UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LG ELECTRONICS, INC.,
`LG ELECTRONICS U.S.A., INC., and
`LG ELECTRONICS MOBILECOMM U.S.A., INC.,
`Petitioner
`v .
`CYPRESS SEMICONDUCTOR CORPORATION
`Patent Owner
`
`Case IPR2014-01302
`Patent 8,059,015
`
`DECLARATION OF ROBERT DEZMELYK
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LG ELECTRONICS, INC.,
`LG ELECTRONICS U.S.A., INC., and
`LG ELECTRONICS MOBILECOMM U.S.A., INC.,
`Petitioner
`v .
`CYPRESS SEMICONDUCTOR CORPORATION
`Patent Owner
`
`Case IPR2014-01302
`Patent 8,059,015
`
`DECLARATION OF ROBERT DEZMELYK
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`Case IPR2014-01302
`U.S. Patent No. 8,059,015
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`TABLE OF CONTENTS
`INTRODUCTION ...........................................................................................1
`
`QUALIFICATIONS........................................................................................1
`
`I.
`
`II.
`
`III. MATERIALS CONSIDERED........................................................................6
`
`IV.
`
`V.
`
`SUMMARY OF OPINIONS...........................................................................6
`
`LEGAL STANDARDS, PERSON OF ORDINARY SKILL IN THE
`ART .................................................................................................................7
`
`VI.
`
`‘015 PATENT TECHNOLOGY BACKGROUND........................................8
`
`VII. CLAIMS 1, 2, 4–7, 13, 17–19, 21, AND 22 OF THE `015 PATENT
`ARE NOT OBVIOUS OVER BOIE AND ANDRE ....................................15
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`Overview of Boie ................................................................................15
`
`Overview of Andre..............................................................................21
`
`1.
`
`Andre’s Virtual Keys Do Not Have A Pre-Defined Area ........24
`
`Independent Claims 1 And 7 Are Not Rendered Obvious By
`The Combination Of Boie And Andre................................................30
`
`Claims 2, 4–6, 13, 17–19, 21, And 22 Are Not Rendered
`Obvious By The Combination Of Boie And Andre For the
`Same Reasons As Claims 1 and 7.......................................................36
`
`Claim 15 Is Not Rendered Obvious By The Combination Of
`Boie, Andre, and Hristov....................................................................36
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`CONCLUSION ...................................................................................37
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`I, Robert Dezmelyk, declare and state as follows:
`
`I.
`
`INTRODUCTION
`1.
`I have been retained by Kaye Scholer LLP at the rate of $270 per hour
`to provide opinions in connection with the Inter Partes review of U.S. Patent No.
`
`8,059,015 (the “‘015 patent”). My compensation is not affected by the outcome of
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`this proceeding.
`
`2.
`
`I have no financial interest in any of the parties, or the ‘015 patent.
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`II. QUALIFICATIONS
`3.
`I am currently President of LCS/Telegraphics, a consulting and
`
`technology supply company. In addition to my design and engineering work at
`
`LCS/Telegraphics I personally provide consulting related to areas of technology
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`that I have expertise in. I have been working with input devices, microcomputers,
`
`and interactive computer systems since 1976. In 1979, I received my degree from
`
`the Massachusetts Institute of Technology (“MIT”). I studied in a specialized
`
`program on the application of computers to measurement and control that
`
`combined Electrical Engineering and Computer Science courses with courses and
`
`research in control systems, signal processing, and instrumentation.
`
`4.
`
`During my 35 year career, I have concentrated my work on the
`
`interfaces between humans and computers. I have worked on the design and
`
`development of numerous input devices, including mice, keyboards, digitizers,
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`touch pads and touch screens. As a part of that work I have designed, implemented,
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`and debugged numerous digital and analog circuits, including circuits used to
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`determine the location of a user’s touch. I have also developed a large amount of
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`software that interacts with input device hardware in order to write device driver
`
`programs for input devices. I have developed graphical user interfaces, and
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`software which uses touch or stylus input as its primary means of user interaction. I
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`have designed, written, and led the development of software that interprets user
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`gestures, and I have designed and written controller firmware for keyboards,
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`joysticks, mice, trackballs, digitizing tablets, touch pads, and resistive and
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`capacitive touch screens. I have also been involved with a number of industry
`
`standards setting efforts related to input device interfaces. I have been qualified as
`
`an expert regarding user interfaces, input device technology, including capacitive
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`touch screen technology, gesture based user interfaces, the display of graphic
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`images, and KVM (keyboard - video - mouse) switch technology. My experience
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`and education are detailed in my curriculum vitae, which is attached as Appendix
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`A.
`
`5. While at MIT, in 1976 I began writing software and designing
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`microcomputer-based devices and had the opportunity to work on some of the first
`
`personal computers, writing software and helping to build an interactive flight
`
`simulator game. At MIT, I took a project oriented class at MIT’s Architecture
`
`Machine Group and had the opportunity to familiarize myself with and work with
`
`an experimental touch screen with 6DOF force sensors, and a projection based
`
`virtual keyboard.
`
`6.
`
`After receiving my degree from MIT, I formed Robert Dezmelyk
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`Associates, a consulting and design company. Projects I personally completed
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`included a control and data acquisition system for pulsed dye lasers used in
`
`research, a dynamic RAM board for IBM, and a number of microcomputer systems
`
`for data acquisition and analysis. Several of those systems used digitizing tablets,
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`input devices which sense the location of a stylus held by a user to input X,Y
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`coordinate data from images.
`
`7.
`
`In 1980, I incorporated my business as Laboratory Computer Systems,
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`Inc. (“LCS”) and we launched its first product, a microcomputer based image
`
`analysis system called the Image-80 which incorporated a digitizing tablet. Data
`
`was entered by tracing features in images with a stylus. In 1981 we introduced a
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`smaller image analyzer built into a digitizing tablet, the Microplan II. The
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`Microplan II was marketed under a private label agreement with Nikon, Inc. and
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`sold by Nikon for a number of years as a part of its scientific instrument product
`
`line. For Microplan II, I re-wrote the firmware for the digitizing tablet and licensed
`
`that firmware back to the tablet manufacturer, starting a long relationship with
`
`manufacturers of digitizing tablets. The Microplan II firmware computed
`
`morphometric parameters from the user’s input strokes in real time. The Microplan
`
`II firmware performed the same type of computations used in real time gesture
`
`recognition software.
`
`8.
`
`In 1984, I developed a concept for an interactive communications
`
`program for the newly introduced IBM Personal Computers that allowed users to
`
`browse remote time sharing systems with a graphical interface, similar in
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`appearance in many ways to a modern web browser, and to share typed and drawn
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`communications, in real time, with remote sites using modems and the telephone
`
`network. This product was named TeleVision . We also introduced one of the first
`
`PC compatible paint programs named TelePaint. Both TelePaint and TeleVision
`
`used a fully mouse driven icon and window based user interface, and were some of
`
`the earliest PC applications that required a mouse. I designed a major portion of the
`
`user interface and led the team of engineers who implemented the products.
`
`9.
`
`As a result of our development and marketing efforts for TelePaint,
`
`we established relationships with a number of the early manufacturers of mice
`
`including Microsoft, Logitech, Mouse Systems, and Torrington. Torrington needed
`
`a mouse driver in order to sell its hardware product, and we developed an
`
`emulation of Microsoft’s mouse driver for Torrington. Our engineering group,
`
`which I led, became the foremost experts in emulating the functionality of
`
`Microsoft’s mouse driver, and our licensees distributed millions of copies of the
`
`drivers with mice, trackballs, digitizing tablets, touch screens, touch pads, and
`
`computers.
`
`10.
`
`At LCS we introduced input device drivers for every version of
`
`Windows beginning with Windows 3.0 and extending up through Windows XP, as
`
`well as a number of more specialized operating systems such as OS/2 and the
`
`various pen computer operating environments. We had a particular focus on
`
`drivers for early pen computers and developed drivers for and tested many pen-
`
`based systems. In many cases we helped debug hardware related issues with the
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`sensors used in the pen computers. During the 1990s LCS developed and provided
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`drivers for touchpads used on notebook computers, most of which were based on
`
`capacitive sensing. Our customers included Alps, Cirque, Interlink, Hagiwara-
`
`Syscom, Synaptics, and others. Either I personally, or the engineers I supervised,
`
`frequently developed code that interpreted the user’s touch input gestures into
`
`output commands. This included time based gestures such as tapping and dragging
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`as well as scroll gestures.
`
`11.
`
`At LCS in the late 1990s I led a research effort that developed a
`
`gesture recognizer that could interpret short, fast strokes on a touchpad in real time
`
`as commands instead of ordinary pointing input. The recognizer used a variety of
`
`parameters measured from the input point stream, including relative angle of stroke
`
`components.
`
`12.
`
`During the first decade of this century, I concentrated more of my
`
`design efforts on hardware, firmware, and mechanical aspects of input devices and
`
`USB interfaces. Projects included the design and sale of USB interface chips for
`
`input devices, the re-design of a line of mice and other input devices to reduce cost
`
`and improve their performance, the design of several novel input devices, and
`
`extensive work on a capacitive touch screen controller. In addition, I designed and
`
`developed the USB interface portion of a line of radio frequency test equipment,
`
`which has grown to include synthesizers, attenuators, phase shifters, and switches,
`
`designed a USB hub intended for laboratory use, and debugged a number of
`
`complex issues related to USB signal integrity.
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`13.
`
`Recently, along with research and study related to providing
`
`consulting related to litigation matters, I have developed an input device for a
`
`medical system, a specialized analog to digital conversion module, and continued
`
`development of software and firmware related to the radio frequency test
`
`equipment.
`
`14.
`
`I was Founder and served from 1991 to 2000 as Chairman of the
`
`Committee for Advanced Pointing Standards, the group which created the
`
`Wintab™ standard Applications Programming Interface for digitizing tablets and
`
`other pointing devices. From 1996 to 1998 I served as Chairman of the Universal
`
`Serial Bus Human Interface Working Group, the group which created the USB
`
`HID standard. From 1993 to 1995, I chaired the Access.bus Software Working
`
`Group, part of the Access.bus industry standards group which developed a
`
`predecessor to Universal Serial Bus.
`
`III. MATERIALS CONSIDERED
`15.
`As a part of the process of forming my opinions, I have reviewed the
`
`‘015 patent and its file history (Exs. 1001 & 1011), LG’s Petition, the declaration
`
`of Dr. Wright regarding the ‘015 patent (Ex. 1010), U.S. Patent No. 5,463,388 to
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`Boie et al. (“Boie”) (Ex. 1002), U.S. Patent No. 7,844,914 to Andre et al.
`
`(“Andre”) (Ex. 1012), and U.S. Patent No. 7,821,502 to Hristov (Ex. 1004). I have
`
`also relied on my own knowledge, expertise, and experience.
`
`IV.
`
`SUMMARY OF OPINIONS
`16.
`I disagree with Dr. Wright’s conclusions regarding claims 1, 2, 4-7,
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`13, 15, 17-19, 21 and 22 of the ‘015 patent. Dr. Wright’s conclusions are not
`
`supported by the elements of the prior art references he identified in his
`
`declaration, and as I have set forth below, do not render the claims obvious in view
`
`of the references.
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`V.
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`LEGAL STANDARDS, PERSON OF ORDINARY SKILL IN THE
`ART
`17.
`I have been instructed concerning and/or reviewed 35 U.S.C. 102 and
`103; Graham v. John Deere Co., 383 U.S. 1 (1966); KSR Int’l Co. v. Teleflex, Inc.,
`
`550 U.S. 398 (2007); and section 2141 of the Manual of Patent Examining
`
`Procedure entitled “Examination Guidelines for Determining Obviousness Under
`
`35 U.S.C. 103.”
`
`18.
`
`I have been informed that a prior art reference must be considered in
`
`its entirety, i.e., as a whole, including portions that would lead away from the
`claimed invention. W.L. Gore & Assocs., Inc. v. Garlock, Inc., 721 F.2d 1540,
`
`1550 & 1552 (Fed. Cir. 1983). Thus, if a reference, as a whole, criticizes,
`
`discredits, or otherwise discourages the solution that is the claimed invention, the
`
`reference is deemed to teach away from the claimed invention and cannot be
`properly used to support a prima facie case of obviousness.
`
`19.
`
`I have been informed that claims should be given their “broadest
`
`reasonable interpretation in light of the specification in which it appears” and that
`
`claim terms should be given their plain and ordinary meaning as would be
`
`understood by a person of ordinary skill at the time of the invention (“PHOSITA”)
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`in the context of the entire patent disclosure except in instances where the patentee
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`either sets out his or her own definition, acting as his or her own lexicographer, or
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`when the patentee disavows the full scope of a claim term either in the
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`specification or during prosecution. I further understand that the “broadest
`
`reasonable interpretation” standard is different than the standard used in litigation
`
`in courts.
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`20.
`
`It is my opinion, based on my experience both working as a design
`
`engineer and managing engineers, that a person of ordinary skill in the art in the
`
`field of the `015 patent would have had a Bachelor of Science in Electrical
`
`Engineering, or an equivalent technical degree, and two years of experience in the
`
`field of touch input devices, or a Masters or other advanced degree in Electrical
`
`Engineering, and one year of experience or research in the field of touch input
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`devices.
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`VI.
`
`‘015 PATENT TECHNOLOGY BACKGROUND
`21.
`The `015 patent is directed to touch technology. Touch sensor
`
`technology based on capacitive sensing is increasingly becoming the preferred user
`
`interaction method for many consumer devices, especially mobile smart phones
`
`and tablets. The technology allows a user to interact with a device using many
`
`different kinds of touch gestures such as simple touch/select and more complex
`
`interactions such as long touch, swipe, drag, double touch and pinch.
`
`22. Capacitive touch controls rely on the human body’s conductivity and
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`its ability to store electrical charge, in order to determine where and how a finger is
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`interacting with the touch device. The human body, except for the outer layer of
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`skin is fairly conductive due to the presence of water and ions within the body.
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`When a finger or other conductive or dielectric object is placed into an electric
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`field, it disturbs the electric field as the charge rearranges on the surface of the
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`object to minimize the electric field within the dielectric object. The disturbance to
`
`the local electric field changes the electrical properties of electrodes located near
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`the finger in a way that can be measured. In other words, because the presence of
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`fingers on, or in the proximity to, a touch device changes the electrical
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`characteristics of the touch sensors in a known way, a determination can be made
`
`as to the presence of the user’s finger based on those changed electrical
`
`characteristics.
`
`23. Capacitance is a physical property that represents the ability of
`
`physical objects to store an electrical charge. Capacitance is a function of the
`
`relative shape and placement of conductors, and a physical
`
`property, the dielectric constant, of the material or
`
`materials between the conductors. For simple geometries,
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`such as a pair of conductive plates separated by a fixed
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`distance, the capacitance can be readily calculated. A
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`“capacitor” is a device capable of storing electrical charge. A capacitor has two
`
`“plates” separated by a dielectric material. As an approximation, the capacitance
`
`between objects can be represented as a circuit formed from discrete capacitors.
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`Ex. 1001, 9:15-19. As illustrated in Figure 3A of the `015 patent, when a finger, or
`
`other conductive object is in the vicinity of electrodes that form the two plates (301
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`and 302) of a capacitor, it effectively becomes part of the capacitor and thus the
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`ability of the capacitor to store charge will increase due to the conductivity of the
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`finger. For the electrode designs shown in the ‘015 patent the capacitance will
`increase as the finger moves over the pair of plates. Id., 9:19-27.
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`24.
`
`To receive and process user inputs, the invention in the `015 patent
`
`generally utilizes a multiplicity of capacitors that act as sensing areas to measure
`
`the electrical effect of the finger’s location. The capacitors (sensing areas) are
`
`created by a matrix of rows and columns of electrically conductive material
`
`layered on a surface. These rows and columns of elements, shown as diamonds in
`
`Fig. 5A of the `015 patent, (invisible to the user) can dynamically form respective
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`plate pairs of capacitors (sensing areas):
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`Figure 5A of the ‘015 patents illustrates row electrodes (black) and column
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`electrodes (white) with diamond shaped conductors found in a touch device1.
`25. As shown in Figure 5A, the electrically conductive rows and columns
`
`are connected to the pins (connections) of processing device (210). Processing
`
`device (210) is responsible for electrically charging and discharging the various
`
`rows and columns of the elements via the pins to dynamically create the two plates
`
`of a capacitor, measure the capacitance variation of the plates of the capacitor,
`
`compare it to the expected value of capacitance and then, based on the variation,
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`determine if and where a finger might be located relative to the capacitor. Ex.
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`1001, 10:65-11:3, 16:48-55. This process is repeated across the entire pattern so
`
`that many capacitors (sensing areas) are created and measured across the
`
`capacitance matrix and the location of the finger can be fixed relative to all of the
`measurements of all of the capacitors (sensing areas). Id., 11:19-42. The process
`
`is then repeated over and over in a continuous fashion to allow for the constant
`
`monitoring of a finger’s position and actions across time. Id.
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`26.
`
`The `015 patent further describes a touch device that can be used as a
`
`keyboard, and which allows selection of a particular keyboard key based on its
`
`position on the keyboard, and which allows for a lower pin count between the
`
`sensing device implementing the keyboard, and a processing device. Ex. 1001,
`
`3:34-57. In the embodiments described in the `015 patent, each key of the
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`1 Other shapes such as vertical and horizontal bars may be utilized instead of
`diamond-shaped elements. Ex. 1001, 17:27-33
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`keyboard is assigned a different predetermined area on a matrix of capacitive
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`sensors. Ex. 1001, 3:58-63. Because each keyboard key is assigned to a different
`
`predetermined area on the sensor matrix, each key will provide a different
`
`capacitance variation to the processor when the finger is detected. Ex. 1001, 3:64-
`
`67. The capacitance variation measured on sensing pins that couple the sensor
`
`device to the processor, can be used to determine the X and Y coordinates of the
`
`conductive object (e.g., finger). Ex. 1001, 3:67-4:6.
`
`27.
`
`The relationship between the sensor elements, the predetermined
`
`areas, and the pins can be seen in Figs. 6A-6C. Fig. 6A is annotated below to show
`
`the relationship between a single sensor element and several predefined areas:
`
`As can be seen, three keyboard keys 603(1)-603(3) are outlined in blue while a
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`single sensor element is outlined in red. Each key 601(1)-601(3) is assigned to and
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`corresponds to a predefined area. Ex. 1001, 18:29-33 (“Keyboard keys, A-C
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`603(1)-603(3), are assigned pre-defined areas of the sensing device. In this
`
`embodiment, the keyboard keys 603(1)-603(3) correspond to pre-defined areas that
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`are disposed in a horizontal line along a center line of the diamond-shaped sensor
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`element, sensor element 601.”).
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`28.
`
`The `015 patent teaches that while Fig. 6A shows gaps between the
`
`predefined areas, keys can also be adjacent to each other, which the `015 patent
`
`teaches means there is no space between the keyboard keys. Ex. 1001, 18:36-41
`
`(“It should be noted that the gaps between the pre-defined areas (represented as
`
`square buttons) are merely for illustration and description purposes, and
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`accordingly, the keyboard keys may be assigned adjacent to one another without
`
`any space between the keyboard keys.”).
`
`29.
`
`Figs. 6B and 6C show how the sensor and the predefined area/keys of
`
`Fig. 6C can implement a keyboard. In particular, Fig. 6C shows how a keyboard
`
`having the keys “A” through “Z” 606(0)-606(25) can be implemented using the
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`concepts of the `015 patent. In the embodiment of Fig. 6C, each key “A” through
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`“Z” 606(0)-606(25) is assigned to a single predefined area. In this embodiment,
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`there are eight rows of sensors 504(1)-504(8) (shown in black) and eight columns
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`of sensors 505(1)-505(8) (shown in white). Each row and column has eight sensor
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`elements each. Ex. 1001, 19:63-20:3.
`
`30.
`
`Each sensor in a row of sensors is electrically coupled to each other,
`
`and the same is true for columns of sensors. Each row of sensors and each column
`
`of sensors is coupled to the processing device using capacitive sensing pins 502.
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`Thus, in this embodiment, there are sixteen total capacitive sensing pins. Ex. 1001,
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`20:3-9. The annotated drawing below shows the relationship between the keys,
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`each of which is assigned to a predefined area (three of which are outlined in blue)
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`and the sensor elements (one of which is outlined in red):
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`Because each of the keyboard keys is assigned to a predefined area, once a
`
`conductive object such as a finger has been detected and its location determined,
`
`the system can determine which key was pressed simply by comparing the position
`
`with the pre-defined areas. Ex. 1001, 20:26-47. The determination that a particular
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`key has been selected by the user only requires the comparison of the location of
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`the user’s touch with the pre-defined boundaries of the area for that particular key.
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`VII. CLAIMS 1, 2, 4–7, 13, 17–19, 21, AND 22 OF THE `015 PATENT ARE
`NOT OBVIOUS OVER BOIE AND ANDRE
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`Overview of Boie
`1.
`31. Boie (Ex. 1002) discloses a method for calculating the location of a
`
`finger touch on either a cursor control touchpad or a keypad. The location of the
`
`finger touch is calculated using the “centroid” of the measured capacitance values
`
`on a capacitive touch sensor which has a rectangular array of sensing electrodes. A
`
`person having ordinary skill in the art would know that a centroid is the “center of
`
`gravity or first moment” of the capacitance distribution. See Ex. 1002, 2:64-3:2.
`
`Fig. 1 of Boie shows a histogram of the capacitance measurements taken at each
`
`sensor in four-by-four array of sensors. Ex. 1002, 2:61-64 (“Histogram 110 shows
`
`the capacitances for electrodes 101 in array 100 with respect to finger 102. Such
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`capacitances are a two- dimensional sampling of the distribution of capacitance
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`between array 100 and finger 102.”). The location labeled as point 111 in Fig. 1 is
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`finger contact location, and is calculated from capacitance measurements of the
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`individual sensors:
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`32.
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`The point marked 111 is the centroid, and is the location of the finger
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`on the sensor array. Ex. 1002, 2:64-3:2 (“The centroid (center of gravity or first
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`moment) 111 of such distribution will correspond to the position of finger 102, or
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`some other object touching array 100, if suitable sampling criteria are met; that is,
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`by choosing electrodes of sufficiently small size when compared to the extent of
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`the distribution. Such criteria are discussed in the Blonder et al. patent referred to
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`above.”). The centroid based position calculation disclosed by Boie requires that
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`the electrodes be arranged in a rectangular array, or a one dimensional linear array.
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`Ex. 1002, 2:50-60.
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`33. Boie discloses two applications for its sensor. The first is a cursor
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`controller that can replace devices such computer mice. Ex. 1002, 1:43-50 (“Input
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`devices such as mice, joysticks and trackballs can be cumbersome because of their
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`size and shape and, particularly with mice, the room needed for use. These
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`drawbacks are more apparent with respect to portable computers, such as the so-
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`called ‘notebook’ computers. It is deskable [sic: desirable], therefore, to furnish
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`such control capabilities in an input device that can be incorporated in a small
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`space, but without sacrificing ease of use.”). The second application for the sensor
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`described in Boie is a keyboard. In the keyboard embodiment, keys, e.g., “1,”
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`“Enter,” etc., are overlaid on the capacitive sensor array. Ex. 1002, 6:61:-64
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`(“FIG. 7 is a diagram showing how an array 100 can be used as a keyboard in
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`accordance with the invention. Again, array 100 is shown as a 4x4 matrix of
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`electrodes, but with a keyboard pattern overlay superimposed on the matrix.”).
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`34.
`
`In either the cursor controller or keyboard embodiments, the location
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`of a finger is calculated by computing the centroid from the capacitance values at
`each electrode in its sensing array. See Boie at 3:5-15 and 5:25-56. By calculating
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`a centroid, Boie is determining the X and Y positions of the finger on the sensor
`array. Ex. 1002, 3:5-8 (“The x and y coordinates of the centroid can be
`determined by directly measuring the capacitance at each electrode 101 and
`
`calculating such x and y coordinates from such measured capacitances. Thus,
`for the 4x4 array 100, sixteen capacitance measurements would be needed.”).2
`Indeed, regardless of the application, Boie’s sensor always calculates the x and y
`
`2 Unless indicated, I have added the bolding, underlining, etc. of text in my
`declaration.
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`location of the centroid, which is seen in Figs. 6 and 8. Fig. 6 is a flowchart
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`showing how Boie operates as a touchpad, while Fig. 8 shows how Boie operates
`
`as a keyboard:
`
`35.
`
`Boie’s keyboard embodiment is shown in Fig. 7. As shown in Fig. 7,
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`the keyboard is made up of keys, e.g., “0,” “2,” “enter,” “-,” etc. As I have
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`discussed above, Boie teaches that the identity of a touched key is determined by
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`the X and Y positions determined by the centroid calculation. Once the X and Y
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`position of the centroid is determined, Boie determines whether that location falls
`
`within ranges of X and Y coordinates corresponding to a key. Boie provides
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`several examples of ranges of X and Y coordinates in Fig. 7 that correspond to the
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`identity of a specific key. Ex. 1002, 7:8-12 (“For example, using the x and y
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`coordinates shown in FIG. 7, a ‘5’ can be defined as a touch with [1.7≤x≤2.3,
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`2.3≤y≤2.7]; a ‘0’ can be defined as a touch with [1≤x≤2.3, 1≤y≤1.3]; and a ‘+’ can
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`be defined as a touch with [3.7≤x≤4, 2.4≤y≤3.5].”).
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`36. Boie teaches that these coordinates are selected to leave “guard
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`bands” between keys Ex. 1002, 7:12-14 (“These ranges are chosen to leave guard
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`bands between adjacent keys. Such a range for each key on the keyboard is stored
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`in microprocessor 406.”). The resulting guard bands in Boie can be seen in the
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`annotated drawing below:
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`37.
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`The X-Y coordinate system in Boie’s keyboard embodiment is
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`illustrated in the annotated drawing in red. The range of X and Y coordinates Boie
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`discloses for the “5” key are shown in blue. The range of X and Y coordinates
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`Boie discloses for the “0” key are shown in green. Finally, the range of X and Y
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`coordinates Boie discloses for the “+” key are shown in orange. As is seen, Boie
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`intentionally places large gaps between keys. Moreover, for both the “0” and “+”
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`keys, the X and Y coordinates do not even align with the respective keys printed
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`on the sensor array 100. Indeed, a person having ordinary skill in the art would
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`understand that Boie explicitly teaches that its centroid calculation methodology
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`cannot report positions outside the centers of each electrode at the edge of the
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`keyboard. The algorithm Boie teaches for its centroid calculation is embodied in
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`equations (1) and (2), found at 5:30-40. Boie teaches “that the value of x can
`neither be less than 1 nor more than ux and the value of y can neither be less than 1
`nor more than uy.” Ex. 1002, 5:47-49.
`38.
`Since there are no capacitance values outside of the sensor array, the
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`centroid interpolation method cannot determine the position of touches outside of
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`the centerlines of the outermost electrodes at a higher resolution than the
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`coordinates of the electrode. In other words, the minimum and maximum
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`coordinates that can be calculated by the algorithm Boie teaches are the
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`coordinates of the centerlines of the outermost electrodes. This means that
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`equations (1) and (2) will not result in the calculation of a location between the
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`center of an electrode and the edge of the sensor array 100. Thus, Boie describes a
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`capacitive position sensor, which with respect to FIG. 7, cannot calculate x-
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`positions less than 1, x-positions greater than 4, y-positions less than 1, or y-
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`positions greater than 4.
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`Overview of Andre
`2.
`39. Andre discloses a touch screen device in which a user can activate
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`items displayed on a graphical user interface (“GUI”). Ex. 1012, 3:20-23.
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`According to Andre, a user will often miss its intended target of the GUI when
`placing a finger on the device. Id., 3:23-25 (“As can be seen from FIGS. 1-1A, 1-
`
`1B and 1-1C, the touch area of a user’s finger, to activate a GUI item on a touch
`
`screen, typically does not match a visual target associated with that GUI item.”).
`
`Because of this, Andre discloses a touch screen device that processes “touches on a
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`touch screen in a way that does not necessarily depend on a match between the
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`visual target 10 and a touch area of a touch to activate a GUI to which the visual
`target 10 corresponds.” See Ex. 1012, 3:38-42. Andre solves the problem it
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`identified by processing “touches on a touch screen in a way that ‘makes sense,’
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`which may include considering factors beyond (or instead of) a correspondence of
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`the visual target and the touch area of a touch to activate the GUI to which the
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`visual target corresponds.” Id., 3:42-47.
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`40. Andre thus discloses a device, e.g., a virtual keyboard, made up of
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`keys. An example is shown in Andre’s Fig. 1, an annotated version of which is
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`shown below:
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`41. Andre states that “FIG. 1 illustrates a keyboard GUI
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