`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`REALTEK SEMICONDUCTOR CORP.,
`Petitioner,
`
`v.
`
`ATI TECHNOLOGIES ULC
`Patent Owner.
`
`Case No.: IPR2023-00564
`
`Patent 7,742,053
`
`PETITIONER’S OBJECTIONS TO PATENT OWNER’S EVIDENCE
`SUBMITTED WITH PATENT OWNER’S RESPONSE
`
`
`
`Pursuant to 37 C.F.R. § 42.64(b)(1), Petitioner Realtek Semiconductor Corp.
`
`(“Realtek”) objects to the following exhibits filed by Patent Owner ATI
`
`Technologies ULC (“ATI”) with its Patent Owner Response (Paper No. 11).
`
`Exhibit
`
`EX2009 –
`Declaration of John
`Hart Regarding U.S.
`Patent No. 7,742,053
`
`Objection(s)
`Petitioner objects to EX2009 including, for example, Dr.
`Hart’s testimony (paragraphs) related to the claim terms
`memory device, operative/operable to, portions,
`command threads, arbiter, and command processing
`engine, as improper expert testimony under FRE 203 and
`703, and C.F.R § 42.65, to the extent it is irrelevant, not
`helpful, reliable, or based on sufficient facts and not the
`product of reliable principles and methods and does not
`reflect a reliable application of the principles and methods
`to the facts of the case.
`
`Dated: April 12, 2024
`
` /Jeffrey L. Johnson/
`
`
`
`Jeffrey L. Johnson
`Reg. No. 53,078
`BAKER BOTTS, LLP
`910 Louisiana Street
`Houston, TX 77002-4995
`Telephone: 713-229-1234
`Facsimile: 713-229-1522
`Email: Jeffrey.Johnson@bakerbotts.com
` DLBBRealTEKIPRs@bakerbotts.com
`
`Christopher J. Higgins
`Reg. No. 66,422
`ORRICK, HERRINGTON & SUTCLIFFE LLP
`Columbia Center
`2100 Pennsylvania Avenue NW
`Washington, D.C. 20037
`Telephone: (202) 339-8400
`
`2
`
`
`
`Facsimile: (202) 339-8500
`Email: 0CHPTABDocket@orrick.com
`
`Steve Baik
`Reg. No. 42,281
`WHITE HAT LEGAL
`P. O. Box 382
`San Jose, CA 95002
`Telephone: (650) 618-5282
`Email: sbaik@whitehat.legal
`
`Counsel for Petitioner
`Realtek Semiconductor Corp.
`
`3
`
`
`
`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), I certify that on this 12th day of April, 2024,
`
`Petitioner’s Objections to Patent Owner’s Evidence Submitted With Patent
`
`Owner’s Response was served by email on the following counsel for Patent
`
`Owner:
`
`William A. Meunier
`wameunier@mintz.com
`
`Michael T. Renaud
`mtrenaud@mintz.com
`
`Adam S. Rizk
`arizk@mintz.com
`
`Reza Dokhanchy
`rdokhanchy@mintz.com
`
`AMD_IPRS@mintz.com
`
`Dated: April 12, 2024
`
`/Jeffrey L. Johnson/
`Jeffrey L. Johnson (Reg. No. 53,078)
`
`4
`
`
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