throbber
DOCKET NO: 440199US
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`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`TRIAL NO.: IPR2014-__________
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`
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`PATENT: 8,004,497
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`INVENTOR: Jiang XiaoPing
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`TITLE: TWO-PIN BUTTONS
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`DECLARATION OF DR. DANIEL J. WIGDOR
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`1.
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`I, Dr. Daniel J. Wigdor, make this declaration on behalf of BlackBerry
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`Corp. (“BlackBerry” or “Petitioner”) in connection with the petition for inter
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`partes review of U.S. Patent No. 8,004,497 (“the ‘497 patent,” attached as Exhibit
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`1001 to the petition). I am over 21 years of age and otherwise competent to make
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`this declaration. Although I am being compensated for my time in preparing this
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`declaration, the opinions herein are my own, and I have no stake in the outcome of
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`the inter partes review proceeding.
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`I.
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`QUALIFICATIONS
`2.
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`A detailed record of my professional qualifications, including a list of
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`publications, awards, and professional activities, can be found in my curriculum
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`vitae, which is attached as Ex. 1007 to the concurrently filed the petition for inter
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`1
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`BLACKBERRY EX. 1006, Pg. 1
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`partes review. My curriculum vitae also lists each matter in which I have provided
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`testimony, either though declaration, deposition or trial, in the last 5 years.
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`3.
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`I am an Assistant Professor of Computer Science at the University of
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`Toronto, where I have joint appointments at the Department of Computer Science
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`and the department of Mathematical and Computational Sciences.
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`4.
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`Before joining the faculty at the University of Toronto in 2011, I was
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`a researcher at Microsoft Research, the user experience architect of the Microsoft
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`Surface Tablet, and a company-wide expert in user interfaces for new technologies.
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`5. While studying to obtain my Ph.D. degree at the University of
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`Toronto, which pioneered much of the early work on touch sensitive devices and,
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`in particular, multi-touch devices, I was a fellow at the Initiative in Innovative
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`Computing at Harvard University and conducted research for Mitsubishi Electric
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`Research Labs (“MERL”). While at MERL, I was part of the DiamondSpace
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`project that developed the DiamondTouch multi-touch device. DiamondTouch is a
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`multi-input touch sensitive device that allows multiple people, simultaneously, to
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`interact with the display.
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`6.
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`In particular, I was responsible for conducting research regarding user
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`interfaces for use on the DiamondTouch. More particularly, I was responsible for
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`the design and development of user interface software that ran on the
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`2
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`BLACKBERRY EX. 1006, Pg. 2
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`DiamondTouch display, and that responded to user input as detected by changes in
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`capacitance measurements of the touch sensor.
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`7. My work regularly involved designating areas of the display to
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`correspond to buttons and other user interface elements, and writing software to
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`map the sensed capacitance variations of each sensor area or element to a user
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`interface object, including pre-processing and filtering of input. My work further
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`included the creation of applications, as well as general-purpose tools that would
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`process input and enable application software.
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`8.
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`In my work at MERL, I developed such software not only for the
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`DiamondTouch, but for several other touchscreen technologies as well, such as the
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`FingerWorks iGesture pad, mobile phones, and digital whiteboards, among others.
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`I was also responsible for the design of hardware devices, such as a two-sided
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`DiamondTouch, and mobile devices.
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`9.
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`I hold Hon. B.Sc., M.S., and Ph.D. degrees in computer science, and
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`have published extensively, with about 70 technical publications. Of these,
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`approximately 16 are peer-reviewed, technical papers which relate directly to the
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`design of touch sensitive devices and implementation of the same into electronic
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`3
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`BLACKBERRY EX. 1006, Pg. 3
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`devices.1 I have also written multiple conference short papers on this topic. I have
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`given over 70 invited talks, including multiple keynote lectures.
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`10.
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`I have used my education and experience working in the computer
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`science field, and my understanding of the knowledge, creativity, and experience
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`of a person having ordinary skill in the art in forming the opinions expressed in this
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`report, as well as any other materials discussed herein.
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`II. MATERIALS CONSIDERED
`11.
`In forming my opinions, I read and considered the ‘497 patent and its
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`prosecution history, the exhibits listed in the Exhibit Appendix filed with the ‘497
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`petition, as well as any other material referenced herein.
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`III. UNDERSTANDING OF THE LAW
`12. For the purposes of this declaration, I have been informed about
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`certain aspects of patent law that are relevant to my analysis and opinions, as set
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`forth in this section of my declaration.
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`A. A Person Having Ordinary Skill in the Art
`13.
`I understand that the disclosure of patents and prior art references are
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`to be viewed from the perspective of a person having ordinary skill in the art at the
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`time of the alleged invention (“POSITA”). Unless I state otherwise, I provide my
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`1 This includes papers numbered C.7, C.9, C.11, C.13, C.15, C.16, C.17,
`C.18, C.24, C.26, C.29, C.32, C.33, C.39, C.41, C.44 in my curriculum vitae.
`4
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`BLACKBERRY EX. 1006, Pg. 4
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`opinion herein from the viewpoint of a POSITA at the earliest alleged priority date
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`for the ‘497 patent, which I have been informed is May 18, 2006.
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`14. The ‘497 patent pertains to the field of user interface devices and, in
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`particular, touch sensitive devices, such as a touchscreen for a computer, tablet, or
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`other computing device.
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`15.
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`In determining whom a POSITA would be, I considered the ‘497
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`patent, the types of problems encountered in designing touch sensitive devices, the
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`prior art solutions to those problems, the rapid pace of innovation in this field, the
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`sophistication of touch sensitive computing devices, and the educational level of
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`workers active in the field.
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`16. Based on these factors, I have concluded that a POSITA was
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`sufficiently skilled in the design and manufacture of touch sensor devices for use in
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`computing device user-interfaces (e.g., notebook computer displays, PDA and
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`other mobile handset displays, consumer electronics, appliances, embedded
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`systems, and the like) in which the number of buttons of the touch sensor device is
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`greater than the number of sensing areas of the touch sensor device. (See, e.g., Ex.
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`1002 6:66 – 7:6, Fig. 7; Ex. 1003 Fig. 8; Ex. 1004 3:25-31, 4:16-55, Fig. 7.)
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`Moreover, one of ordinary skill in the art was aware that the location of a
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`conductive object of a touch sensor could be interpolated between sensing areas.
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`BLACKBERRY EX. 1006, Pg. 5
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`(See, e.g., Ex. 1002 6:66 – 7:6, Fig. 7; Ex. 1003 Fig. 8; Ex. 1004 3:25-31, 4:16-55,
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`Fig. 7.)
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`B. Claim Construction
`17.
`I understand that “claim construction” is the process of determining a
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`patent claim’s meaning. I also have been informed and understand that the proper
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`construction of a claim term is the meaning that a POSITA would have given to
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`that term.
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`18.
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`I understand that claims in inter partes review proceedings are to be
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`given their broadest reasonable interpretation in light of the specification, which is
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`what I have done when performing my analysis in this declaration.
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`C. Anticipation
`19.
`I understand that a patent claim is unpatentable as anticipated if a
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`POSITA would have understood a single prior art reference to teach every
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`limitation of the claim. The disclosure in a reference does not have to be in the
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`same words as the claim, but all of the requirements of the claim must be described
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`in enough detail, or necessarily implied by or inherent in the reference, to enable a
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`POSITA looking at the reference to make and use at least one embodiment of the
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`claimed invention.
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`BLACKBERRY EX. 1006, Pg. 6
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`IV. THE ‘497 PATENT
`20. Figure 6B of the ‘497 patent illustrates a configuration of a sensing
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`device having one more button than a number of sensors as described and claimed in
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`the ‘497 patent.
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`(Ex. 1001)
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`21. According to the ‘497 patent, a processing device 210 detects whether
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`a conductive object is present on one of the touch-sensor buttons 601-603. The
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`processing device 210 includes capacitance sensors 201(1) and 201(2) coupled to
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`buttons 601-603. In this regard, button 601 is coupled to capacitance sensor
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`201(1), button 603 is coupled to capacitance sensor 201(2), and button 602 is
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`coupled to both capacitance sensor 201(1) and 201(2). (Ex. 1001 17:17-26.)
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`22. The processing device 210 includes two sensing areas 613 and 614,
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`which are used to make up the three buttons and sensor elements 601-603.
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`BLACKBERRY EX. 1006, Pg. 7
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`(Ex. 1001 17:36-43, 46-48.) Particularly, button 601 includes a sensor element
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`having a surface area of one conductive material (i.e., white surface), and button 603
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`includes a sensor element having a surface area of another conductive material.
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`(Ex. 1001 17:36-43, 46-48.) Button 601 is coupled to a first pin 609, and button
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`603 is coupled to a second pin 610. (Ex. 1001 17:36-43, 46-48.)
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`23. Button 602 includes a sensor element having a surface area of two
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`conductive materials in which a first portion 604 is coupled to the conductive
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`material of button 601, and a second portion 605 is coupled to the conductive
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`material of button 603. (Ex. 1001 17:48-55.) Furthermore, the first portion 604
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`is coupled to the sensor element of button 601 using a conductive line 606, and the
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`second portion 605 is coupled to the sensor element of button 603 using a
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`conductive line 607. (Ex. 1001 17:56-59.) The conductive lines 606 and 607 may
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`be conductive traces printed on the surface of a printed circuit board (“PCB”). The
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`conductive lines may also be conductive paths of conductive material that couple
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`the conductive material of the sensor elements to the pins. (Ex. 1001 17:59-63.)
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`24.
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`In operation, the processing device 210 scans the touch-sensor buttons
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`601- 603 using the capacitance sensors 201(1) and 201(2), and measures the
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`capacitance on the two sensing areas of conductive material (613 and 614) to
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`recognize activation of one of the touch-sensor buttons 601-603. (Ex. 1001 17:65
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`- 18:1.) For example, a first button operation is recognized when the presence of the
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`BLACKBERRY EX. 1006, Pg. 8
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`conductive object is detected on a first sensing area 613; a second button
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`operation is recognized when the presence of the conductive object is detected
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`on a second sensing area 614; and a third button operation is recognized when the
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`presence of the conductive object is detected on the first and second sensing areas
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`613 and 614. (Ex. 1001 18:48-57.)
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`V. CLAIM CONSTRUCTION
`25.
`In comparing the claims of the ‘497 patent to the known prior art, I
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`have carefully considered the ‘497 patent and its file history based upon my
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`experience and knowledge in the relevant field. In my opinion, the broadest
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`reasonable interpretation of the claim terms of the ‘497 patent are generally
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`consistent with the terms’ ordinary and customary meaning, as a POSITA would
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`have understood them. That said, for purposes of this proceeding, I have applied
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`the following constructions when analyzing the prior art and the claims:
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`26. Claims 1-4 of the ‘497 patent use the term “sensing areas.” The term
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`“sensing area” should be defined as “an electrically isolated element connected to a
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`single pin on which capacitance changes are observed.” The specification
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`describes that sensing areas are made of conductive material and are electrically
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`isolated from one another. (E.g., Ex. 1001 3:24-34, 17:36-46.) Each sensing area
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`connects to a respective pin of a processing device to measure capacitance changes
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`BLACKBERRY EX. 1006, Pg. 9
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`for detecting the presence of a conductive object, such as a finger. (E.g., Ex. 1001
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`3:39 – 4:6, 17:65 – 18:14, 20:4-6, Figs. 5-7.)
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`VI. DESCRIPTION OF THE PRIOR ART
`27. The idea of using fewer sensors than the number of active buttons on a
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`capacitance sensing device predates the alleged invention of the ‘497 patent by
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`decades and forms a basic and well-understood concept underlying today’s touch
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`sensitive devices.
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`A. Overview of Piguet’s Teachings
`28. Piguet issued on December 30, 1980 and describes a capacitive sensing
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`device formed of a plurality of electrodes that form “sensing areas” as described in the
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`‘497 patent. The activation of Piguet’s sensing areas controls the device display. (Ex.
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`1004 Abstract, 3:13-21.)
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`29. Piguet describes that the “N electrodes 101 of ... a sensor are capable of
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`defining 2N-1 different positions of ... [a] finger,” with buttons corresponding to
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`each N positions of N electrodes, plus the additional N-1 positions for buttons
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`that can be placed between two adjacent electrodes. (Ex. 1004 3:25-31.) As
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`shown in Fig. 7 of Piguet, 6 electrodes or sensing areas permit the selection of
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`12 symbols on control display 125. (Ex. 1004 6:10-12.) If the “user activates a
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`single electrode of the sensor 120, he selects the corresponding symbol” such as
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`“symbols 2, 4, 6, 8, 0 and C.” (Ex. 1004 6:13-15.) If the user “activates
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`simultaneously two adjacent electrodes[,] he selects the symbol which is comprised
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`BLACKBERRY EX. 1006, Pg. 10
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`between these two electrodes” such as the symbols “1, 3, 5, 7, 9 and F.” (Ex. 1004
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`6:15-20.)
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`30.
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`I note that the Fig. 7 of Piguet, reproduced below, does not precisely
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`follow the described equation 2N-1 equals the number of button areas. Rather, in
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`Fig. 7, the number of button areas is equal to 2N, with N being the number of
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`sensing areas. This difference is simply a result of the sensing areas in Fig. 7 being
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`arranged in a circle, rather than linearly and, with this arrangement, an extra button
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`area is realized based upon the combination of the first sensing area and the last
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`sensing area in sequence. In other words, when arranged in a circle, the
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`combination of the first and sixth sensing areas can be used to define a button area,
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`which cannot occur when arranged linearly because the first and sixth buttons
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`areas would not share a common boarder in this arrangement.
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`31. The above teaching of Piguet represents the precise feature of the
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`claimed invention that is alleged to be novel and non-obvious over the prior art;
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`namely, the detection of one or more button operations when the presence of a
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`conductive object is detected on two different sensing areas. (See, e.g., Ex. 1001
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`Abstract, 2:46-50, 2:64 – 3:23.) More particularly, and as shown in Fig. 7, which
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`I have annotated, detection of a finger pressing the F symbol occurs when the
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`finger is detected on the first and second sensing areas marked below. (Ex. 1004
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`6:10-18.)
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`(Ex. 1004 Fig. 7)
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`32. There is nothing novel or non-obvious about this feature of the ‘497
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`patent—it was well-known that a capacitance sensing device may use fewer
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`sensing areas than buttons to detect activation of the buttons. While Piguet applies
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`this concept of using few sensing areas than buttons to a one-dimensional sensing
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`device, where adjacent sensors are arranged along a line or circle, it was also well-
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`known to one of ordinary skill in the art to apply the same concept in two-
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`dimensional sensing devices, where the presence of a conductive object is detected
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`in an array of sensors overlapping each other in the x and y directions—in other
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`words, on the rows and columns of electrodes found in modern touch sensitive
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`displays.
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`B. Overview of Binstead’s Teachings
`33. Binstead describes a multiple input touchpad system that can be used
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`as a touchscreen, for example, where predetermined areas of the touchpad are
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`interpreted as discrete “keypads, or ‘boxes.’” (Ex. 1002 2:18-22.) An
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`BLACKBERRY EX. 1006, Pg. 12
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`interpolation technique is taught by Binstead such that the number of keys or
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`“boxes” can be arbitrarily arranged over the surface of the touchpad, and the
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`number of keys or “boxes” may be greater than the number of sensing areas. (Ex.
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`1002 6:66 – 7:6, Fig. 7.)
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`(Ex. 1002 Fig. 7)
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`34. As shown in Fig. 7 of Binstead, which I have annotated above, it was
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`well-known in the art to arrange sensing areas in a two-dimensional array of rows
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`and columns, where each conductive element 12-2 through 12-4 and conductive
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`element 14-1 through 14-5 represents separate sensing areas of the described
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`device.
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`C. Overview of Boie’s Teachings
`35. Boie describes a capacitive position sensor comprised of an array 100
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`of electrodes 101 arranged in a grid pattern of rows and columns. (Ex. 1003
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`BLACKBERRY EX. 1006, Pg. 13
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`2:50-52.) The x and y location of a finger or other conductive object can be
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`determined based upon the centroid of capacitances measured from the electrodes.
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`(Ex. 1003 3:5-15.) As shown in Fig. 7 of Boie, which I have annotated below, the
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`capacitance electrode array 100 is a 4x4 grid that includes 8 sensing areas defined
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`by the horizontal rows 1-4 and the vertical columns 1-4. Each element within a
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`row is electrically connected with the other elements within the same row, and
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`each element within a column is electrically connected to the other elements in
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`the same column. (Ex. 1003 3:16-36, 3:52-56, Fig. 2.) Thus, just as in
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`Binstead, Boie teaches that each row and column of a sensor array may
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`constitute a separate sensing area.
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`(Ex. 1003 Fig. 7)
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`36. Boie also teaches that each square of the sensor array 100, such as
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`the area defined by the space x=2 and y=3 on the 4x4 grid of Fig. 7, may be
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`BLACKBERRY EX. 1006, Pg. 14
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`electrically isolated and connected to an individual pin of the processing device,
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`thereby creating 16 sensing areas, which are used to detect touches to, in the
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`case of the figure, 17 buttons. (Ex. 1003 4:13-20, 6:62-64.)
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`37.
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`It is therefore my opinion, as explained in greater detail below, that
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`it was known to those of ordinary skill in the art that a capacitance sensing
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`device may use fewer sensors than buttons and, as a result, fewer pins than buttons,
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`to detect the presence of a conductive object in both one-dimensional and two-
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`dimensional sensor arrays.
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`VII. ANALYSIS
`38.
`It is my opinion that claims 1-4 of the ‘497 patent are individually
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`anticipated by Binstead and also by Boie. At the request of counsel, I have divided
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`claims 1, 2, and 4 into elements denoted [preamble], [a], [b], [c], etc. to correspond
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`to the discussion of the same elements in the petition for inter partes review.
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`39. Claim 1, as annotated, reads as follows:
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`[Preamble] A method, comprising:
`[a] detecting a presence of a conductive object on a capacitance sensing
`device, the sensing device comprising at least two sensing areas each
`coupled to a capacitance measurement input; and
`[b] recognizing activation of at least three button performed by the detected
`presence of the conductive object, wherein the number of buttons is
`equal to at least the number of sensing areas plus one and
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`[c] wherein a combination of the at least two sensing areas is used to
`recognize at least one of the activated buttons.
`40. Claim 2, as annotated, reads as follows:
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`[Preamble] The method of claim 1, wherein recognizing the plurality of
`button activations comprises:
`[a] recognizing a first activated button when the presence of the conductive
`object is detected on a first sensing area of the at least two sensing areas
`of the sensing device;
`[b] recognizing a second activated button when the presence of the conductive
`object is detected on a second sensing area of the at least two sensing
`areas of the sensing device; and
`[c] recognizing a third activated button when the presence of the conductive
`object is detected on the first and second sensing areas.
`41. Claim 3 reads as follows:
`
`The method of claim 1, further comprising measuring a capacitance of the
`conductive object on the sensing device over time, wherein measuring
`the capacitance further comprises measuring a capacitance of the at
`least two sensing areas of the sensing device, and wherein recognizing
`the activated buttons is based on the measured capacitance of the at
`least two sensing areas.
`42. Claim 4, as annotated, reads as follows:
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`[Preamble] The method of claim 1, further comprising
`[a] scanning the at least two sensing areas of the sensing device, and
`wherein
`recognizing
`the plurality of activated buttons
`comprises:
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`BLACKBERRY EX. 1006, Pg. 16
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`[b] recognizing a first activated button when a first sensing area of the
`at least two sensing areas detects the presence of the conductive
`object during the scanning of the at least two sensing areas;
`[c] recognizing a second activated button when a second sensing area
`of the two sensing areas detects the presence of the conductive
`object during the scanning of the at least two sensing areas; and
`[d] recognizing a third activated button when the first and second
`sensing areas detect the presence of the conductive object
`during the scanning of the at least two sensing areas.
`A. CLAIMS 1-4 ARE ANTICIPATED BY BINSTEAD
`Claim 1 [a]: “detecting a presence of a conductive object on a
`capacitance sensing device, the sensing device comprising at least two
`sensing areas each coupled to a capacitance measurement input”
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`43. Binstead describes a multiple input touchpad system that can be used
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`as a touchscreen, for example, where predetermined areas of the touchpad are
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`interpreted as discrete “keypads, or ‘boxes.’” (Ex. 1002 2:18-22.) An
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`interpolation technique is taught by Binstead such that the number of keys or
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`“boxes” can be arbitrarily arranged over the surface of the touchpad, and the
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`number of keys or “boxes” may be greater than the number of sensing areas, as
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`shown in Fig. 7, which I have annotated below. (Ex. 1002 6:66 – 7:6, Fig. 7.)
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`BLACKBERRY EX. 1006, Pg. 17
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`(Ex. 1002 Fig. 7)
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`44. Binstead provides for “a multiple input proximity detector in which
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`the juxtaposition of two or more independent sensor inputs are used to determine
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`the proximity of a finger.” (Ex. 1002 2:63-66.) The touchpad comprises “an
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`electrically insulating membrane with a first series of spaced apart conductors
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`[elements 12] on a first face of the membrane and a second series of spaced apart
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`conductors [elements 14] on or proximal thereto, in which there is no electrical
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`contact between the first and second series of conductors, each conductor being
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`sensitive to the proximity of a finger to modify the capacitance of said conductor to
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`detect the presence of said finger positioned close to that conductor.” (Ex. 1002
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`3:7-14, interpolation added; see also Ex. 1002 3:47-55.)
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`45.
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`“Detected changes in capacitance on more than one conductor
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`element in any one scanning sequence enables interpolation of a keystroke between
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`BLACKBERRY EX. 1006, Pg. 18
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`those conductor elements.” (Ex. 1002 6:49-51.) Thus, it is my opinion that the
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`first series of conductor elements 12 and the second series of conductor elements
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`14 teaches “detecting a presence of a conductive object on a capacitance sensing
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`device,” as recited in claim element 1[a].
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`46. Further, Binstead Fig. 6 shows that conductor elements 12-1 through
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`12-n and conductor elements 14-1 through 14-n form an x and y matrix. (Ex. 1002
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`6:52-54).
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`(Ex. 1002 Fig. 6)
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`47. Specifically, Binstead describes that “[a] finger or other object at
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`position 40 can be determined in the X-direction by the relative effect on the
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`capacitance of element 14-3 compared with element 14-4, and in the Y-direction
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`by the relative effect on the capacitance of element 12-1 compared with element
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`12-2.” (Ex. 1002 6:54-58.)
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`48. As shown in Fig. 8, each conductor element is connected at one end to
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`resistor 71 and at the other end to multiplexer 75 to output line 72. (Ex. 1002 6:2-
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`12.) Because each conductor element is separately connected to a resistor 71 (each
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`connected to, for example, ground potential), and separately connected to
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`multiplexer 75, it is my opinion that conductor elements 12 (i.e., 12-1 through 12-
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`n) and conductor elements 14 (i.e., 14-1 through 14-n) are electrically isolated
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`elements—each respectively connected to a corresponding unique pin—on which
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`capacitance changes are observed and, thus, comprise the “sensing areas” of the
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`claimed invention. This is also confirmed by the specification of Binstead:
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`“[a]ccording to the present invention there is provided a touchpad comprising an
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`electrically insulating membrane with a first series of spaced apart conductors on a
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`first face of the membrane and a second series of spaced apart conductors on or
`
`proximal thereto, in which there is no electrical contact between the first and
`
`second series of conductors, each conductor in said series being sensitive to the
`
`proximity of a finger to modify the capacitance of said conductor to detect the
`
`presence of said finger positioned close to that conductor.” (Ex. 1002 3:5:14.)
`
`
`
`20
`
`BLACKBERRY EX. 1006, Pg. 20
`
`

`

`(Ex. 1002 Fig. 8)
`
`49.
`
`“Output line 72 is connected to the input of a capacitance controlled
`
`oscillator 85, the output of which is connected to a divide-by-n circuit 90, which
`
`provides the data output on line 92…. A processing means, not shown, is
`
`operative to receive the data from divide-by-n counter on line 92, and store it in a
`
`plurality of locations, each allocated to a particular one of the conductor elements
`
`12 and 14.” (Ex. 1002 6:21-30.)
`
`50. Accordingly, it is my opinion that conductor elements 12-1 through
`
`12-n and conductor elements 14-1 through 14-n arranged in columns and rows,
`
`coupled to multiplexer 75 and ultimately data output line 92, comprise “at least
`
`two sensing areas each coupled to a capacitance measurement input,” as recited in
`
`claim element 1[a].
`
`
`
`21
`
`BLACKBERRY EX. 1006, Pg. 21
`
`

`

`Claim 1 [b]: “recognizing activation of at least three button performed
`by the detected presence of the conductive object, wherein the number
`of buttons is equal to at least the number of sensing areas plus one”
`
`51. Referring to Fig. 7, which I have reproduced below, Binstead teaches
`
`that “the interpolation technique enables not only an analogue representation of
`
`finger position on the touchpad to be created, but also allows the use of an
`
`increased number of ‘boxes’ or predetermined key areas 60, 61 over the number of
`
`element intersections …. Such ‘boxes’ or keypad areas could be arranged in any
`
`number of configurations capable of being resolved by the system.”
`
`(Ex. 1002 Fig. 7)
`
`52. Conductive elements 14-1 through 14-5 and conductive elements 12-2
`
`through 12-4 define eight sensing areas. In contrast, through the described
`
`interpolation technique, the device of Binstead achieves increased resolution of
`
`keypad areas to sensing areas well beyond a one-to-one correspondence, as shown
`
`by the dozens of “boxes” in Fig. 7 as compared to the eight sensing areas. For
`22
`
`
`
`BLACKBERRY EX. 1006, Pg. 22
`
`

`

`example, as shown above, there can be at least 32 keypad areas located within the
`
`rectangle defined between conductive elements 14-1 through 14-5 in the X
`
`direction and conductive elements 12-2 through 12-4 in the Y direction. As noted
`
`previously, the position of “[a] finger or other object … can be determined in the
`
`X-direction by the relative effect on the capacitance of element 14-3 compared
`
`with element 14-4, and in the Y-direction by the relative effect on the capacitance
`
`of element 12-[2] compared with element 12-[3].” (Ex. 1002 6:54-58.) Because
`
`relative capacitance variations between conductive elements are used to determine
`
`the position of a conductive object, even more keypad areas than the 4-to-1
`
`correspondence above may be capable of being resolved by the system. (See, e.g.,
`
`Ex. 1002 6:66 – 7:6.)
`
`53.
`
`In this regard, Binstead teaches that at least 256 keypad areas can be
`
`resolved using only sixteen electrically isolated conductive elements and, thus, 16
`
`pins. (Ex. 1002 8:22-25.) Accordingly, it is my opinion that Binstead teaches
`
`“recognizing activation of at least three button performed by the detected presence
`
`of the conductive object, wherein the number of buttons is equal to at least the
`
`number of sensing areas plus one,” as recited in claim element 1[b].
`
`Claim 1 [c]: “wherein a combination of the at least two sensing areas is
`used to recognize at least one of the activated buttons”
`
`54. As illustrated in Fig. 7, which I have annotated below, the
`
`combination of conductive elements (i.e., sensing areas) 14-2 and 12-3 is used to
`23
`
`
`
`BLACKBERRY EX. 1006, Pg. 23
`
`

`

`recognize keypad or box 60-2. Binstead shows and describes this as based on
`
`interpolation techniques, wherein “detected changes in capacitance on more than
`
`one conductor element in any one scanning sequence enables interpolation of a
`
`keystroke between those conductor elements” (Ex. 1002 6:49-51, emphasis
`
`added.)
`
`(Ex. 1002 Fig. 7)
`
`55. Specifically, when a conductive object, such as a finger, is placed on
`
`box 60-1, recognition of this button press is detected on the first sensing area 12-3.
`
`This determination or recognition is made by a scanning system that “samples each
`
`conductor element in turn according to the analogue multiplexer sequence, and
`
`stores each capacitance value in memory. These values are compared with
`
`reference values from earlier scans, and with other capacitance values in the same
`
`scan from the other conductor elements in order to detect a keystroke. Keystrokes
`24
`
`
`
`BLACKBERRY EX. 1006, Pg. 24
`
`

`

`must be above a threshold value to be valid….” (Ex. 1002 6:34-41.) Thus, in
`
`order to detect a keystroke at 60-1, the capacitance variation of a first sensing area
`
`12-3 must be greater than a threshold or reference value.
`
`56. Correspondingly, in order to detect a keystroke at 60-1 and not 60-2,
`
`the relative effect on the capacitance of elements 14-1 and the second sensing area
`
`14-2 in the X direction must be compared. (Ex. 1002 6:52-61.) A keystroke at 60-
`
`1 will have a greater relative effect on the capacitance of conductive element 14-1
`
`than the second sensing area 14-2. Thus, the capacitance variation of the second
`
`sensing area 14-2 will not be greater than the reference value when signaling a
`
`keystroke at 60-1.
`
`57. When a conductive object, is placed on box 60-4, recognition of this
`
`button press is detected on the second sensing area 14-2. A position of a finger
`
`touching box 60-4 can be determined in the X-direction by the relative effect on
`
`the capacitance of element 14-1 and the second sensing area 14-2. (Ex. 1002 6:52-
`
`61.) As discussed above, the determination of a finger position and corresponding
`
`keystroke is made by comparing capacitance variations to a threshold or reference
`
`value. (Ex. 1002 6:34-41.) Thus, in order to detect a keystroke at 60-4, the
`
`capacitance variation of a second sensing area 14-2 must be greater than a
`
`threshold or reference value.
`
`
`
`25
`
`BLACKBERRY EX. 1006, Pg. 25
`
`

`

`58. Correspondingly, in order to detect a keystroke at 60-4 and not 60-2,
`
`the relative effect on the capacitance of elements 12-2 and the first sensing area 12-
`
`3 in the Y direction must be compared. (Ex. 1002 6:52-61.) A keystroke at 60-4
`
`will have a greater relative effect on the capacitance of conductive element 12-2
`
`than the first sensing area 12-3. Thus, the capacitance variation of the first sensing
`
`area 12-3 will not be greater than the reference value when signaling a keystroke at
`
`60-4.
`
`59. Lastly, when a conductive object is placed on box 60-2, recognition of
`
`this button press is detected on both the first sensing area 12-3 and the second
`
`sensing area 14-2. A position of a finger touching box 60-2 can be determined in
`
`the Y-direction by the relative effect on the capacitance of element 12-2 and the
`
`first sensing area 12-3, and in the X-direction by the relative effect on the
`
`capacitance of element 14-1 and the second sensing area 14-2. (Ex. 1002 6:52-61.)
`
`In order to detect a ke

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