`
`
`
`Exhibit 3001Exhibit 3001
`
`
`
`New Claim Construction In Reply
`
`Petition:
`
`Reply:
`
`“Entering”
`“For this proceeding, Petitioner interprets ‘entering’
`to include entering threshold information at that
`manufacturing stage or through user input.” (p. 5)
`“First, the meaning of ‘entering’ includes entry of
`information internally by an electronic device.” (p. 2)
`
`IPR2014-00631 - U.S. Patent No. 7,817,914
`
`Exhibit 2017
`
`9
`
`
`
`Argument In Reply
`
`Mishima:
`
`Ono:
`
`“Entering” - New Anticipation Argument
`Internal reading an imaging program is “entering.”
`Reply at 14.
`A timing signal generator receiving an internally
`stored photographing condition is “entering.”
`Reply at 17.
`
`IPR2014-00631 - U.S. Patent No. 7,817,914
`
`Exhibit 2017
`
`10
`
`
`
`New Evidence In Reply
`
`“Entering” – New Evidence
`Stevenson
`Rebuttal Declaration
`Paragraph 13
`
`New Argument
`
`Claim Construction
`
`Anticipation by Mishima
`based on new construction
`
`Anticipation by Ono
`based on new construction
`
`Paragraphs 48 - 50
`
`Paragraphs 57 - 59
`
`IPR2014-00631 - U.S. Patent No. 7,817,914
`
`Exhibit 2017
`
`11
`
`
`
`New Claim Construction In Reply
`
`Petition:
`
`Reply:
`
`“Threshold Level”
`“Petitioner is interpreting ‘threshold level’ to refer to
`a measurable level of a sensed signal or measured
`variable relating to the presence of the trigger
`condition” (p. 5)
`“Thus, a POSA would have understood ‘threshold
`level’ to correspond to a quantitative level or value
`that, when surpassed, indicates that something is
`true or takes place” (p. 4)
`
`IPR2014-00631 - U.S. Patent No. 7,817,914
`
`Exhibit 2017
`
`12
`
`
`
`New Claim Construction In Reply
`
`“Automatically Operating”
`Petition: No construction offered.
`Reply:
`“[T]he automatically operating step merely requires
`that the image capture device automatically
`determines the timing of image capture without user
`involvement.” (p. 6)
`
`IPR2014-00631 - U.S. Patent No. 7,817,914
`
`Exhibit 2017
`
`15
`
`
`
`Improper Reply
`
`Rule 23(b) provides that “[a] reply may only respond to
`arguments raised in the corresponding opposition or patent
`owner response.”
`
`IPR2014-00631 - U.S. Patent No. 7,817,914
`
`Exhibit 2017
`
`18
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