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`BEFORE THE PATENT TRIAL AND APPEALS BOARD
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`NFL ENTERPRISES LLC,
`Petitioner
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`v.
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`OPENTV, INC.
`Patent Owner
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`Case No.: IPR2017-02092
`Patent No. 6,233,736
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`PATENT OWNER’S OBJECTIONS TO EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64(b)(1)
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`Pursuant to 37 C.F.R. § 42.64(b)(1), OpenTV hereby submits the following
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`objections to NFL Exhibit 1006.
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`Exhibit 1006
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`OpenTV objects to Exhibit 1006 under Rules 403 and 702 of the Federal
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`Rules of Evidence and 37 C.F.R. § 42.65. Mr. Bradner’s opinions are conclusory,
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`lack sufficient explanation, are not based on sufficient facts or data, and are not the
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`product of reliable principles and methods reliably applied to the facts of the case,
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`at least because Mr. Bradner opines on claim construction but fails to apply or
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`consider relevant law on claim construction, see, e.g., Ex. 1006 at ¶¶ 14-17, 93-
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`104, and because Mr. Bradner lacks the relevant technical experience necessary to
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`opine on claim construction or patentability. Accordingly, Ex. 1006 is an improper
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`declaration and is more prejudicial than it is of probative value.
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`Dated: April 2, 2018
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`Respectfully submitted,
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`By: /Cory C. Bell /
`Cory C. Bell,
`Registration No. 75,096
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a copy of the foregoing PATENT
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`OWNER’S OBJECTIONS TO EVIDENCE PURSUANT TO 37 C.F.R. §
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`42.64(b)(1) was served on April 2, 2018 via email directed to counsel of record for
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`the Petitioner at the following:
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`By: /Lauren K. Young/
`Lauren K. Young
`Litigation Legal Assistant
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, L.L.P.
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`Stephen C. Stout, Lead Counsel
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`sstout@velaw.com
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`NFLE-IPR@velaw.com
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`Hilary L. Preston, Back-up Counsel
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`Rachel P. McClure, Back-up Counsel
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`hpreston@velaw.com
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`rmcclure@velaw.com
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`Petitioner consents to electronic service.
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`Dated: April 2, 2018
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`2
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