounting to an
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`improper and unauthorized surreply.
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`Demonstrative Slide 27
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`GTL objects to demonstrative slide 27, because Securus advances a new
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`argument that does not appear in the written record, attempting to add attorney
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`argument related to Dr. Kakadiaris’ testimony, and amounting to an improper and
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`unauthorized surreply.
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`- 2 -
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`Demonstrative Slide 47
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`IPR2016-01220
`U.S. Patent No. 9,007,420
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`GTL objects to demonstrative slide 47, because Securus advances a new
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`argument in the red and blue text that does not appear in the written record,
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`presenting new arguments to characterize GTL’s position, and amounting to an
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`improper and unauthorized surreply.
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`II. New images not found in the written record
`Demonstrative Slide 23
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`GTL objects to demonstrative slide 23, because Securus introduces new
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`images not present anywhere in the record, failing to cite the Patent Owner
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`Response or any other paper where the images were present.
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`Demonstrative Slide 36
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`GTL objects to demonstrative slide 36, because Securus introduces a new
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`image that is not present anywhere in the record, failing to cite the Patent Owner
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`Response or any other paper where the image was present.
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`Demonstrative Slide 46
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`GTL objects to demonstrative slide 46, because Securus introduces a new
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`image that is not present anywhere in the record, failing to cite the Patent Owner
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`- 3 -
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`Response or any other paper where the image was present.
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`IPR2016-01220
`U.S. Patent No. 9,007,420
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`These objections are made at least three business before the August 9, 2017
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`oral hearing.
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`Respectfully submitted,
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`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
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`/Joseph E. Mutschelknaus/
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`Michael D. Specht, Reg. No. 54,463
`Joseph E. Mutschelknaus, Reg. No. 63,285
`Attorneys for Petitioner
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`Date: August 4, 2017
`1100 New York Avenue, N.W.
`Washington, D.C. 20005
`(202) 371-2600
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`- 4 -
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`IPR2016-01220
`U.S. Patent No. 9,007,420
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`CERTIFICATION OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the
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`foregoing PETITIONER’S OBJECTIONS TO PATENT OWNER’S
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`DEMONSTRATIVE SLIDES was served electronically via e-mail on August 4,
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`2017 in its entirety on the following counsel of record for Patent Owner:
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`Nicholas C. Kliewer (Lead Counsel)
`Jeffrey R. Bragalone (Back-up Counsel)
`Daniel F. Olejko (Back-up Counsel)
`Terry A. Saad (Back-up Counsel)
`Justin B. Kimble (Back-up Counsel)
`BRAGALONE CONROY PC
`JKimble-IPR@bcpc-law.com
`jbragalone@bcpc-law.com
`dolejko@bcpc-law.com
`tsaad@bcpc-law.com
`nkliewer@bcpc-law.com
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`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
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`/Joseph E. Mutschelknaus/
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`Joseph E. Mutschelknaus
`Attorney for Petitioner
`Registration No. 63,285
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`Date: August 4, 2017
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
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