`
`______________
`
`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. (SHIEN LUEN FLORIDA),
`CHIEN LUEN INDUSTRIES CO., LTD., INC. (SHIEN 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 No. IPR2014-00938
`Patent 7,429,827
`
`PETITIONER’S OBJECTION TO PATENT OWNER'S
`DEMONSTRATIVES
`
`
`
`Introduction
`
`Petitioner and patent owner met and conferred over objections to their
`
`respective demonstrative exhibits and were able to resolve many of their respective
`
`disputes. Based on these agreements, it is our understanding that patent owner will
`
`file corrected demonstratives on September 18, 2015. Petitioner will, likewise, file
`
`its corrected, previously-served demonstratives on September 18, 2015. However,
`
`patent owner and petitioner were unable to resolve certain issues relating to the
`
`substance of a few of patent owner’s demonstratives. Petitioner, therefore, sets
`
`forth its objections below.
`
`Objection #1
`
`Slide 40 cites Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1583-84
`
`for a legal proposition for which it was not previously cited, and appears to be a
`
`new argument as the demonstrative slide contains no citation to the record.
`
`Objection #2
`
`Slide 45 cites SRI Int'l v. Matsushita Elec. Corp., 775 F.2d 1107, 1118 (Fed.
`
`Cir. 1985), which appears to not have been previously cited by patent owner,
`
`moreover, the slide contains no cite to the record.
`
`Objection #3
`
`Petitioner objects to demonstrative exhibit 2066 because the slides/exhibit
`
`contains a video clip of petitioner’s expert, Dr. Shackle's, deposition testimony,
`
`1
`
`
`
`which was not submitted as part of the record in these IPRs and thus is new and
`
`untimely evidence.
`
`Conclusion
`
`Petitioner believes it has resolved all of patent owner’s objections and
`
`believe these are the only remaining objections. Petitioner is available from 10:00
`
`a.m. EST to 12:00 p.m. EST, and after 3:00 p.m. EST on September 18, 2015 to
`
`discuss if necessary.
`
`Respectfully submitted,
`
`Dated:
`
`September 17, 2015
`
`233 South Wacker Drive
`Suite 7800
`Chicago, IL 60606-6306
`
`DENTONS US LLP
`
`/Mark C. Nelson /
`
`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
`
`2
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a copy of the PETITIONER’S OBJECTION
`
`TO PATENT OWNER'S DEMONSTRATIVES 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
`
`Respectfully submitted,
`
`Dated: __September 17, 2015_____ ___/Nona Durham/_________
`
`Nona Durham
`
`3
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
