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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
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`BLUEBIRD BIO, INC.
`Petitioner
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`v.
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`SLOAN KETTERING INSTITUTE FOR CANCER RESEARCH,
`Patent Owner
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`_________________
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`Case No. IPR2023-00070
`Patent No. 7,541,179
`_________________
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`PETITIONER’S OBJECTIONS TO
`PATENT OWNER’S EXHIBITS
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`Case No. IPR2023-00070
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`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner submits the following
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`objections to exhibits served by Patent Owner in Case No. IPR2023-00070.
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`Petitioner’s objections apply equally to Patent Owner’s reliance on the exhibit in
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`any subsequently-filed documents. These objections are timely, having been
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`served within ten business days after institution of trial. 37 C.F.R. § 42.64(b)(1).
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`Exhibit 2001
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`Petitioner objects to Exhibit 2001 under Rules 901 and 902 of the Federal
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`Rules of Evidence (FRE) because it does not contain all of the signatures required
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`and is thus insufficiently authenticated and not self-authenticating.
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`Exhibit 2002
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`Petitioner objects to Exhibit 2002 under FRE 602 and/or 901 for lack of
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`foundation.
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`Exhibit 2003
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`Petitioner objects to Exhibit 2003 under FRE 602 and/or 901 for lack of
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`foundation. Petitioner further objects to Exhibit 2003 under FRE 802 because it
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`contains out of court statements that Patent Owner relies on for their truth, thus
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`constituting impermissible hearsay.
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`Exhibit 2004
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`Petitioner objects to Exhibit 2004 under FRE 602 and/or 901 for lack of
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`foundation. Petitioner further objects to Exhibit 2004 under FRE 802 because it
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`contains out of court statements that Patent Owner relies on for their truth, thus
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`Case No. IPR2023-00070
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`constituting impermissible hearsay.
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`Exhibit 2006
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`Petitioner objects to Exhibit 2006 under FRE 602 and/or 901 for lack of
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`foundation.
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`Exhibit 2007
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`Petitioner objects to Exhibit 2007 under FRE 602 and/or 901 for lack of
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`foundation.
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`Exhibit 2008
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`Petitioner objects to Exhibit 2008 under FRE 602 and/or 901 for lack of
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`foundation.
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`Exhibit 2009
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`Petitioner objects to Exhibit 2009 under FRE 602 and/or 901 for lack of
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`foundation.
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`Exhibit 2033
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`Petitioner objects to Exhibit 2033 under FRE 106 because it is an incomplete
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`writing. Petitioner further objects to Exhibit 2033 under FRE 802 because it
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`contains out of court statements that Patent Owner relies on for their truth, thus
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`constituting impermissible hearsay. Petitioner also objects to Exhibit 2033 under
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`FRE 602 and/or 901 for lack of foundation.
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`Case No. IPR2023-00070
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`Exhibit 2034
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`Petitioner objects to Exhibit 2034 under FRE 106 because it is an incomplete
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`writing. Petitioner further objects to Exhibit 2034 under FRE 802 because it
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`contains out of court statements that Patent Owner relies on for their truth, thus
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`constituting impermissible hearsay. Petitioner also objects to Exhibit 2003 under
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`FRE 602 and/or 901 for lack of foundation.
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`Exhibit 2035
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`Petitioner objects to Exhibit 2035 under FRE 602 and/or 901 for lack of
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`foundation. Petitioner further objects to Exhibit 2035 under FRE 802 because it
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`contains out of court statements that Patent Owner relies on for their truth, thus
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`constituting impermissible hearsay.
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`Dated: May 8, 2023
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` Respectfully submitted,
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`By: /Naveen Modi/
` Naveen Modi (Reg. No. 46,224)
` Counsel for Petitioner
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`Case No. IPR2023-00070
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`CERTIFICATE OF SERVICE
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`I hereby certify that I caused to be served on the counsel identified below a
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`true and correct copy of the foregoing Petitioner’s Objections to Patent Owner’s
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`Exhibits by electronic means on May 8, 2023:
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`FOR THE PATENT OWNER:
`Luke Toft (Reg. No. 75,311)
`ltoft@foxrothschild.com
`Fox Rothschild LLP
`33 South Sixth Street, Suite 3600
`Minneapolis, MN 55402
`Telephone: (612) 607-7000
`Facscimile: (612) 607-7100
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`Joe Chen (Reg. No. 70,066)
`joechen@foxrothschild.com
`Fox Rothschild LLP
`997 Lenox Drive
`Lawrenceville, NJ 08648
`Telephone: (609) 844-3024
`Facsimile: (609) 896-1469
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`Respectfully submitted,
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`By: /Naveen Modi/
` Naveen Modi (Reg. No. 46,224)
` Counsel for Petitioner
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