`Filed: January 30, 2018
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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 LLC,
`Petitioner,
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`v.
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`UNILOC USA, INC. and UNILOC LUXEMBOURG, S.A.,
`Patent Owner.
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`_________________
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`Case No. IPR2017-01685
`U.S. Patent No. 7,804,948
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`PETITIONER’S OBJECTIONS TO PATENT OWNER’S EXHIBIT
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`IPR2017-01685
`U.S. Patent No. 7,804,948
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`In accordance with 37 C.F.R. § 42.64(b)(1), Petitioner submits the following
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`objections to an exhibit submitted by Patent Owner. Petitioner’s objections apply
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`with equal force to Patent Owner’s reliance on this exhibit in subsequently filed
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`documents. The objections are timely, having been served within ten business days
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`of Institution. Petitioner objects to the following exhibit:
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`Ex. 2001 Declaration of William Easttom II
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`Ex. 2001
`Petitioner objects to Ex. 2001 under the Federal Rules of Evidence (“FRE”),
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`IPR2017-01685
`U.S. Patent No. 7,804,948
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`Rules 401-403, as prejudicial, confusing, or a waste of time. Petitioner also objects
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`to Ex. 2001 under FRE 702 because opinions contained therein are conclusory and
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`lack sufficient explanation. The opinions are not based on sufficient facts or data
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`and are not the product of reliable principles and methods applied to the facts of
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`the case. 37 C.F.R. § 42.65. Until Patent Owner provides the declarant for cross-
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`examination, Ex. 2001 is inadmissible hearsay.
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`Dated: January 30, 2018
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`Respectfully submitted,
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`By: /Erika H. Arner/
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`Erika H. Arner (Reg. No. 57,540)
`Jason E. Stach (Reg. No. 54,464)
`Daniel C. Cooley (Reg. No. 59,639)
`Kai Rajan (Reg. No. 70,110)
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`Attorneys for Petitioner Google LLC
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies a copy of the foregoing PETITIONER’S
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`IPR2017-01685
`U.S. Patent No. 7,804,948
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`OBJECTIONS TO PATENT OWNER’S EXHIBIT was served electronically on
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`January 30, 2018, on counsel of record for the Patent Owner as follows:
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`Brett Mangrum
`brett@etheridgelaw.com
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`Sean D. Burdick
`sean.burdick@unilocusa.com
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`Ryan Loveless
`ryan@etheridgelaw.com
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`James Etheridge
`jim@etheridgelaw.com
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`Jeffrey Huang
`jeff@etheridgelaw.com
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`By: /Lisa C. Hines/
`Lisa C. Hines
`Litigation Clerk
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
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`Dated: January 30, 2018
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