`Filed: July 7, 2017
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`GOOGLE INC.,
`Petitioner
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`v.
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`IXI IP, LLC
`Patent Owner
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`Case IPR2016-01669
`Patent 7,552,124
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`PETITIONER’S OBJECTIONS TO
`PATENT OWNER’S EXHIBITS
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner submits the following
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`Case IPR2016-01669
`Patent No. 7,552,124
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`objections to certain exhibits served by Patent Owner in Case No. IPR2016-01669.
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`Petitioner’s objections apply equally to Patent Owner’s reliance on these exhibits
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`in any subsequently-filed documents. These objections are timely, having been
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`served within five business days of service of the evidence to which the objection
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`is directed.
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`Exhibit 2002
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`Petitioner objects to Exhibit 2002 under Rule 802 of the Federal Rules of
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`Evidence because it contains out of court statements that Patent Owner relies on
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`for their truth, thus constituting impermissible hearsay. See Patent Owner’s
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`Response at 11. Petitioner also objects to Exhibit 2002 under Rule 901 of the
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`Federal Rules of Evidence, as Patent Owner has not produced any evidence
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`establishing that Exhibit 2002 is what Patent Owner claims it to be. See Patent
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`Owner’s Response at vi.
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`Dated: July 7, 2017
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`Respectfully submitted,
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` /Naveen Modi/
`Naveen Modi
`Reg. No. 46,224
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`Counsel for Petitioner
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`1
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`CERTIFICATE OF SERVICE
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`Case IPR2016-01669
`Patent No. 7,552,124
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`I hereby certify that on this 7th day of July 2017, a copy of the foregoing
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`Petitioner’s Objections to Patent Owner’s Exhibits was served by e-mail on the
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`following counsel of record for Patent Owner:
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`Andy H. Chan (chana@pepperlaw.com)
`Charles F. Koch (kochc@pepperlaw.com)
`Griffin Mesmer (mesmerg@pepperlaw.com)
`Andrew Schultz (schultza@pepperlaw.com)
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`Respectfully submitted,
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` /Naveen Modi/
`Naveen Modi
`Reg. No. 46,224
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`Counsel for Petitioner
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`Dated: July 7, 2017
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