`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`JIAWEI TECHNOLOGY (HK) LTD., JIAWEI TECHNOLOGY (USA) LTD.,
`SHENZHEN JIAWEI PHOTOVOLTAIC LIGHTING CO., LTD., ATICO
`INTERNATIONAL (ASIA) LTD., ATICO INTERNATIONAL USA, INC.,
`CHIEN LUEN INDUSTRIES CO., LTD., INC. (CHIEN LUEN FLORIDA),
`CHIEN LUEN INDUSTRIES CO., LTD., INC. (CHIEN LUEN CHINA),
`COLEMAN CABLE, LLC, NATURE’S MARK, RITE AID CORP., SMART
`SOLAR, INC., AND TEST RITE PRODUCTS CORP.
`Petitioner,
`
`v.
`
`SIMON NICHOLAS RICHMOND
`Patent Owner.
`______________
`
`Case IPR2014-00938
`Patent 7,429,827
`
`PETITIONER'S NOTICE OF OBJECTION TO EVIDENCE
`
`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`PETITIONER'S NOTICE OF OBJECTION TO EVIDENCE for
`Inter Partes Review of U.S. Patent No. 7,429,827
`Case IPR2014-00938
`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner, Jiawei Technology (HK)
`
`Ltd., Jiawei Technology (USA) Ltd., Shenzhen Jiawei Photovoltaic Lighting Co.,
`
`Ltd., Atico International (Asia) Ltd., Atico International USA, Inc., Chien Luen
`
`Industries Co., Ltd., Inc. (Chien Luen Florida), Chien Luen Industries Co., Ltd.,
`
`Inc. (Chien Luen China), Coleman Cable, LLC, Nature’s Mark, Rite Aid Corp.,
`
`Smart Solar, Inc., and Test Rite Products Corp. (collectively “Petitioner”), hereby
`
`submits its notice of objections to certain evidence that Patent Owner, Simon
`
`Nicholas Richmond (“Patent Owner”), submitted in connection with IPR2014-
`
`00938.
`
`Testimony of Simon Nicholas Richmond
`
`Petitioner objects to certain testimony of Simon Nicholas Richmond
`
`submitted as part of Exhibit 2063 (Declaration by Simon Nicholas Richmond).
`
`Specifically, Petitioner objects to paragraphs 10, 18, 20, 22, and 24 of Exhibit 2063
`
`to the extent they include hearsay statements and/or to the extent Simon Nicholas
`
`Richmond offers factual observations without
`
`laying foundation or otherwise
`
`demonstrating personal knowledge (FRE 602, 702, 703, 801, and 802).
`
`Paragraphs 10, 18, 20, 22, and 24 reference Exhibits 2042, 2050, 2052,
`
`2054, and 2062 which are Linkedin.com profiles that include hearsay statements as
`
`to the roles or job titles that are stated on such profiles. Additionally, one cannot
`
`adequately substantiate the information contained in the underlying exhibits.
`
`1
`
`
`
`PETITIONER'S NOTICE OF OBJECTION TO EVIDENCE for
`Inter Partes Review of U.S. Patent No. 7,429,827
`Case IPR2014-00938
`
`Exhibits
`
`Petitioner objects to the following exhibits under FRE 801 and 802 as
`
`including hearsay statements as discussed above:
`
`•
`
`•
`
`•
`
`•
`
`•
`
`Exhibit 2042 - Floyd W. Smith's LinkedIn profile
`
`Exhibit 2050 - Lisa Biggs’ LinkedIn profile
`
`Exhibit 2052 - Kathy Jo Van’s LinkedIn profile
`
`Exhibit 2054 - Multiple LinkedIn profiles
`
`Exhibit 2062 - Heather Foster's LinkedIn Profile
`
`Petitioner reserves the right to move to exclude the noted testimony and
`
`exhibits.
`
`Dated: __July 8, 2015______
`
`233 South Wacker Drive
`Suite 7800
`Chicago, IL 60606-6306
`
`Respectfully submitted,
`
`DENTONS US LLP
`
`/Kevin Greenleaf/________
`Mark C. Nelson
`Reg. No. 43,830
`Lissi Mojica
`Reg. No. 63,421
`Kevin Greenleaf
`Reg. No. 64,062
`Daniel Valenzuela
`Reg. No. 69,027
`
`
`
`PETITIONER'S NOTICE OF OBJECTION TO EVIDENCE for
`Inter Partes Review of U.S. Patent No. 7,429,827
`Case IPR2014-00938
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on July 8, 2015, a copy of PETITIONER'S
`
`NOTICE OF OBJECTION TO EVIDENCE for Inter Partes Review of U.S. Patent
`
`No. 7,429,827 was served on the Counsel for the Patent Owner via email to the
`
`following email addresses:
`
`tfshiells@shiellslaw.com
`
`admin@shiellslaw.com
`
`marcusb@tlpmb.com
`
`Dated: July 8, 2015
`
`233 South Wacker Drive
`Suite 7800
`Chicago, IL 60606-6306
`
`Respectfully submitted,
`
`___/Nona Durham/_________
`Nona Durham
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