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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`THE BOEING COMPANY
`Petitioner
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`v.
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`SEYMOUR LEVINE
`Patent Owner
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`Case No. IPR2015-01341
`U.S. Patent No. RE39,618
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`Petitioner’s Objections to Patent Owner’s Evidence
`Under 37 C.F.R. § 42.64(b)(1)
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`03007-0014/92055503.1
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`Case No. IPR2015-01341
`U.S. Patent No. RE39,618
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner, The Boeing Company,
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`submits the following objections to Exhibit Nos. 2009-2010, which were served by
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`Patent Owner, Seymour Levine, together with his Response. These objections are
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`timely because they have been served within five business days of the service of
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`the Patent Owner Response, which occurred on March 28, 2016. See 37 C.F.R.
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`§ 42.64(b)(1).
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`Exhibit
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`2009
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`Objections
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`¶ 4: FRE 402, 801, 1002. Declarant testifies re: contents
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`of “earlier version of draft invention disclosure,” but that
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`document has not been produced.
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`¶ 7: FRE 106, 402, 801, 1002. Draft patent application
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`not produced, return draft not produced, redacted portion
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`of transmittal letter in fairness ought to be considered at
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`the same time as non-redacted portion.
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`03007-0014/92055503.1
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`1
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`Exhibit
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`2010
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`Case No. IPR2015-01341
`U.S. Patent No. RE39,618
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`Objections
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`¶ 2: FRE 402, 801, 1002. Declarant testifies re: contents
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`of “preliminary invention disclosure,” but that document
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`has not been not produced.
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`¶ 6: FRE 106, 402, 801, 1002. Referenced patent
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`application not produced; redacted portion of transmittal
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`letter in fairness ought to be considered at the same time
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`as unredacted portion.
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`¶ 7: FRE 402, 801, 1002. Referenced drafts and
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`provisions not produced.
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`Respectfully submitted,
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` /Ryan J. McBrayer/
`Ryan J. McBrayer (Reg. No. 54,299)
`Perkins Coie LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101
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`Attorneys for The Boeing Company
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`Dated: April 4, 2016
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`03007-0014/92055503.1
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`2
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`Case No. IPR2015-01341
`U.S. Patent No. RE39,618
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`Certificate of Service
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`The undersigned hereby certifies that the above-captioned Petitioner’s
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`Objections to Patent Owner’s Evidence Under 37 C.F.R. § 42.64(b)(1) was served
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`in its entirety on April 4, 2016, upon the following counsel for Patent Owner via e-
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`mail, pursuant to the parties’ agreement concerning service:
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`Bruce R. Zisser
`Amar L. Thakur
`Quinn Emanuel Urquhart & Sullivan, LLP
`865 South Figueroa Street, 10th Floor
`Los Angeles, CA 90017
`brucezisser@quinnemanuel.com
`amarthakur@quinnemanuel.com
`Attorneys for Patent Owner Seymour Levine
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` /Ryan J. McBrayer/
`Ryan J. McBrayer (Reg. No. 54,299)
`Perkins Coie LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101
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`Attorneys for The Boeing Company
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`3
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`Dated: April 4, 2016
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`03007-0014/92055503.1