throbber
IPR2016-01470
`U.S. Patent No. 8,611,404
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`DISH NETWORK L.L.C.
`Petitioner
`
`v.
`
`TQ DELTA LLC
`Patent Owner
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2016-01470
`Patent 8,611,404
`
`
`
`PETITIONER’S OBJECTION TO PATENT OWNER’S
`DEMONSTRATIVES
`
`
`
`
`
`
`
`

`

`IPR2016-01470
`U.S. Patent No. 8,611,404
`
`Pursuant to the Board’s Trial Hearing Order of October 6, 2017 (Paper No. 35),
`
`Petitioner hereby objects to the Patent Owner’s demonstratives for the oral hearing
`
`scheduled for November 8, 2017:
`
`(1)
`
`Petitioner’s objects to slide 29 of the Patent Owner’s demonstratives as
`
`containing new argument because the second bullet point cites to and provides an
`
`image from “Ex. 1002 at ¶ 65,” and Patent Owner has never addressed or cited to this
`
`paragraph in any of its briefings. A copy of this slide is attached to this paper.
`
`
`
`
`
`Dated: November 6, 2017
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, DC 20004
`Tel: 650-843-5001
`Fax: 650-849-7400
`
`
`
`
`By:
`
`
`
`
`Respectfully submitted,
`
`/ Heidi L. Keefe /
`Heidi L. Keefe
`Reg. No. 40,673
`Counsel for Petitioner
`
`
`
`1
`
`

`

`29
`
`
`
`mm66.5;EonioérommE68:8mmFEmoor.xm_
`
`Ex. 1002 at ¶ 65 (cited at IPR2016-01470 at Pet. at 6)
`
`mHOmEm 3303.—E23.5.33:28HAmfiwnmhmvm9H3:on95m6:50o
`
`
`
`fix:$808:953m-m3:0,HAxfiEma3—8gofimflvb
`
`
`
`4%?EBwho;595.3
`
`3:53:
`
`
`
`
`
`h:EMflmMEmiguh53..5.“can:he:Am_m::a:uln_=&3:3:aEEoU.mw
`
`
`
`
`
`IPR2016-01470 Reply at 19-20
`
`
`
`quxm{82:51A8-2a£2;330-28%
`
`(cid:102)Petitioner’s Expert:
`
`6:8
`
`
`
`
`
`
`
`3::Panama—Bab:5:tEmflgg2:53:2:Emma0:58:m:.5:magic
`
`
`
`0:2tau.5:253.553memo—0mgarsom:33mama—55:3Emma:2$550
`
`
`
`
`
`
`
`
`
`5:mmAw?AmongEmmwmdmOm2:mmAg:rwdvbig—FEmama0:.EEmmini
`
`
`
`
`
`
`
`
`
`
`
`
`
`0:2“6::Paudwflmfifim?flaw_m:w_m255mm:angiomfian—mcbEflmmoa“32:?
`
`
`
`
`
`
`
`
`
`
`
`aE22:ESSaw2?downs«do395::mm:Ewfi2:52:53<damfi2:5»:
`
`
`
`
`
`
`
`
`
`(cid:102)Petitioner’s (Attorney-Argument-Only) Reply:
`
`
`
`.nx_qmm..-~>_co-flc.oE:9<->mc_o:$.95:02:01A
`
`3230:.I>33.3:232:3;
`
`93539".>3csgcgcoom.w3:25E39".mflEaEEomEE2552
`$522
`:mgxm
`
`Argument Mischaracterizes Patent Owner &
`Petitioner’s ’404 Reply –Incorrect Attorney
`
`Is Contradicted by Petitioner’s Expert
`
`
`

`

`IPR2016-01470
`U.S. Patent No. 8,611,404
`
`
`CERTIFICATE OF SERVICE
`
`
`I hereby certify, pursuant to 37 C.F.R. Sections 42.6, that a complete copy of
`
`the attached PETITIONER’S OBJECTION TO PATENT OWNER’S
`DEMONSTRATIVES is being filed with the PTAB and served via electronic mail
`on the 6th day of November, 2017, upon counsel of record for the Patent Owner as
`follows:
`
`Peter J. McAndrews
`pmcandrews@mcandrews-ip.com
`
`Thomas J. Wimbiscus
`twimbiscus@ mcandrews-ip.com
`
`Scott P. McBride
`smcbride@ mcandrews-ip.com
`
`Christopher M. Scharff
`cscharff@ mcandrews-ip.com
`
`
`Dated: November 6, 2017
`
`
`
`
`
`
`
`
`
`COOLEY LLP
`ATTN: Patent Docketing
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, D.C. 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` /Heidi L. Keefe/
`Heidi L. Keefe
`Reg. No. 40,673
`
`
`
`
`
`1
`
`
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

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.

throbber

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.

Become a Member

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

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket