In Sony Corporation v Tessera, Inc., IPR2012-000333, Paper 13, (January 22, 2013) that PTAB denied Sony leave to file two Tessera-authored documents from the parties pending litigation, although Tessera questioned their relevance, it did not expressly object to their filing.  The PTAB did not see the relevance to whether a proceeding should be instituted, but did indicate that Sony could submit the documents if and when the trial was instituted.