`
`
`
`
`
`
`
`
`
`
`
`
`
`Paper No. 31
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`___________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________________________________
`
`
`Sony Corporation
`Petitioner
`
`v.
`
`FUJIFILM Corporation
`Patent Owner
`___________________
`
`Case IPR2018-00877
`U.S. Patent No. 6,462,905
`___________________
`
`REPLY TO OPPOSITION TO MOTION TO EXCLUDE
`
`
`
`
`
`
`As Petitioner admits in its Opposition, Petitioner does not rely on Exhibit 1034
`
`in IPR Proceeding No. IPR2018-00877. See Petitioner’s Opposition to Patent
`
`Owner’s Motion to Exclude (Paper No. 30) (“Opposition”) at 1. Further, Sony
`
`agrees that Exhibit 1034 is irrelevant to this proceeding. See Opposition at 1-2. As
`
`discussed in Patent Owner’s Motion to Exclude, Exhibit 1034 was submitted for the
`
`first time along with Petitioner’s Reply, and was not cited in the Petition or
`
`Petitioner’s Reply. Because Exhibit 1034 cannot support Petitioner’s grounds
`
`submitted in the Petition, Exhibit 1034 is irrelevant under FRE 401-402, and should
`
`be excluded.
`
`
`
`June 4, 2019
`
`
`
`
`
`
`
`
`
`
`
`Respectfully,
`
`/Eliot D. Williams/
`Eliot D. Williams
`Reg. No. 50,822
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`Phone: (650) 739-7511
`Facsimile: (650) 739-7611
`eliot.williams@bakerbotts.com
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on the 4th day
`
`of June 2019, a complete and entire copy of this Reply to Opposition to Motion to
`
`Exclude Evidence was filed with the PTAB through its E2E system and served via
`
`email on attorneys of record for Sony at the following address:
`
`Richard F. Giunta
`RGiunta-PTAB@wolfgreenfield.com
`
`Michael N. Rader
`MRader-PTAB@wolfgreenfield.com
`
`Randy J. Pritzker
`RPritzker-PTAB@wolfgreenfield.com
`
`Nathan Speed
`Nathan.Speed@WolfGreenfield.com
`
`
`
`
`Respectfully submitted,
`BAKER BOTTS LLP
`
`
`June 4, 2019
`
`/Eliot D. Williams/
`Eliot D. Williams
`Reg. No. 50,822
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, CA 94304
`Phone: (650) 739-7511
`Facsimile: (650) 739-7611
`eliot.williams@bakerbotts.com
`
`
`FUJIFILM CORPORATION
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
