`
`Filed on behalf of TQ Delta, LLC
`By: Peter J. McAndrews
`Andrew B. Karp
`McAndrews, Held & Malloy, Ltd.
`500 W. Madison St., 34th Floor
`Chicago, IL 60661
`Tel: 312-775-8000
`Fax: 312-775-8100
`E-mail: pmcandrews@mcandrews-ip.com
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`ERICSSON INC. AND TELEFONAKTIEBOLAGET LM ERICSSON
`Petitioners
`
`v.
`
`INTELLECTUAL VENTURES I LLC
`Patent Owner
`_____________
`
`Case IPR2018-00727
`Patent No. 6,628,629
`_____________
`
`PATENT OWNER’S OBJECTIONS TO EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64(b)(1)
`
`
`
`
`
`
`
`Patent Owner’s Objections to Evidence
`IPR2018-00727
`U.S. Patent No. 6,628,629
`
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner files the following
`
`objections to evidence that Petitioners submitted with its Petition for Inter Parties
`
`Review of U.S. Patent No. 6,628,629. A chart listing Patent Owner’s objections
`
`and its basis for the objections is provided below.
`
`Exhibit
`Ex. 1003 (Declaration
`of Zygmunt Haas), ¶¶
`38–49, 91, 136, and all
`other uncited portions
`
`Ex. 1009
`(PRMA/DA: A New
`Media Access Control
`Protocol for Wireless
`ATM)
`Ex. 1012 (Computer
`Dictionary &
`Handbook)
`
`Objection
`Relevance: These portions of Ex. 1003 are not relied on
`by the Petition, and therefore not relevant under FRE 402.
`See, e.g., 35 U.S.C. §§ 312(a)(3), (4); 37 C.F.R. §§
`42.104(b)(4), (5); 37 C.F.R. § 42.22(a)(2); 37 C.F.R. §
`42.6(a)(3); Cisco Sys., Inc. v. C-Cation Techs., LLC,
`IPR2014-00454, Paper 12 (Aug. 29, 2014) (informative).
`
`Confusion, Delay, and Waste of Time: To the extent that
`this exhibit has any other relevance to the Petition, that
`relevance was not raised by the Petition, and any
`argument for raising it now would result in confusion,
`delay, and wasted time. See FRE 403.
`Hearsay: The exhibit constitutes inadmissible hearsay,
`and no hearsay exception applies. See FRE 801-807.
`Additionally, Petitioner has provided no admissible
`evidence establishing the date of publication.
`
`Hearsay: The exhibit constitutes inadmissible hearsay,
`and no hearsay exception applies. See FRE 801-807.
`Additionally, Petitioner has provided no admissible
`evidence establishing the date of publication.
`
`Authenticity: The exhibit is not authenticated as required
`by FRE 901 and is not self-authenticating.
`
`2
`
`
`
`Patent Owner’s Objections to Evidence
`IPR2018-00727
`U.S. Patent No. 6,628,629
`
`
`Exhibit
`Ex. 1014 (Computer
`Networks)
`
`Ex. 1018 (SWAN: An
`Indoor Wireless ATM
`network)
`
`Ex. 1019 (Mobile
`Cellular
`Telecommunications:
`Analog and Digital
`Systems)
`
`Ex. 1020 (NEC
`Combines High-Speed
`IP Packet Processing
`with ATM
`Switching,)
`
`Objection
`Hearsay: The exhibit constitutes inadmissible hearsay,
`and no hearsay exception applies. See FRE 801-807.
`Additionally, Petitioner has provided no admissible
`evidence establishing the date of publication.
`
`Authenticity: The exhibit is not authenticated as required
`by FRE 901 and is not self-authenticating.
`Relevance: This exhibit is not relied on by the Petition,
`and therefore not relevant under FRE 402.
`
`Confusion, Delay, and Waste of Time: To the extent that
`this exhibit has any other relevance to the Petition, that
`relevance was not raised by the Petition, and any
`argument for raising it now would result in confusion,
`delay, and wasted time. See FRE 403.
`
`Hearsay: The exhibit constitutes inadmissible hearsay,
`and no hearsay exception applies. See FRE 801-807.
`Additionally, Petitioner has provided no admissible
`evidence establishing the date of publication.
`
`Authenticity: The exhibit is not authenticated as required
`by FRE 901 and is not self-authenticating.
`Hearsay: The exhibit constitutes inadmissible hearsay,
`and no hearsay exception applies. See FRE 801-807.
`Additionally, Petitioner has provided no admissible
`evidence establishing the date of publication.
`
`Authenticity: The exhibit is not authenticated as required
`by FRE 901 and is not self-authenticating.
`Hearsay: The exhibit constitutes inadmissible hearsay,
`and no hearsay exception applies. See FRE 801-807.
`Additionally, Petitioner has provided no admissible
`evidence establishing the date of publication.
`
`Authenticity: The exhibit is not authenticated as required
`by FRE 901 and is not self-authenticating.
`
`3
`
`
`
`Patent Owner’s Objections to Evidence
`IPR2018-00727
`U.S. Patent No. 6,628,629
`
`
`Objection
`Exhibit
`Ex. 1021 (RFC 2063) Relevance: This exhibit is not relied on by the Petition,
`and therefore not relevant under FRE 402.
`
`Confusion, Delay, and Waste of Time: To the extent that
`this exhibit has any other relevance to the Petition, that
`relevance was not raised by the Petition, and any
`argument for raising it now would result in confusion,
`delay, and wasted time. See FRE 403.
`
`Hearsay: The exhibit constitutes inadmissible hearsay,
`and no hearsay exception applies. See FRE 801-807.
`Additionally, Petitioner has provided no admissible
`evidence establishing the date of publication.
`
`Authenticity: The exhibit is not authenticated as required
`by FRE 901 and is not self-authenticating.
`Ex. 1022 (RFC 1483) Relevance: This exhibit is not relied on by the Petition,
`and therefore not relevant under FRE 402.
`
`Confusion, Delay, and Waste of Time: To the extent that
`this exhibit has any other relevance to the Petition, that
`relevance was not raised by the Petition, and any
`argument for raising it now would result in confusion,
`delay, and wasted time. See FRE 403.
`
`Hearsay: The exhibit constitutes inadmissible hearsay,
`and no hearsay exception applies. See FRE 801-807.
`Additionally, Petitioner has provided no admissible
`evidence establishing the date of publication.
`
`Authenticity: The exhibit is not authenticated as required
`by FRE 901 and is not self-authenticating.
`
`
`
`
`
`
`4
`
`
`
`Patent Owner’s Objections to Evidence
`IPR2018-00727
`U.S. Patent No. 6,628,629
`
`Dated: October 24, 2018
`
`Respectfully submitted,
`
`/Peter J. McAndrews/
`Peter J. McAndrews
`Registration No. 38,547
`McAndrews, Held & Malloy, Ltd.
`500 West Madison Street, 34th Floor
`Chicago, Illinois 60661
`Office: (312) 775-8000
`Fax: (312) 775-8100
`Email: pmcandrews@mcandrews-ip.com
`
`Lead Counsel for Patent Owner
`
`
`
`5
`
`
`
`Patent Owner’s Objections to Evidence
`IPR2018-00727
`U.S. Patent No. 6,628,629
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing Patent
`
`Owner’s Objections to Evidence were served on October 24, 2018 via email to
`
`counsel for Petitioners at the following:
`
`Ericsson_629IPR@bakerbotts.com
`
`
`/Peter J. McAndrews/
`Peter J. McAndrews
`Registration No. 38,547
`
`
`
`
`
`
`
`
`
`
`
`
`
`
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`
`
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