U.S. Patent No. 7,518,879
`
`PNY Technologies, Inc.
`Petitioner
`v.
`Phison Electronics Corp.
`Patent Owner
`
`Oral Hearing
`November 12, 2014
`
`Slide 1 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150)
`
`
`
`PNY Technologies, Inc.
`Petitioner
`v.
`Phison Electronics Corp.
`Patent Owner
`
`Oral Hearing
`November 12, 2014
`
`Slide 1 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150)
`
`
`
`Introduction
`
`2
`
`A. Overview of the ‘879 Patent
`
`B. The Board Properly Construed the Terms:
`“Concave”
`
`I.
`
`II. “Prop”
`
`III. “Fixed”
`
`C. The Rejections based on Minneman are Proper
`
`I. Minneman in view of Takahashi (Claims 1-4,8-12, and 16)
`
`D. The Rejections based on Elbaz are Proper
`I. Elbaz in view of Deng (Claims 1,3-9, and 11-21)
`
`II. Elbaz in view of Deng and AAPA (Claims 2 and 10)
`
`Slide 2 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`
`Overview of the ‘879 Patent
`
`3
`
`Fig. 5
`
`Fig. 6
`
`Total Claims: 21
`
`Independent Claims: 1, 9, & 17
`- See ‘879 Patent (Exh. 1001), FIGS. 5-6 and Cover Page
`
`Slide 3 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`
`Overview of the ‘879 Patent
`
`4
`
`- See ‘879 Patent (Exh. 1001), 6:8-18
`
`Slide 4 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`
`Overview of the ‘879 Patent
`
`5
`
`- See ‘879 Patent (Exh. 1001), 6:48-53
`
`Slide 5 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`
`Overview of the ‘879 Patent
`
`6
`
`- See ‘879 Patent (Exh. 1001), 7:18-8:4
`
`Slide 6 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`
`Overview of the ‘879 Patent
`
`7
`
`Dependent Claims
`
`Features
`
`Housing = Metallic Conductive Material
`
`PCBA = Memory Controller + Storage Memory + USB Interface Circuit + IC Package
`
`Storage Memory = Flash or EEPROM
`
`LED Indicator
`
`LED Module Controller
`
`Opening in Housing for LED
`
`Concave Props Support PCBA to Form Space Between Housing and PCBA
`
`LED Module Projects from IC Package
`
`Claim Nos.
`
`2, 10
`
`3, 11, 20
`
`4, 12
`
`5, 13
`
`6, 14
`
`7, 15, 18
`
`8, 16, 19
`
`21
`
`- See ‘879 Patent (Exh. 1001), 6:19-8:24
`
`Slide 7 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`
`The Board Properly Construed
`the Term “Concave”
`
`8
`
`(cid:1) The Board construed the term
`“Concave” as “Curving Inwards from
`a Housing”
`
`- See Decision – Institution of Inter Partes Review (Paper No. 10, p. 7 in
`IPR2013-00472) (“First Decision”); see also Decision - Institution of Inter
`Partes Review (Paper No. 8, pp. 6-8 in IPR2014-00150) (“Second
`Decision”)
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`Slide 8 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
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`The Board Properly Construed
`the Term “Concave”
`
`9
`
`(cid:1) Specification Supports This Construction
`A. Figure 6, Concave Props 512 and Housing 51
`
`Concave Props
`
`- See ‘879 Patent (Exh. 1001),
`FIG. 6
`
`Slide 9 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`The Board Properly Construed
`the Term “Concave”
`
`10
`
`(cid:1) Specification Supports This Construction
`B. Col. 4, lines 28-32:
`
`- See ‘879 Patent (Exh. 1001), 4:28-32
`
`Slide 10 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`The Board Properly Construed
`the Term “Concave”
`
`11
`
`(cid:1) A Recess is Not Required
`A. Nowhere is a “Recess” Discussed in the ‘879 Patent
`
`B. A “Recess” Does Not Support Anything – The Props
`Do
`
`C. Patent Owner’s Dictionary Does Not Use the Term
`“Recess” in Defining “Concave”
`“hollow and curved like the inside half of a hollow ball”
`
`1.
`
`- See Petitioner’s Reply (Paper No. 29) at pp. 2-3; Exh.
`2010, p. 287; Second Decision at p. 7
`
`Slide 11 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`The Board Properly Construed
`the Term “Props”
`
`12
`
`(cid:1) The Board Construed the Term “Props”
`as “A Structure That Supports”
`
`- See First Decision, pp. 7-8; see also Second Decision, pp. 7-8
`
`Slide 12 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`
`The Board Properly Construed
`the Term “Props”
`
`13
`
`(cid:1) Specification Supports This Construction
`A. Figure 6, Concave Props 512, PCBA 52, and End Base
`54
`
`Concave Props
`
`PCBA
`
`End Base
`
`- See ‘879 Patent (Exh. 1001),
`FIG. 6
`
`Slide 13 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`The Board Properly Construed
`the Term “Props”
`
`14
`
`(cid:1) Patent Owner Admits That Props
`Function as Supports
`(cid:1) “although Patent Owner agrees that a proper
`construction of ‘prop’ must include at least ‘a
`structure that supports…’”
`
`- See Patent Owner Response (Paper No. 24
`in IPR2013-00472), p. 19 (emphasis added)
`
`Slide 14 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`The Board Properly Construed
`the Term “Fixed”
`
`15
`
`(cid:1) The Board Construed the Term “Fixed” as
`“Fastened Securely in Position”
`
`- See Second Decision, p. 8
`
`(cid:1) Specification Does Not Say Fixed in All
`Degrees of Freedom
`
`- See Second Decision, p. 15
`
`Slide 15 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`The Board Properly Construed
`the Term “Fixed”
`
`16
`
`(cid:1) Patent Owner’s Expert Admitted That
`Something Can Be Secured in Position, But
`Free to Move
`
`- See Transcript of Deposition of Steven Visser (Exhibit 1008), 78:18-79:10
`
`Slide 16 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`The Rejections Based on
`Minneman are Proper
`
`17
`
`- See Minneman (Exh. 1003), FIGS. 3-4 and Cover
`Page
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150)
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`Slide 17 of 66
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`
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`Claim 1 is Obvious over Minneman
`in view of Takahashi
`
`18
`
`Claim 1
`
`Minneman
`
`- See ‘879 Patent at 6:8-18; see also Minneman (Exh. 1003), FIGS. 3-4, 6-8, 9:65-10:6,
`10:48-61; Petition in IPR2013-00472 (“First Petition”) at p. 15
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`Slide 18 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`Claim 1 is Obvious over Minneman
`in view of Takahashi
`
`19
`
`Claim 1
`
`Minneman
`
`- See ‘879 Patent at 6:8-18; see also Minneman (Exh. 1003), FIGS. 3-4, 6-8, 9:65-10:6,
`10:48-61; First Petition at p. 15
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`Slide 19 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`Claim 1 is Obvious over Minneman
`in view of Takahashi
`
`20
`
`Claim 1
`
`Minneman
`
`- See ‘879 Patent at 6:8-18; see also Minneman (Exh. 1003), FIGS. 3-4, 6-8, 9:65-10:6,
`10:48-61; First Petition at p. 15
`
`Slide 20 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`Claim 1 is Obvious over Minneman
`in view of Takahashi
`
`21
`
`Claim 1
`
`Minneman
`
`- See ‘879 Patent at 6:8-18; see also Minneman (Exh. 1003), 9:65-10:6; First Petition at
`p. 15
`
`Slide 21 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`Claim 1 is Obvious over Minneman
`in view of Takahashi
`
`22
`
`Claim 1
`
`Minneman
`
`- See ‘879 Patent at 6:8-18; see also Minneman (Exh. 1003), FIGS. 3-4, 6-8, 10:11-31,
`10:39-41; First Petition at p. 15
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`Slide 22 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`Claim 1 is Obvious over Minneman
`in view of Takahashi
`
`23
`
`Claim 1
`
`Minneman
`
`- See ‘879 Patent at 6:8-18; see also Minneman (Exh. 1003), 10:52-61; First Petition at
`p. 16; Petitioner’s Reply (Paper No. 29) at pp. 10-11
`
`Slide 23 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`Claim 1 is Obvious over Minneman
`in view of Takahashi
`
`24
`
`Claim 1
`
`Minneman
`
`- See ‘879 Patent at 6:8-18; see also Minneman (Exh. 1003), FIGS. 3-4 and 6-8; First
`Petition at p. 16
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`Slide 24 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`Claim 1 is Obvious over Minneman
`in view of Takahashi
`
`25
`
`Claim 1
`
`Takahashi
`
`- See ‘879 Patent at 6:8-18; see also Takahashi (Exh. 1006), FIGS. 20A-20B, ¶¶ 0159-
`0162; First Petition at p. 15; Petitioner’s Reply at pp. 8-9
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`Slide 25 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150)
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`
`Claim 9 is Obvious over Minneman
`in view of Takahashi
`
`26
`
`Claim 9
`
`Minneman
`
`- See ‘879 Patent at 6:48-53; see also Minneman (Exh. 1003), FIGS. 3-4, 6-8, 10:11-31,
`10:39-41; First Petition at pp. 18-19
`
`Slide 26 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`Claim 9 is Obvious over Minneman
`in view of Takahashi
`
`27
`
`Claim 9
`
`Minneman
`
`- See ‘879 Patent at 6:48-53; see also Minneman (Exh. 1003), FIGS. 3-4, 6-8, 9:65-10:6,
`10:48-61; First Petition at p. 19
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`Slide 27 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`Claim 9 is Obvious over Minneman
`in view of Takahashi
`
`28
`
`Claim 9
`
`Minneman
`
`- See ‘879 Patent at 6:48-53; see also Minneman (Exh. 1003), FIGS. 3-4, 6-8, 9:65-10:6,
`10:48-61; First Petition at p. 19
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`Slide 28 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`Claim 9 is Obvious over Minneman
`in view of Takahashi
`
`29
`
`Claim 9
`
`Minneman
`
`- See ‘879 Patent at 6:48-53; see also Minneman (Exh. 1003), FIGS. 3-4, 6-8, 10:11-31,
`10:39-41; First Petition at p. 19
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`Slide 29 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`
`Claim 9 is Obvious over Minneman
`in view of Takahashi
`
`30
`
`Claim 9
`
`Minneman
`
`- See ‘879 Patent at 6:48-53; see also Minneman (Exh. 1003), FIGS. 3-4, 6-8, 10:48-61;
`First Petition at p. 20; Petitioner’s Reply (Paper No. 29) at pp. 10-11
`
`10:52 – 10:61
`
`Slide 30 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`Claim 9 is Obvious over Minneman
`in view of Takahashi
`
`31
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`Claim 9
`
`Minneman
`
`- See ‘879 Patent at 6:48-53; see also Minneman (Exh. 1003), FIGS. 3-4, 6-8; First
`Petition at p. 20
`
`Slide 31 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`Claim 9 is Obvious over Minneman
`in view of Takahashi
`
`32
`
`Claim 9
`
`Takahashi
`
`- See ‘879 Patent at 6:48-53; see also Takahashi (Exh. 1006), FIGS. 20A-20B, ¶¶ 0159-
`0162; First Petition at p. 19; Petitioner’s Reply at pp. 8-9
`
`Slide 32 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`
`
`The Rejections Based on
`Elbaz are Proper
`
`33
`
`- See Elbaz (Exh. 1003), FIGS. 10A-10C and Cover
`Page
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
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`Slide 33 of 66
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`
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`Claim 1 is Obvious over Elbaz in
`view of Deng
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`34
`
`Claim 1
`
`Elbaz
`
`- See ‘879 Patent at 6:8-18; see also Elbaz (Exh. 1003), FIGS. 7a-7c, 10a-10b, ¶¶ 48,
`49, 54, 63; Petition in IPR2014-00150 (“Second Petition”) at p. 24
`
`Slide 34 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`
`Claim 1 is Obvious over Elbaz in
`view of Deng
`
`35
`
`Claim 1
`
`Elbaz
`
`- See ‘879 Patent at 6:8-18; see also Elbaz (Exh. 1003), FIGS. 7a-7c, 10a-10b, ¶¶ 48,
`49, 54, 63; Second Petition at p. 24
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`Slide 35 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`Claim 1 is Obvious over Elbaz in
`view of Deng
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`36
`
`Claim 1
`
`Elbaz
`
`- See ‘879 Patent at 6:8-18; see also Elbaz (Exh. 1003), FIGS. 7a-7c, 10a-10b, ¶¶ 48,
`49, 54, 63; Second Petition at p. 24; Petitioner’s Reply at pp. 12-13
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`Slide 36 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`
`Claim 1 is Obvious over Elbaz in
`view of Deng
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`37
`
`Claim 1
`
`Elbaz
`
`- See ‘879 Patent at 6:8-18; see also Elbaz (Exh. 1003), ¶¶ 47, 48, and 63; Second
`Petition at p. 25
`
`Slide 37 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`Claim 1 is Obvious over Elbaz in
`view of Deng
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`38
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`Claim 1
`
`Elbaz
`
`- See ‘879 Patent at 6:8-18; see also Elbaz (Exh. 1003), FIGS. 10a-10c, ¶¶ 11, 15;
`Second Petition at p. 25
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`Slide 38 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`Claim 1 is Obvious over Elbaz in
`view of Deng
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`39
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`Claim 1
`
`Elbaz
`
`- See ‘879 Patent at 6:8-18; see also Elbaz (Exh. 1003),
`FIGS. 10a-10c, ¶ 60; Second Petition at p. 25;
`Petitioner’s Reply at pp. 13-14
`Slide 39 of 66
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`Petitioner’s Exhibit 1009
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`Claim 1 is Obvious over Elbaz in
`view of Deng
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`40
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`Claim 1
`
`Elbaz
`
`- See ‘879 Patent at 6:8-18; see also Elbaz (Exh. 1003), FIG. 10c; Second Petition at p.
`25
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`Slide 40 of 66
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`Petitioner’s Exhibit 1009
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`Claim 1 is Obvious over Elbaz in
`view of Deng
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`41
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`Claim 1
`
`Deng
`
`7:9-15
`
`- See ‘879 Patent at 6:8-18; see also Deng (Exh. 1004), Abstract, FIGS. 1-3; 6:66-7:37;
`Second Petition at p. 24
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`Slide 41 of 66
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`Petitioner’s Exhibit 1009
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`Claim 1 is Obvious over Elbaz in
`view of Deng
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`42
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`Claim 1
`
`Deng
`
`- See ‘879 Patent at 6:8-18; see also Deng (Exh. 1004), FIG. 2; 6:66-7:5; Second
`Petition at p. 25
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`Slide 42 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`Claim 1 is Obvious over Elbaz in
`view of Deng
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`43
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`Claim 1
`
`Deng
`
`7:9-15
`
`- See ‘879 Patent at 6:8-18; see also Deng (Exh. 1004), FIG. 2; 6:66-7:5; Second
`Petition at p. 25
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`Slide 43 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`Claim 9 is Obvious over Elbaz in
`view of Deng
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`44
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`Claim 9
`
`Elbaz
`
`- See ‘879 Patent at 6:48-53; see also Elbaz (Exh. 1003), FIGS. 7a-7c, 10a-10c, ¶¶ 48,
`49, 54, 63; Second Petition at p. 29
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`Slide 44 of 66
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`Petitioner’s Exhibit 1009
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`Claim 9 is Obvious over Elbaz in
`view of Deng
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`45
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`Claim 9
`
`Elbaz
`
`- See ‘879 Patent at 6:48-53; see also Elbaz (Exh. 1003), FIGS. 10a-10c, ¶ 61; Second
`Petition at pp. 29-30; Petitioner’s Reply at pp. 12-13
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`Slide 45 of 66
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`Petitioner’s Exhibit 1009
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`Claim 9 is Obvious over Elbaz in
`view of Deng
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`46
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`Claim 9
`
`Elbaz
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`- See ‘879 Patent at 6:48-53; see also Elbaz (Exh. 1003), FIGS. 10a-10c; Second
`Petition at p. 30
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`Slide 46 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`Claim 9 is Obvious over Elbaz in
`view of Deng
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`47
`
`Claim 9
`
`Elbaz
`
`- See ‘879 Patent at 6:48-53; see also Elbaz
`(Exh. 1003), FIGS. 10a-10c, ¶¶ 60, 61; Second
`Petition at p. 30; Petitioner’s Reply at pp. 13-14
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`Slide 47 of 66
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`Claim 9 is Obvious over Elbaz in
`view of Deng
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`48
`
`Claim 9
`
`Elbaz
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`- See ‘879 Patent at 6:48-53; see also Elbaz (Exh. 1003), FIGS. 10a-10c, ¶ 60; Second
`Petition at p. 30
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`Slide 48 of 66
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`Petitioner’s Exhibit 1009
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`Claim 9 is Obvious over Elbaz in
`view of Deng
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`49
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`Claim 9
`
`Deng
`
`7:9-15
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`- See ‘879 Patent at 6:48-53; see also Deng (Exh. 1004), Abstract; FIGS. 1-3; 6:66-7:37;
`Second Petition at p. 29
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`Slide 49 of 66
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`Petitioner’s Exhibit 1009
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`Claim 9 is Obvious over Elbaz in
`view of Deng
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`50
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`Claim 9
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`Deng
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`7:9-15
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`- See ‘879 Patent at 6:48-53; see also Deng (Exh. 1004), FIG. 2; 6:66-7:5; Second
`Petition at p. 29
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`Slide 50 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
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`Claim 9 is Obvious over Elbaz in
`view of Deng
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`51
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`Claim 9
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`Deng
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`7:9-15
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`- See ‘879 Patent at 6:48-53; see also Deng (Exh. 1004), FIG. 2; 6:66-7:5; Second
`Petition at pp. 29-30
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`Slide 51 of 66
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`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`52
`
`Claim 17
`
`Elbaz
`
`- See ‘879 Patent at 7:18-8:4; see also Elbaz (Exh. 1003), FIGS. 7a-7c, 10a-10c, ¶¶ 48,
`49, 54, 63; Second Petition at p. 34
`
`Slide 52 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`53
`
`Claim 17
`
`Elbaz
`
`- See ‘879 Patent at 7:18-8:4; see also Elbaz (Exh. 1003), FIGS. 7a-7c, 10a-10c, ¶¶ 48,
`49, 54, 63 ; Second Petition at p. 34
`
`Slide 53 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`54
`
`Claim 17
`
`Elbaz
`
`- See ‘879 Patent at 7:18-8:4; see also Elbaz (Exh. 1003), FIGS. 10a-10c, ¶ 61; Second
`Petition at p. 34; Petitioner’s Reply at pp. 12-13
`
`Slide 54 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`55
`
`Claim 17
`
`Elbaz
`
`- See ‘879 Patent at 7:18-8:4; see also Elbaz
`(Exh. 1003), ¶¶ 47, 48, and 63; Second Petition
`at pp. 34-35
`
`Slide 55 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`56
`
`Claim 17
`
`Elbaz
`
`- See ‘879 Patent at 7:18-8:4; see also Elbaz (Exh. 1003), FIGS. 10a-10c, ¶¶ 11, 15;
`Second Petition at p. 35
`
`Slide 56 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`57
`
`Claim 17
`
`Elbaz
`
`- See ‘879 Patent at 7:18-8:4; see also
`Elbaz (Exh. 1003), FIGS. 10a-10c, ¶ 60;
`Second Petition at p. 35; Petitioner’s
`Reply at pp. 13-14
`
`Slide 57 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`58
`
`Claim 17
`
`Elbaz
`
`- See ‘879 Patent at 7:18-8:4; see also Elbaz (Exh. 1003), FIGS. 10a-10c, Second
`Petition at p. 35
`
`Slide 58 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`59
`
`Claim 17
`
`Deng
`
`7:9 - 15
`
`- See ‘879 Patent at 7:18-8:4; see also Deng (Exh. 1004), Abstract, FIGS. 1-3, 6:66-
`7:37; Second Petition at pp. 33-34
`
`Slide 59 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`60
`
`Claim 17
`
`Deng
`
`- See ‘879 Patent at 7:18-8:4; see also Deng (Exh. 1004), FIG. 2, 6:66-7:5; Second
`Petition at p. 34
`
`Slide 60 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`61
`
`Claim 17
`
`Deng
`
`- See ‘879 Patent at 7:18-8:4; see also Deng (Exh. 1004), FIG. 2, 6:66-7:5; Second
`Petition at p. 35
`
`Slide 61 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`62
`
`Claim 17
`
`Deng
`
`8:5 - 8
`
`13:49 - 52
`
`- See ‘879 Patent at 7:18-8:4; see also Deng (Exh. 1004), FIG. 6, 8:5-8, 13:49-52;
`Second Petition at p. 35
`
`Slide 62 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Claim 17 is Obvious over Elbaz in
`view of Deng
`
`63
`
`Claim 17
`
`Deng
`
`7:18 - 24
`
`- See ‘879 Patent at 7:18-8:4; see also Deng (Exh. 1004), FIGS. 3, 6; 7:9-31, 8:5-8;
`13:49-52; Second Petition at p. 35
`
`Slide 63 of 66
`
`Petitioner’s Exhibit 1009
`IPR2013-00472
`(consolidated with IPR2014-00150))
`
`
`
`Dependent Claims
`
`64
`
`(cid:2) Patent Owner has not independently argued the
`patentability of any dependent claims of the ‘879 Patent,
`i.e., Claims 2-8, 10-16, and 18-21, in the proceeding.
`
`(cid:2) As such, Petitioner does not believe that it is necessary
`to now present further arguments against the dependent
`claims.
`
`(cid:2) Petitioner respectfully references the First Petition and
`the Second Petition, which fully demonstrate that the
`dependent claims are not patentable and were known in
`the art at the time of filing of the ‘879 Patent. See First
`Petition, pp. 14-22; Second Petition, pp. 20-39.
`
`Slide 64 of 66
`
`
`
`It is Obvious to Combine
`Minneman with Takahashi
`
`65
`
`(cid:2) It would have been obvious to a person of
`ordinary skill in the art to modify the shape of
`the stand-offs 45 in Minneman so that they
`would be curved (concave), as taught by
`Takahashi.
`
`(cid:2) The concave shape is a matter of choice that a
`person of ordinary skill in the art would have
`found to be obvious.
`
`(cid:2) See First Petition, p. 14;
`Petitioner’s Reply, p. 8.
`
`Slide 65 of 66
`
`
`
`It is Obvious to Combine Elbaz
`with Deng
`
`66
`
`(cid:2) Using the printed circuit board of Deng with USB memory
`devices is nothing more than a mere substitution of a well-
`known type of circuit configuration (PCB) for the module 5 of
`Elbaz. See M.P.E.P. §2143(b).
`
`(cid:2) It would be obvious for an integrated circuit chip, such as the
`module 5 of Elbaz to include the flash memory 1, the
`microcontroller (memory controller) 21, and the USB interface
`controller 22 of Deng, as such are well-known, standard
`electrical components and one of ordinary skill in the art
`would recognize that integrated circuit chips would include
`such standard components. See M.P.E.P. § 2143(a), (b), and
`(g).
`
`(cid:2) See Second Petition, pp. 20-
`23.
`
`Slide 66 of 66
`
`
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