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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`MICROCHIP TECHNOLOGY INC.,
`Petitioner,
`v.
`
`APTIV TECHNOLOGIES AG,
`Patent Owner.
`
`
`Patent No. 11,176,072
`
`_______________
`Inter Partes Review No. IPR2024-00230
`____________________________________________________________
`PATENT OWNER’S OPPOSITION TO PETITIONER’S MOTION TO
`EXCLUDE EVIDENCE
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`
`
`IPR2024-00230
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`
`TABLE OF CONTENTS
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`
`
`Page
`
`I.
`
`B.
`C.
`
`DR. HOUH’S DECLARATIONS (EXS. 2001 AND 2019) SHOULD
`NOT BE EXCLUDED ................................................................................... 1
`A. Dr. Houh Rendered His Opinions From the Perspective of a
`POSITA ................................................................................................ 1
`Dr. Houh is a POSITA ......................................................................... 3
`Dr. Houh’s Secondary Considerations Testimony Should Not
`be Excluded .......................................................................................... 4
`PETITIONER’S OBJECTIONS TO EXHIBITS BEYOND DR.
`HOUH’S DECLARATION ARE UNGROUNDED ..................................... 6
`III. THE DISTRICT COURT TRIAL TESTIMONY (EXHIBITS 2002-
`2003, 2017, AND 2040-2043) SHOULD NOT BE EXCLUDED ................ 7
`IV. EXHIBITS 2005-2010 AND 2031-2035 SHOULD NOT BE
`EXCLUDED ................................................................................................... 9
`EXHIBITS 2024-2025 AND 2027-2028 SHOULD NOT BE
`EXCLUDED ................................................................................................. 12
`VI. EXHIBITS 2026, 2030, AND 2032 SHOULD NOT BE EXCLUDED ...... 12
`VII. EXHIBITS 2036-2039 SHOULD NOT BE EXCLUDED .......................... 13
`VIII. CONCLUSION ............................................................................................. 14
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`
`II.
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`V.
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`
`
`i
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`IPR2024-00230
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`TABLE OF AUTHORITIES
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`
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` Page(s)
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`Cases
`Abstrax, Inc. v. Dell, Inc.,
`No. 2:07-CV-221-DF, 2009 WL 10677355 (E.D. Tex. Oct. 9,
`2009) ..................................................................................................................... 9
`Apple Inc. v. DSS Tech. Mgmt., Inc.,
`IPR2015-00373, Paper 39 (June 17, 2016) ......................................................... 13
`Apple Inc. v. Samsung Elec. Co., Ltd.,
`816 F.3d 788 (Fed. Cir. 2016) ............................................................................. 9
`
`Ascend Performance Materials Operations LLC v. Samsung SDI Co.,
`Ltd.,
`IPR2020-00349, Paper 53 (PTAB July 15, 2021) ................................................ 4
`Braun Melsungen AG v. Terumo Med. Corp.,
`749 F.Supp.2d 210 (D. Del. 2010) ........................................................................ 5
`In re Hanford Nuclear Rsrv. Litig.,
`534 F.3d 986 (9th Cir. 2008) ................................................................................ 8
`Henny Penny Corp. v. Frymaster LLC,
`938 F.3d 1324 (Fed. Cir. 2019) .......................................................................... 13
`Leo Pharm. Prods., Ltd. v. Rea,
`726 F.3d 1346 (Fed. Cir. 2013) ...................................................................... 6, 11
`Nestlé Healthcare Nutrition, Inc. v. Steuben Foods, Inc.,
`IPR2015-00249, Paper 76 (PTAB June 2, 2016) ................................................. 4
`In re Rouffet,
`149 F.3d 1350 (Fed. Cir. 1998) ............................................................................ 6
`
`Vifor Fresenius Med. Care Renal Pharma Ltd. v. Lupin Atlantis
`Holdings SA,
`No. CV 18-390 (MN), 2020 WL 4699050 (D. Del. Aug. 13, 2020) .................... 5
`
`
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`ii
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`IPR2024-00230
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`In re WorldCom, Inc.,
`357 B.R. 223 (S.D.N.Y.2006) ............................................................................ 13
`Other Authorities
`Fed. R. Evid. 703 ..................................................................................................... 12
`Fed. R. Evid. 901(b)(1) ............................................................................................ 14
`Fed. R. Evid. 801(d)(2) .............................................................................................. 8
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`I.
`DR. HOUH’S DECLARATIONS (EXS. 2001 AND 2019) SHOULD
`NOT BE EXCLUDED
`Petitioner offers no basis for excluding any portion of Dr. Houh’s
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`declaration testimony—let alone the “entirety” of his two declarations. (Motion
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`(Papers Nos. 42, 43), 1.) The Motion is premised on Petitioner’s unduly narrow
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`proposal for the level of ordinary skill, which was rejected in the Institution
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`Decision. (DI (Paper 12), 8-10.) Petitioner does not dispute that the testimony
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`should not be excluded if the Board again rejects Petitioner’s proposed level of
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`skill. (Motion, 1-2 (“If the Board agrees …”)(emphasis added).) Moreover,
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`regardless of the level of skill, Petitioner’s concerns go to the weight of Dr. Houh’s
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`testimony—which the Board can readily evaluate—not to its admissibility.
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`Petitioner’s Motion as it relates to Dr. Houh’s testimony should therefore be
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`denied.
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`A. Dr. Houh Rendered His Opinions From the Perspective of a
`POSITA
`Petitioner argues that Dr. Houh’s declarations are “irrelevant,” and should be
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`excluded in their entirety, because Dr. Houh’s opinions applied the Patent Owner’s
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`(and the DI’s) version of the level of ordinary skill, rather than Petitioner’s overly
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`restrictive version. (Motion, 1-3.)
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`Patent Owner’s proposed level of skill is applicable here for the reasons set
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`forth in the POR and sur-reply. (POR (Paper 25), 3-5; Sur-Reply (Paper 40), 20-
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`21.) But even if the Board does not again adopt Patent Owner’s proposed level of
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`skill, it would not merit excluding Dr. Houh’s testimony, because the parties’
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`proposed levels of skill overlap substantially. As Petitioner put it: “little
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`difference exists between the parties’ definitions and the prior art analysis is
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`substantially the same.” (Reply (Paper 30), 3.) For example, as Petitioner
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`acknowledges, the parties “agree on education and that some education/work
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`experience can trade off,” and that either “several years” or “two years” of work
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`experience would be necessary. (Reply, 2-3.) There is no dispute that Dr. Houh’s
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`opinions are provided under these mutually agreed-upon POSITA qualifications.
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`(See EX2019, ¶¶26-30.)
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`While Petitioner proposes a more “granular” level of skill that presumes a
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`priori knowledge of specific USB documents and concepts, Reply at 3, Dr. Houh
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`testified that the Petitioner’s additional requirements are not reflective of the true
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`level of skill applicable to the patents. (EX1084, 95:14-96:11.) Moreover, Dr.
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`Houh testified (and Petitioner does not dispute) that a POSITA under either party’s
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`definition would have been able to review, understand, and apply the USB
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`standards and specifications as relevant to the challenged patent. (EX1084, 91:13-
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`92:14, 94:24-95:8, 100:17-103:19.) Thus, even if the Board were to adopt
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`Petitioner’s proposed level of skill, Dr. Houh’s testimony is still relevant and
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`probative. Any additional critique by Petitioner of Dr. Houh’s testimony would go
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`to the weight of the testimony, not its admissibility.
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`B.
` Dr. Houh is a POSITA
`Petitioner additionally argues that Dr. Houh’s declarations should be
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`excluded because Dr. Houh himself does not meet Petitioner’s specific proposed
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`level of ordinary skill. (Motion, 3-5.) Dr. Houh is a POSITA, and should not be
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`excluded on that basis, for reasons analogous to those described above. For
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`example, Patent Owner’s proposed level of skill is applicable, and was adopted by
`
`the Board in the Institution Decision; and Petitioner does not dispute that Dr. Houh
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`is a POSITA under at least that level of skill.
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`Dr. Houh also meets Petitioner’s proposed level of skill, at least because his
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`experiences and education provide him with the ability to understand and apply
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`USB standards and technologies. (EX1084, 79:22-80:19, 83:7-84:7, 100:20-
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`101:22.) Petitioner agreed that a “relevant advanced degree,” which certainly
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`includes Dr. Houh’s Ph.D. in networking, could substitute for specific work
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`experience to meet the level of ordinary skill. (Petition (Paper 1), 23.) Moreover,
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`Dr. Houh testified to his familiarity with USB concepts, and to the “high overlap”
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`between USB protocol concepts and other communications concepts and protocols,
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`such as networking protocols, which Dr. Houh is more specifically experienced
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`with. (EX1084, 83:7-88:12, 100:20-101:22.) Petitioner does not dispute Dr.
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`Houh’s testimony, or provide any reason why Dr. Houh’s education and
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`experience would render him incapable of understanding and applying USB
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`protocol concepts. (See EX1084, 83:7-88:12; EX2001, Exh. A; EX2019, ¶¶ 3-16.)
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`Regardless, the Board has recognized that “there need not be a perfect match
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`between the expert’s qualifications and the patent at issue.” Nestlé Healthcare
`
`Nutrition, Inc. v. Steuben Foods, Inc., IPR2015-00249, Paper 76 at 24 (PTAB June
`
`2, 2016) (citing SEB S.A. v. Montgomery Ward & Co., 594 F.3d 1360, 1373 (Fed.
`
`Cir. 2010)). And in any event, “the wholesale exclusion of a witness’s declarations
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`is rarely called for in a proceeding before the Board;” again, the Board can
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`consider Dr. Houh’s qualifications as appropriate in determining the weight to be
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`given his testimony. Ascend Performance Materials Operations LLC v. Samsung
`
`SDI Co., Ltd., IPR2020-00349, Paper 53 at 11 (PTAB July 15, 2021) (vacated on
`
`other grounds, Paper 57 (Nov. 1 2021)).
`
`C. Dr. Houh’s Secondary Considerations Testimony Should Not be
`Excluded
`Dr. Houh’s testimony on secondary considerations is both relevant and
`
`probative. Drawing on his experience and education in networking technologies,
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`see EX2019 at ¶¶3-16, Dr. Houh reviewed the record and offered detailed analysis
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`on several key issues: (1) the operation of Aptiv’s Dual Role Hub and its nexus to
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`the challenged claims; (2) the technical challenges introduced by CarPlay and
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`similar platforms, particularly in light of the technical requirements of the
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`functionality that automakers sought to implement; (3) the difficulties Microchip
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`and its engineers encountered in developing a workable solution; and (4) the
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`functionality of Microchip’s eventual CarPlay product and its clear parallels to
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`Aptiv’s design. Each of these topics bears directly on the secondary considerations
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`analysis. Dr. Houh’s opinions are especially valuable in clarifying the technical
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`record—much of which is couched in specialized terminology—particularly in
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`light of Petitioner’s own objections to the “jargon, acronyms, and shorthand” used
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`in the underlying documents. (Motion, 13).
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`Moreover, any risk of prejudice is minimal in this context, as the Board is
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`well-equipped to evaluate Dr. Houh’s testimony and assign it appropriate weight.
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`See e.g. Vifor Fresenius Med. Care Renal Pharma Ltd. v. Lupin Atlantis Holdings
`
`SA, No. CV 18-390 (MN), 2020 WL 4699050, at *3 (D. Del. Aug. 13, 2020)
`
`(Denying motion to exclude expert testimony regarding secondary considerations
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`in the context of a bench trial because “it is plain the Court can address with
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`minimal prejudice any assertion that a particular piece of testimony is outside an
`
`expert's area of expertise, [and] assess whether it supports the assertion that it
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`supports a finding that objective indicia undermine Plaintiffs’ obviousness
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`contention.”); Braun Melsungen AG v. Terumo Med. Corp., 749 F.Supp.2d 210,
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`223 (D. Del. 2010) (same).
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`II.
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`PETITIONER’S OBJECTIONS TO EXHIBITS BEYOND DR.
`HOUH’S DECLARATION ARE UNGROUNDED
`Petitioner’s remaining objections underscore its broader disregard for the
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`legal significance of secondary considerations in the obviousness inquiry.
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`Contrary to Petitioner’s characterization, these are not “collateral matters.” The
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`Federal Circuit has made clear that objective indicia are an integral component of
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`the obviousness analysis, not an afterthought. Leo Pharm. Prods., Ltd. v. Rea, 726
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`F.3d 1346, 1358 (Fed. Cir. 2013) (“[C]onsideration of the objective indicia is part
`
`of the whole obviousness analysis, not just an afterthought.”) (emphasis in
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`original). “Objective indicia of nonobviousness play a critical role in the
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`obviousness analysis” and “‘can be the most probative evidence of nonbviousness
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`in the record, [enabling] the court to avert the trap of hindsight.’” Id. at 1358
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`(quoting Crocs, Inc. v. Int’l Trade Comm’n, 598 F.3d 1294, 1310 (Fed. Cir. 2010)).
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`These indicia include, among others, copying, long-felt but unmet need, failure of
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`others, commercial success, unexpected results, industry licensing, and pre-
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`invention skepticism. See In re Rouffet, 149 F.3d 1350, 1355 (Fed. Cir. 1998).
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`Each of the exhibits to which Petitioner objects bears directly on nexus or one or
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`more of these well-established objective indicia and is therefore plainly relevant to
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`the secondary considerations analysis.
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`Petitioner’s repeated contention that CarPlay is irrelevant is likewise entirely
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`unfounded. As demonstrated by the very evidence to which Petitioner objects,
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`automakers’ requirements for a viable CarPlay solution were the motivating factor
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`behind the development of the claimed invention, the factor that motivated others
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`to try and fail to develop a solution, the reason for the success of Patent Owner’s
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`embodying product, and the reason Petitioner itself chose to copy Patent Owner’s
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`embodying product. (POR, 54-72.) Indeed, the specification describes CarPlay in
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`all but name: “Recently, the system level design thinking has shifted towards
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`viewing smart phones as the USB Host, and any device connecting thereto as the
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`USB Device. . . . This presents some problems for automotive systems. . . .
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`Automotive manufacturers desire compatibility with smart phones and are
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`therefore motivated to adapt to this changing technology. A redesign of the USB
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`architecture in the vehicle is thus necessary such that the vehicle can act either as
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`the USB Host . . . or USB Device . . . .” ’072 Patent at 2:65-3:20.
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`III. THE DISTRICT COURT TRIAL TESTIMONY (EXHIBITS 2002-
`2003, 2017, AND 2040-2043) SHOULD NOT BE EXCLUDED
`Petitioner’s general objections—based on relevance, prejudice, foundation,
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`and hearsay—to testimony from the prior trial are unfounded. Petitioner was a
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`party to that trial, represented by experienced counsel, and had a full and fair
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`opportunity to object to the introduction of any evidence and to cross-examine any
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`witnesses providing testimony. The testimony is offered here for the same
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`purposes as at trial: (1) to show the operation of Aptiv’s Boston 2 chip, which was
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`accused of infringement; (2) to establish the technical and commercial context
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`motivating the chip’s development, a key aspect of Aptiv’s noninfringement
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`defense; (3) to document Microchip’s failed attempts to create a viable CarPlay
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`product, which supported Aptiv’s case; and (4) to demonstrate the commercial
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`success of the Boston 2 chip, which underpinned Petitioner’s own damages theory.
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`Petitioner’s objections to the prior trial transcripts are both meritless and
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`internally inconsistent. Petitioner simultaneously claims the testimony lacks
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`sufficient context and that it is too burdensome to contextualize. (Mot. at 8.). In
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`reality, Patent Owner has cited specific, narrowly tailored portions of the trial
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`record addressing discrete issues relevant to this proceeding. These excerpts are
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`self-contained and require no additional context to be understood. But to the
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`extent Petitioner believed further context was required, Petitioner—having been a
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`party to the prior trial and having cross-examined each of the witnesses—was
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`equally well-positioned to supply it. The record was complete and accessible to
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`both parties.
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`Petitioner’s hearsay objections are likewise unavailing. By presenting the
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`testimony of its experts, Dr. Zatkovich and Stephen Becker, at trial and repeatedly
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`relying on that testimony during closing argument, Petitioner adopted those
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`statements as its own. As such, the testimony—which Aptiv now offers against
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`Microchip—qualifies as an admission by a party-opponent and falls outside the
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`definition of hearsay under Federal Rule of Evidence 801(d)(2). See e.g., In re
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`8
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`Hanford Nuclear Rsrv. Litig., 534 F.3d 986, 1016 (9th Cir. 2008) (“Dr. Hoffman's
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`testimony at the first bellwether trial was an admission of a party opponent under
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`Federal Rule of Evidence 801(d)(2)(C). . . . Plaintiff cannot now exclude trial
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`testimony that she, herself, proffered.” (citation omitted)); Abstrax, Inc. v. Dell,
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`Inc., No. 2:07-CV-221-DF, 2009 WL 10677355, at *1 (E.D. Tex. Oct. 9, 2009)
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`(“[T]he statements made by [defendant's] expert in the Lucent litigation are not
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`hearsay. They are admissions.”)
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`IV. EXHIBITS 2005-2010 AND 2031-2035 SHOULD NOT BE EXCLUDED
`Petitioner also objects to internal Microchip communications that show that
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`its engineers struggled to comprehend Aptiv’s solution and were unable to devise a
`
`viable alternative that met automakers’ technical requirements. These
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`communications bear on additional objective indicia, including the failure of others
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`and skepticism by skilled artisans. See Apple Inc. v. Samsung Elec. Co., Ltd., 816
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`F.3d 788, 805 (Fed. Cir. 2016) (“[E]xpression of disbelief by experts and then later
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`acquiescence to the invention may be strong evidence of nonobviousness.”)
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`(vacated in part on other grounds, 839 F.3d 1034 (Fed. Cir. 2016)).
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`Petitioner argues that the individuals expressing skepticism were not
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`engineers and were therefore irrelevant. This assertion is false. Most of these
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`individuals were, in fact, engineers with substantial experience. Brigham Steele,
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`an electrical engineer with a decade of post-degree experience1, stated that
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`automakers’ demands “may be physically outside the capabilities of ANY USB
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`system” (EX2005, 1-2); Chris Behal, an engineer with nearly two decades of post-
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`degree experience2, advised customers that while non-data, charging-only ports
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`were feasible, “we saw no way for [data connectivity] to actually work.” (EX2006,
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`2). He also noted that “the OEM’s do not have a good understanding of what is
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`possible with CarPlay… all they know is they want CarPlay AND they want
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`additional connectivity to [the] head unit [and] other devices.” (Id.) Dave Sroka,
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`an engineer (EX2040 at 245:12-17) and a contributor to the USB 3.1 standard3,
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`acknowledged that “[w]hen persistent USB is a requirement, we definitely have
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`run into a wall.” (EX2007, 1).
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`Even if some of those included on these email threads were not engineers,
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`the documents themselves remain relevant because Microchip employed roughly
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`2,000 engineers in its wired connectivity group alone and controlled nearly 100%
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`of the U.S. market for automotive USB hub chips. EX2040 at 195:3-21; 212:2-6.
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`Given the clear customer demand and sustained frustration from its sales unit over
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`1 See Patent Owner Response, 68 n. 4.
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`2 https://www.linkedin.com/in/chris-behal-2b7582a/details/experience/
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`3 See https://manuais.iessanclemente.net/images/b/bc/USB_3_1_r1.0.pdf at iv.
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`the course of a year, it defies logic that Microchip would simply allow tens of
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`millions of dollars in sales to slip away without exploring a viable solution.
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`Microchip’s argument that real-world individuals cannot substitute for the
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`hypothetical POSITA is likewise unfounded—and necessarily so—as it would
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`render the entire objective indicia inquiry meaningless. Objective indicia exist
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`precisely to serve as a real-world check on the obviousness analysis and to “avert
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`the trap of hindsight.” Leo Pharm. Prods., 726 F.3d at 1358 (quoting Crocs, 598
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`F.3d at 1310). Requiring skepticism or failure from a hypothetical individual—a
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`person who by definition does not actually exist—sets an impossible bar for this
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`real-world inquiry.
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`Microchip’s assertion that these emails are misleading because Apple would
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`not permit a bridge is equally baseless. The email on which it relies—a marketer’s
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`summary of a meeting with Apple—states only that Apple desires a “‘direct path’
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`to the head unit.” EX1100. The use of a USB bridge provides just such a “direct
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`path” because the bridge does not provide any USB function, but instead merely
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`enables a direct host-to-host connection between the consumer device and the head
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`unit.
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`Ultimately, evidence demonstrating that individuals at Microchip—the
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`largest provider of automotive USB hub chips by far—specifically tasked with
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`designing and selling automotive USB hub chips were unable to design chips to
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`meet automakers’ requirements and were skeptical that it was possible is almost
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`uniquely probative of the issues for which it is offered.
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`V. EXHIBITS 2024-2025 AND 2027-2028 SHOULD NOT BE EXCLUDED
`Microchip’s objections to Exhibits EX2024–2025 and EX2027–2028—on
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`grounds of relevance, incompleteness, and alleged risk of confusion—are
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`unfounded. These documents directly reflect the operation of Aptiv’s Boston 2
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`chip and are central to establishing nexus, a critical element of the secondary
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`considerations analysis. Separately, the documents were reviewed by Dr. Houh
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`and informed his nexus opinions. It is well-established that experts may rely on
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`materials in forming their opinions regardless of whether those materials are
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`themselves admissible. See Fed. R. Evid. 703 (“If experts in the particular field
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`would reasonably rely on those kinds of facts or data in forming an opinion on the
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`subject, they need not be admissible for the opinion to be admitted.”). There is no
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`basis for excluding these exhibits.
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`VI. EXHIBITS 2026, 2030, AND 2032 SHOULD NOT BE EXCLUDED
`Petitioner’s objections to Exhibits EX2026 and EX2030—internal
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`Microchip product documents—are misplaced. These documents are highly
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`probative of Microchip’s repeated efforts to replicate Aptiv’s successful product
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`and are directly relevant to copying, a well-recognized objective indicium of non-
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`obviousness. Similarly, Exhibit EX2032 (addressed separately above) confirms
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`that Microchip initiated its development efforts with the specific intent to emulate
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`Aptiv’s design, based on its understanding of Aptiv’s implementation at the time,
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`and therefore relates directly to Microchip’s copying. Each document therefore
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`certainly meets the “‘low threshold for relevancy.’” Apple Inc. v. DSS Tech.
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`Mgmt., Inc., IPR2015-00373, Paper 39 at 36 (June 17, 2016) (quoting OddzOn
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`Prods., Inc. v. Just Toys, Inc., 122 F.3d 1396, 1406-07 (Fed. Cir. 1997)).
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`VII. EXHIBITS 2036-2039 SHOULD NOT BE EXCLUDED
`With its objections to the declaration of Michael Dreon and its
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`accompanying exhibits, Petitioner again reveals its fundamental misunderstanding
`
`of the secondary considerations inquiry. Evidence related to the PACE award is
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`direct evidence of praise for Aptiv’s solution based specifically on the very
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`innovation that is the subject of the challenged claims. This is prototypical
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`evidence of the objective indicia of industry praise. See e.g., Henny Penny Corp.
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`v. Frymaster LLC, 938 F.3d 1324, 1333 (Fed. Cir. 2019) (crediting award from the
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`National Restaurant Association for a claimed oil quality sensor).
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`In his declaration, Mr. Dreon provided several attachments related to Aptiv’s
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`receipt of the PACE award and authenticated them based on his personal
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`knowledge. He specifically confirmed that Exhibits B and C—the judges’ citation
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`and the awards ceremony video—accurately represent what they purport to be.
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`This testimony is sufficient to establish both foundation and authentication. In re
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`WorldCom, Inc., 357 B.R. 223, 228 (S.D.N.Y.2006) (to authenticate a document, a
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`witness with personal knowledge to that effect need only testify “that the document
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`is what it purports to be.”); see also Fed.R.Evid. 901(b)(1) (permitting
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`authentication by testimony of a witness with knowledge “that a matter is what it is
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`claimed to be”). Petitioner chose not to depose Mr. Dreon to challenge his
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`statements or inquire further, and cannot now challenge the accuracy of his
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`testimony.
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`Petitioner’s hearsay objections are likewise without merit. Aptiv does not
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`offer Exhibits 2038 and 2039 for the truth of any statements describing how the
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`Dual Role Hub operates—Dr. Houh’s analysis of other Aptiv documents provides
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`that support. Instead, the exhibits are submitted for the non-hearsay purpose of
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`showing the public rationale given for awarding the PACE prize to Aptiv’s
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`product. This evidence is directly relevant to the nexus analysis, as it demonstrates
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`industry recognition and praise tied to the claimed invention.
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`VIII. CONCLUSION
`For the foregoing reasons, Patent Owner respectfully requests that the Board
`
`deny Petitioner’s Motion to Exclude.
`
`14
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`
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`IPR2024-00230
`
`Dated: March 31, 2025
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`
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`
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`
`
`
`
`
`
`By /Adam R. Brausa/
`Adam R. Brausa Reg. No. 60,287
`MORRISON & FOERSTER LLP
`425 Market Street
`San Francisco, CA 94105
`Email: ABrausa@mofo.com
`Tel: 415-268-6053
`
`Counsel for Patent Owner
`
`
`
`15
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`
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`IPR2024-00230
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`
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`
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`Certificate of Service (37 C.F.R. § 42.6(e)(4))
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`I hereby certify that the attached PATENT OWNER’S OPPOSITION TO
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`PETITIONER’S MOTION TO EXCLUDE EVIDENCE was served on the below
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`date via e-mail (by consent) to the following counsel of record for the Petitioner:
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`Travis Jensen (Registration No. 60,087)
`tjensen@orrick.com
`T61PTABDocket@orrick.com
`Jeremy Jason Lang (Registration No. 73,604)
`jlang@orrick.com
`PTABDocketJJL2@orrick.com
`Orrick, Herrington & Sutcliffe LLP
`1000 Marsh Road
`Menlo Park, CA 94025-1015
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`
`
`Dated: March 31, 2025
`
`/Andrew T. Jones/
`Andrew T. Jones
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`
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`16
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