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UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
`
`
`
`INTERNATIONAL BUSINESS MACHINES CORPORATION,
`
`Petitioner
`
`v.
`
`INTELLECTUAL VENTURES I LLC,
`
`Patent Owner
`_________________
`
`Case IPR2015-01481
`Patent 6,510,434
`_________________
`
`
`
`PATENT OWNER’S LISTING OF PORTIONS OF PETITIONER’S
`REPLY AND EXPERT TESTIMONY
`IN SUPPORT OF MOTION TO STRIKE
`
`
`
`
`
`
`
`
`
`

`
`On August 15, 2016 the Board requested Patent Owner to provide a listing
`
`of the portions of Petitioner’s Reply (Paper No. 24) and Dr. Jagadish's Responsive
`
`Declaration (Ex. 1022) that Patent Owner contends raise new arguments and
`
`evidence regarding Wical and the portions of Dr. Jagadish’s deposition testimony
`
`taken on July 29, 2016 (Ex. 1023) that Patent Owner contends brought the new
`
`arguments and evidence to light. The requested listings are provided below
`
`without argument or comment.
`
`Proposed Portions of Petitioner’s Reply to Strike
`
`• Page 2, line 2 to line 3
`
`• Page 2, line 7 to line 13
`
`• Page 3, line 1 to line 2
`
`• Page 3, line 4 to line 6
`
`• Page 3, line 12 to line 14
`
`• Page 5, line 21 to page 6, line 1
`
`• Page 6, line 15 to line 17
`
`Proposed Portions of Dr. Jagadish’s Responsive Declaration to Strike
`
`1
`
`• ¶ 3
`
`• ¶ 4
`
`
`
`
`
`

`
`Relevant Portions of Dr. Jagadish’s Second Deposition Testimony
`
`2
`
`Respectfully submitted,
`
`
`
`/James P. Murphy/
`James P. Murphy
`Reg. No. 55,474
`Henry A. Petri, Jr.
`Reg. No. 33,063
`
`
`• 18:23-19:4
`
`• 19:15-20:2
`
`• 20:15-21:1
`
`• 21:4-25
`
`• 31:24-32:4
`
`• 36:3-19
`
`• 37:4-23
`
`• 41:6-10.
`
`
`
`POLSINELLI PC
`1000 Louisiana Street, 53rd Floor
`Houston, Texas 77002
`P: 713-374-1631
`
`
`
`
`
`

`
`CERTIFICATE OF SERVICE PURSUANT TO 37 C.F.R. § 42.6(e)(4)
`
`The undersigned hereby certifies that a copy of the PATENT OWNER’S
`
`LISTING OF PORTIONS OF PETITIONER’S REPLY AND EXPERT
`
`TESTIMONY IN SUPPORT OF MOTION TO STRIKE has been served via
`
`Electronic Mail on August 15, 2016 upon the following:
`
`Kenneth R. Adamo
`Joel R. Merkin
`Brent P. Ray
`Eugene Goryunov
`KIRKLAND & ELLIS LLP
`300 North LaSalle Street
`Chicago, Illinois 60654
`IBM_IPR_SERVICE@kirkland.com
`
`And
`
`Patent Trial and Appeal Board
`Trials@uspto.gov
`
`
`
`
`
`
`
`/James P. Murphy/
`James P. Murphy
`POLSINELLI PC
`1000 Louisiana Street, 53rd Floor
`Houston, Texas 77002
`P: 713-571-1631
`
`
`3

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