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`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`REGENERON PHARMACEUTICALS, INC.,
`Petitioner,
`
`v.
`
`NOVARTIS PHARMA AG,
`NOVARTIS TECHNOLOGY LLC,
`NOVARTIS PHARMACEUTICALS CORPORATION,
`Patent Owner.
`______________________
`
`Case No. IPR2021-00816
`
`U.S. Patent No. 9,220,631
`
`______________________
`
`PETITIONER’S OBJECTIONS TO
`ADMISSIBILITY OF EVIDENCE SUBMITTED BY PATENT OWNER
`
`
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.64(b), Petitioner Regeneron Pharmaceuticals, Inc.,
`
`hereby objects as follows to the admissibility of evidence filed by Patent Owners
`
`Novartis Pharma AG, Novartis Technology LLC, Novartis Pharmaceuticals
`
`Corporation, in conjunction with the Patent Owner Preliminary Response, filed on
`
`July 29, 2021, and Patent Owner Sur-Reply, filed on August 27, 2021.
`
`Evidence
`Exhibit 2001
`
`Objections
`FRE 105: To the extent that any portion of this exhibit
`
`may be deemed admissible, such admissibility should be
`
`for a limited purpose.
`
`FRE 602: As to at least paragraphs 37-41, 43-44, 46, 48-51,
`
`56-58, 68, 71-75, 79-80, 86-89, 92, 94-95, 99, 101, 106-117,
`
`120-121, 125-132, 134, 136, 138-140, 142-145, 148, 152,
`
`154-164, 166-170, 173-174, 176-179, 184-185, 189-192,
`
`195, 198, 202, 210, the exhibit includes assertions for which
`
`evidence has not been introduced sufficient to show that the
`
`witness has personal knowledge of the matter asserted.
`
`FRE 701/702 and/or 37 C.F.R. § 42.65: As to at least
`
`paragraphs 10-11, 28-60, 63-211, the exhibit declarant is not
`
`qualified to opine on what a person of ordinary skill in the
`
`art would understand, to opine on patent claim limitations,
`
`
`
`1
`
`
`
`Evidence
`
`Objections
`to perform claim construction, and/or to perform legal
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`analysis of invalidity. The opinion testimony offered in this
`
`exhibit is not based on scientific, technical, or other
`
`specialized knowledge, and is also not based on personal
`
`knowledge. The opinion testimony includes unsubstantiated
`
`leaps and advances inaccurate, unqualified and unsupported
`
`generalizations. The opinion testimony fails to properly
`
`disclose the underlying facts or data on which the opinion is
`
`based. The opinion testimony includes testimony on United
`
`States patent law and/or patent examination practice.
`
`FRE 705 and /or 37 C.F.R. § 42.65: As to at least
`
`paragraphs 39-41, 43-44, 46, 48-51, 56-58, 68, 71-75, 79-
`
`80, 86-89, 92, 94-95, 99, 101, 106-117, 120-121, 125-132,
`
`134, 136, 138-140, 142-145, 148, 152, 154-164, 166-170,
`
`173-174, 176-179, 184-185, 189-192, 195, 198, 202, 210,
`
`the exhibit includes expert testimony that does not disclose
`
`the underlying facts or data.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`
`
`2
`
`
`
`Evidence
`
`Objections
`if offered to prove the truth of any matter allegedly asserted
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`therein.
`
`Exhibit 2002
`
`FRE 602: As to at least paragraphs 8-15, 18, the exhibit
`
`includes assertions for which evidence has not been
`
`introduced sufficient to show that the witness has personal
`
`knowledge of the matter asserted.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`Exhibit 2003
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2004
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`
`
`3
`
`
`
`Evidence
`
`Objections
`danger of unfair prejudice, confusing the issues, undue
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2005
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2006
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2007
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`
`
`4
`
`
`
`Evidence
`
`Objections
`FRE 403: The exhibit’s probative value to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2011
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 602: The exhibit includes assertions for which
`
`evidence has not been introduced sufficient to show that the
`
`witness has personal knowledge of the matter asserted.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`
`
`5
`
`
`
`Evidence
`Exhibit 2015
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2016
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`6
`
`
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`Evidence
`
`Objections
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2017
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`
`
`7
`
`
`
`Evidence
`Exhibit 2019
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2020
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`8
`
`
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`Evidence
`
`Objections
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2023
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`
`
`9
`
`
`
`Evidence
`Exhibit 2024
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2025
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`10
`
`
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`Evidence
`
`Objections
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2026
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`
`
`11
`
`
`
`Evidence
`Exhibit 2027
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2028
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`12
`
`
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`Evidence
`
`Objections
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2029
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`
`
`13
`
`
`
`Evidence
`Exhibit 2030
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2031
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`14
`
`
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`Evidence
`
`Objections
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2033
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`
`
`15
`
`
`
`Evidence
`Exhibit 2034
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2035
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`16
`
`
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`Evidence
`
`Objections
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2036
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`
`
`17
`
`
`
`Evidence
`Exhibit 2041
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2042
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`18
`
`
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`Evidence
`
`Objections
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2044
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`
`
`19
`
`
`
`Evidence
`Exhibit 2045
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2046
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2047
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`20
`
`
`
`Evidence
`Exhibit 2048
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2049
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`21
`
`
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`Evidence
`
`Objections
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2050
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2051
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`22
`
`
`
`Evidence
`Exhibit 2052
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2053
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2054
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`23
`
`
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`Evidence
`
`Objections
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2055
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`
`
`24
`
`
`
`Evidence
`Exhibit 2056
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2057
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`25
`
`
`
`Evidence
`Exhibit 2058
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2059
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2060
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`
`
`26
`
`
`
`Evidence
`Exhibit 2061
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`Exhibit 2062
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`Exhibit 2063
`
`FRE 105: To the extent that any portion of this exhibit may
`
`be deemed admissible, such admissibility should be for a
`
`limited purpose.
`
`
`
`27
`
`
`
`Evidence
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2064
`
`FRE 105: To the extent that any portion of this exhibit may
`
`be deemed admissible, such admissibility should be for a
`
`limited purpose.
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`
`
`28
`
`
`
`Evidence
`
`Objections
`danger of unfair prejudice, confusing the issues, undue
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2065
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`
`
`29
`
`
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`Evidence
`
`Objections
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2066
`
`FRE 105: To the extent that any portion of this exhibit may
`
`be deemed admissible, such admissibility should be for a
`
`limited purpose.
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`
`
`30
`
`
`
`Evidence
`Exhibit 2067
`
`Objections
`FRE 105: To the extent that any portion of this exhibit may
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`be deemed admissible, such admissibility should be for a
`
`limited purpose.
`
`FRE 402: The exhibit is not relevant to any ground upon
`
`which trial was instituted.
`
`FRE 403: The exhibit’s probative value to any ground upon
`
`which trial was instituted is substantially outweighed by the
`
`danger of unfair prejudice, confusing the issues, undue
`
`delay, wasting time, or needlessly cumulative evidence.
`
`FRE 802: The entirety of the exhibit is inadmissible hearsay
`
`if offered to prove the truth of any matter allegedly asserted
`
`therein.
`
`FRE 901: Petitioner has not produced evidence sufficient to
`
`support a finding that the exhibit is what Petitioner claims it
`
`is.
`
`Exhibit 2068
`
`FRE 105: To the extent that any portion of this exhibit may
`
`be deemed admissible, such admissibility should be for a
`
`limited purpose.
`
`
`
`31
`
`
`
`Evidence
`
`Objections
`FRE 402: The exhibit is not relevant to any ground upon
`
`IPR2021-00816
`U.S. Patent No. 9,220,631
`
`which trial was instituted.
`
`FRE 403: The exhibit
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