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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`REACTIVE SURFACES LTD. LLP,
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`Petitioner,
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`v.
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`TOYOTA MOTOR CORPORATION,
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`Patent Owner.
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`Case IPR2016-01914
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`Patent No. 8,394,618 B2
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`PATENT OWNERS’ OBJECTIONS TO EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64
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`IPR2016-01914
`U.S. Patent No. 8,394,618 B2
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`Pursuant to 37 C.F.R. § 42.64, Patent Owners Toyota Motor Corporation
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`and Regents of the University of Minnesota object to the admissibility of Exhibit
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`1010 (“Declaration of Dr. David Rozzell, Ph.D.”) submitted by Petitioner Reactive
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`Surfaces Ltd. LLP in the preliminary proceeding. Exhibit 1010 is objected to
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`under F.R.E. 702 (improper expert testimony) and Daubert v. Merrell Dow
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`Pharmaceuticals, Inc., 509 U.S. 579 (1993). Dr. Rozzell does not possess the
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`requisite credentials or expertise to render opinions in this IPR. Exhibit 1010 is
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`further objected to under F.R.E. 702 as the testimony is not based on sufficient
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`facts or data, is not the product of reliable principles and methods, and the
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`principles and methods have not been reliably applied to the facts of the case.
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`Exhibit 1010 is further objected to under F.R.E. 703 as the testimony is based on
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`facts or data that an expert in this field would not reasonably rely on. Exhibit 1010
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`is further objected to under 37 C.F.R. § 42.65(a) for failing to identify with
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`particularity the underlying facts and data on which the opinion is based.
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`These objections have been timely made within ten business days from the
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`institution of trial.
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`Dated: March 6, 2017
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`Respectfully submitted,
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` /s/ Joshua A. Lorentz
`Joshua A. Lorentz
`Reg. No. 52,406
`Dinsmore & Shohl LLP
`255 E. Fifth St.
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`1
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`IPR2016-01914
`U.S. Patent No. 8,394,618 B2
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`Cincinnati, OH 45202
`T: (513) 977-8200
`Attorney for Patent Owners
`Toyota Motor Corporation and
`Regents of the University of
`Minnesota
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`2
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`IPR2016-01914
`U.S. Patent No. 8,394,618 B2
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`CERTIFICATE OF SERVICE
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`I hereby certify that a true and correct copy of the foregoing PATENT
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`OWNERS’ OBJECTIONS TO EVIDENCE PURSUANT TO 37 C.F.R. § 42.64
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`was served on March 6, 2017 by email on the following counsel of record for
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`Petitioner:
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`David O. Simmons (dsimmons@ivcpatentagency.com)
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`Jonathan D. Hurt (jhurt@technologylitigators.com)
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`Mark A.J. Fassold (mfassold@wattsguerra.com)
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`Jorge Mares (jmares@wattsguerra.com)
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`Dated: March 6, 2017
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`Respectfully submitted,
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` /s/ Joshua A. Lorentz
`Joshua A. Lorentz
`Reg. No. 52,406
`Attorney for Patent Owners
`Toyota Motor Corporation and
`Regents of the University of
`Minnesota
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