`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`HAMAMATSU PHOTONICS K.K.,
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`Petitioner,
`
`v.
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`SEMICAPS PTE LTD.,
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`Patent Owner.
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`IPR Number: IPR2017-02110
`
`Patent No. 7,623,982 B2
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`
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`PETITIONER’S OBJECTIONS TO PATENT OWNER’S EVIDENCE
`PURSUANT TO 37 C.F.R. § 42.64(b)(1)
`
`
`
`
`
`
`John G. Smith (Reg. No. 33,818)
`William S. Foster (Reg. No. 51,695)
`Christopher Bruenjes (Reg. No. 62,941)
`Drinker Biddle & Reath LLP
`1500 K Street, N.W.
`Washington, DC 20005-1209
`Phone: (202) 842-8800 (reception)
`Fax: (202) 842-8456
`Email:
`john.smith@dbr.com
`william.foster@dbr.com
`christopher.bruenjes@dbr.com
`
`
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`
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner Hamamatsu Photonics K.K.
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`makes the following objections to the evidence submitted by Patent Owner
`
`SEMICAPS Pte Ltd. in support of its Patent Owner Preliminary Response (Paper 7).
`
`These objections are being timely filed and served within ten business days after the
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`institution of trial, pursuant to 37 C.F.R. § 42.64(b)(1).
`
`Exhibit No.
`2009
`
`2012
`
`2014
`
`Basis of Objection
`Federal Rule of Evidence 106 – Patent Owner only included two
`pages of this book, and did not include the entire “Pulsed and
`Continuous Output” section or “Introduction & Overview”
`chapter in which the submitted pages are included. Petitioner
`requires that Patent Owner include at least the entire chapter
`because “in fairness [it] ought to be considered at the same time”
`as the portion that was submitted.
`Federal Rule of Evidence 106 – Patent Owner only included one
`page of this book, and did not include the entire “Pulsed Laser
`Beam Traits” section or chapter in which the submitted page is
`included. Petitioner requires that Patent Owner include at least
`the entire chapter because “in fairness [it] ought to be considered
`at the same time” as the portion that was submitted.
`Federal Rule of Evidence 106 – Patent Owner only included one
`page of this book, and did not include the entire section or chapter
`in which the submitted page is included. Petitioner requires that
`Patent Owner include at least the entire chapter because “in
`fairness [it] ought to be considered at the same time” as the
`portion that was submitted.
`
`Dated: April 2, 2018
`
`Respectfully submitted,
`
`DRINKER BIDDLE & REATH LLP
`
`
`By:
`/John G. Smith/
`John G. Smith (Reg. No. 33,818)
`
`Counsel for Petitioner
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`
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`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6, I hereby certify that on this 2nd day of April,
`
`2018, I caused the foregoing document to be served via electronic mail on counsel
`
`for record for the Patent Owner as follows:
`
`David D. Schumann
`Hector Ribera
`Marton Ribera Schumann & Chang LLP
`548 Market Street, Suite 36117
`San Francisco, CA 94104
`david@martonribera.com
`hector@martonribera.com
`
`
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`
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`Respectfully submitted,
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`
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`/John G. Smith/
`
`John G. Smith
`Reg. No. 33,818
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