`By: Peter J. McAndrews
`McAndrews, Held & Malloy, Ltd.
`500 W. Madison St., 34th Floor
`Chicago, IL 60661
`Tel: 312-775-8000
`Fax: 312-775-8100
`E-mail:
`pmcandrews@mcandrews-ip.com
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`CISCO SYSTEMS, INC., DISH NETWORK, LLC,
`COMCAST CABLE COMMUNICATIONS, LLC,
`COX COMMUNICATIONS, INC.,
`TIME WARNER CABLE ENTERPRISES LLC,
`VERIZON SERVICES CORP., and ARRIS GROUP, INC.,
`Petitioner,
`
`v.
`
`TQ DELTA, LLC,
`Patent Owner.
`_____________
`Case IPR2016-010061
`Patent No. 7,835,430 B2
`_____________
`
`PATENT OWNER’S OBJECTIONS TO SUPPLEMENTAL EVIDENCE
`
`
`
`
`1 DISH Network, L.L.C., who filed a Petition in IPR2017-00251, and Comcast
`Cable Communications, L.L.C., Cox Communications, Inc., Time Warner Cable
`Enterprises L.L.C., Verizon Services Corp., and ARRIS Group, Inc., who filed a
`Petition in IPR2017-00420, have been joined in this proceeding.
`1
`
`
`
`
`
`Patent Owner Objections to Supp. Evidence
`IPR2016-01006
`Patent No. 7,835,430
`
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Patent Owner TQ Delta, LLC (“Patent
`
`Owner”) hereby files and serves the following objections to supplemental evidence
`
`that Petitioner Dish Network, LLC (“Dish”) served on Patent Owner on June 28,
`
`2017. A chart listing Patent Owner’s objections and its bases for the objections is
`
`provided below.
`
`Exhibit(s)
`
`Objection
`
`Appendix B to Ex. 1112 (FCC
`Order)
`
`
`
`
`This exhibit is not relevant under FRE 401-
`402. It is not being cited by Petitioners for
`any substantive point, but rather to support
`the alleged admissibility of Exhibit 1109.
`Exhibit 1109, however, constitutes
`inadmissible hearsay which is not cured by
`Appendix B. As such, Appendix B standing
`alone is not relevant to any issue in this
`proceeding.
`
`
`Dated: July 5, 2017
`
`
`
`/Peter J. McAndrews/
`
`
`
`
`
`
`
`Peter J. McAndrews
`Registration No. 38,547
`McANDREWS, HELD & MALLOY,
`LTD.
`500 West Madison St., Suite 3400
`Chicago, IL 60661
`Telephone: (312) 775-8000
`
`
`
`
`
`
`
`
`2
`
`
`
`Patent Owner Objections to Supp. Evidence
`IPR2016-01006
`Patent No. 7,835,430
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify, pursuant to 37 C.F.R. Section 42.6, that a complete copy of
`
`the attached PATENT OWNER’S OBJECTIONS TO SUPPLEMENTAL
`
`EVIDENCE are being served via electronic mail on July 5, 2017 to the
`
`following:
`
`Lead Counsel
`David L. McCombs
`HAYNES & BOONE, LLP
`2323 Victory Ave., Suite 700
`Dallas, TX 75219
`Tel. 214-651-5533
`Fax 214-200-0853
`david.mccombs.ipr@haynesboone.com
`
`Heidi L. Keefe
`hkeefe@cooley.com
`zpatdcdocketing@cooley.com
`Cooley LLP
`Patent Group
`1299 Pennsylvania Ave., NW, Ste 700
`Washington, DC 20004
`
`John M. Baird
`Duane Morris LLP
`505 9th St. NW, Ste 1000
`Washington, DC 20004
`Tel. 202-776-7819
`
`
`
`
`
`Back-up Counsel
`Theodore M. Foster
`Tel. 972-739-8649
`Gregory P. Huh
`Tel. 972-739-6939
`Russell Emerson
`Tel. 214-651-5328
`HAYNES & BOONE, LLP
`2323 Victory Ave., Suite 700
`Dallas, TX 75219
`Fax 972-692-9156
`ipr.theo.foster@haynesboone.com
`gregory.huh.ipr@haynesboone.com
`russell.emerson.ipr@haynesboone.com
`Stephen McBride
`smcbride@cooley.com
`Cooley LLP
`Patent Group
`1299 Pennsylvania Ave., NW, Ste 700
`Washington, DC 20004
`
`
`Christopher Tyson
`Duane Morris LLP
`505 9th St. NW, Ste 1000
`Washington, DC 20004
`Tel. 202-776-7819
`
`3
`
`
`
`Patent Owner Objections to Supp. Evidence
`IPR2016-01006
`Patent No. 7,835,430
`
`Fax 202-776-7801
`JMBaird@duanemorris.com
`
`Fax 202-776-7801
`CJTyson@duanemorris.com
`
`Dated: July 5, 2017
`
`
`
`
`
`/Peter J. McAndrews/
`
`
`
`
`
`
`
`Peter J. McAndrews
`Registration No. 38,547
`McANDREWS, HELD & MALLOY,
`LTD.
`500 West Madison Street, 34th Floor
`Chicago, Illinois 60661
`Telephone: (312) 775-8000
`
`4
`
`
`
`
`
`
`
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