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`Paper No. __
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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, SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC.,
`LG ELECTRONICS INC., and
`ELECTRONICS U.S.A., INC.,
`Petitioner,
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`v.
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`PARUS HOLDINGS INC.,
`Patent Owner.
`_____________
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`Case No. IPR2020-00846
`Patent No. 7,076,431
`_____________
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`PETITIONERS’ OBJECTIONS TO EVIDENCE SERVED WITH
`PATENT OWNER RESPONSE
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioners submit the following
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`objections to evidence served in connection with the Patent Owner’s Response on
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`January 13, 2021. These objections have been timely filed and served within five
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`business days of service of the evidence to which the objections are directed.
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`Petitioners object to each of Exhibits 2021-2026 and 2029-2058 (“Objected-
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`to Exhibits”), for the following reasons:
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` Each of the Objected-to Exhibits is inadmissible because Patent
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`Owner has failed to authenticate any of these exhibits in accordance
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`with Fed. R. Evid. 901(a). Patent Owner has not explained what each
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`document is, has not provided evidence regarding the origin or
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`preservation of each document, has not established that each is a true
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`and correct copy, and has not otherwise authenticated each document.
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` The Patent Owner’s Response does not cite with specificity any of the
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`Objected-to Exhibits, nor does the Patent Owner’s Response explain
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`what information (if any) in each of the Objected-to Exhibits is
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`purportedly relied on, nor for what purpose any such information is
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`being offered. To the extent the Patent Owner is attempting to rely on
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`any statement within the Objected-to Exhibits (including, inter alia,
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`any date identified within the exhibits) as evidence to prove the truth
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`1
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`of the matter asserted, such statement is hearsay under Fed. R. Evid.
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`801 and therefore inadmissible under Fed. R. Evid. 802.
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` Due to the above deficiencies, Patent Owner has failed to establish
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`that the Objected-to Exhibits are relevant under Fed. R. Evid. 401, and
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`therefore the exhibits are additionally inadmissible under Fed. R.
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`Evid. 402.
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`Petitioners likewise object to any and all portions of the Patent Owner’s
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`Response (Paper 14), the Kurganov Declaration (Ex. 2020), the Kurganov claim
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`charts (Exs. 2027-2028), the Occhiogrosso Declaration (Ex. 2059), and the Mulka
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`Declaration (Ex. 2060) purporting to rely on any of the Objected-to Exhibits.
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`Date: January 21, 2021
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`Respectfully submitted,
`Google LLC et al.
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`/Elisabeth Hunt/
`Elisabeth H. Hunt, Reg. No. 67,336
`Richard F. Giunta, Reg. No. 36,149
`Gregory S. Nieberg, Reg. No. 57,063
`WOLF, GREENFIELD & SACKS, P.C.
`600 Atlantic Avenue
`Boston, MA 02210
`(617) 646-8000 Phone
`(617) 646-8646 Fax
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`2
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (E)(4)
`I certify that on January 21, 2021, I will cause a copy of the foregoing
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`document, including any exhibits filed therewith, to be served via electronic mail,
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`as previously consented to by Patent Owner, upon the following:
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`Michael J. McNamara
`Michael T. Renaud
`William A. Meunier
`Andrew H. DeVoogd
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`Date: January 21, 2021
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`mmcnamara@mintz.com
`mtrenaud@mintz.com
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`wameunier@mintz.com
`ahdevoogd@mintz.com
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`/MacAulay Rush/
`MacAulay Rush
`Paralegal
`WOLF, GREENFIELD & SACKS, P.C.
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