`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`GOOGLE INC.,
`
`Petitioner,
`
`v.
`
`VEDANTI SYSTEMS LIMITED 1
`
`Patent Owner.
`____________
`
`
`Case No. IPR2016-00212 2
`
`Patent No. 7,974,339 B2
`
`_____________
`
`PATENT OWNER’S OBJECTIONS TO EVIDENCE PURSUANT TO 37
`C.F.R. § 42.64
`
`
`
`1 Vedanti Systems Limited has assigned the patent to the current patent owner,
`Vedanti Licensing Limited.
`2 Case IPR2016-00215 has been consolidated with this proceeding.
`
`
`
`IPR2016-00212
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), the undersigned, on behalf of Patent
`
`Owner Vedanti Licensing Limited (“Patent Owner”) hereby submits the following
`
`objections to the admissibility of Exhibit 1030 submitted with Petitioner’s Reply
`
`on November 21, 2016.
`
`Exhibit 1030 (“Supplemental Declaration of Dr. John R. Grindon”) is
`
`objected to under F.R.E. 702 (improper expert testimony) and Daubert v. Merrell
`
`Dow Pharmaceuticals, Inc. , 509 U.S. 579 (1993). Dr. Grindon does not possess
`
`the requisite specialized knowledge to render opinions as to the understandings
`
`and abilities of a person of ordinary skill in the art at the time of the invention in
`
`view of the expanded standard including a sufficient knowledge of compression.
`
`Exhibit 1030 is further objected to under F.R.E. 702 as the testimony is not based
`
`on sufficient facts or data, is not the product of reliable principles and methods,
`
`and the principles and methods have not been reliably applied to the facts of the
`
`case. Exhibit 1030 is further objected to under F.R.E. 703 as the testimony is
`
`based on facts or data that an expert in this field would not reasonably rely on.
`
`Exhibit 1030 is further objected to under 37 C.F.R. § 42.65(a) for failing to
`
`identify with particularity the underlying facts and data on which the opinions are
`
`based.
`
`Exhibit 1030 is further objected to under 37 C.F.R. §42.23(b) as improper
`
`reply evidence. Paragraphs 49-70 and 73 are objected to as improper reply
`
`evidence to the extent they belatedly present information that could have been
`- 1 -
`
`
`
`raised in the Petition.
`
`
`
`These objections have been timely made within five business days from the
`
`date of service of the evidence to which they are directed.
`
`
`
`Date: November 29, 2016 By: /Robert M. Asher/
`
`
`Robert M. Asher
`Registration No.: 30,445
`Sunstein Kann Murphy & Timbers LLP
`125 Summer Street
`Boston, MA 02110
`Tel: (617) 443-9292
`Fax: (617) 443-0004
`
`- 2 -
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Patent Owner’s
`
`Objections To Evidence Pursuant To 37 C.F.R. § 42.64 was served on November
`
`29, 2016 by electronic mail (by prior agreement with the Petitioner) to the
`
`attorneys of record at:
`Sterne, Kessler, Goldstein & Fox PLLC
`
`1100 New York Avenue, N.W.
`
`Washington, D.C. 20005
`
`by transmitting the documents to the attorneys' email addresses at:
`
`mikem-PTAB@skgf.com; mholoubek-PTAB@skgf.com
`
`By: /Robert M. Asher/
`
`Robert M. Asher
`Registration No.: 30,445
`Sunstein Kann Murphy & Timbers LLP
`125 Summer Street
`Boston, MA 02110
`Tel: (617) 443-9292
`Fax: (617) 443-0004
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