throbber
DOCKET NO: 440194US
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`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`PATENT: 8,519,973
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`INVENTOR: Jiang XiaoPing
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`TITLE: APPARATUS AND METHOD TRIAL NO.: IPR2014-__________
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` FOR DETECTING A
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` CONDUCTIVE OBJECT AT A
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` LOCATION
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`
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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. 8,519,973 (“the ‘973 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
`A detailed record of my professional qualifications, including a list of
`2.
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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 project
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`that developed the DiamondTouch multi-touch device. DiamondTouch is a multi-
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`input touch sensitive device that allows multiple people, simultaneously, to interact
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`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 detect 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 of
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`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
`In forming my opinions, I read and considered the ‘973 patent and its
`11.
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`prosecution history, the exhibits listed in the Exhibit Appendix filed with the ‘973
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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
`I understand that the disclosure of patents and prior art references are
`13.
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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 ‘973 patent, which I have been informed is May 18, 2006.
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`14. The ‘973 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 ‘973
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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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`5
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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
`I understand that “claim construction” is the process of determining a
`17.
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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
`I understand that a patent claim is unpatentable as anticipated if a
`19.
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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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`IV. THE ‘973 PATENT
`20. Figure 6B of the ‘973 patent illustrates a configuration of a sensing
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`device having one more button than a number of sensors.
`6
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`BLACKBERRY EX. 1006, pg. 6
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`(Ex. 1001 Fig. 6B)
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`21. According to the ‘973 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 17:30-40.)
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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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`(Ex. 1001 17:50-57, 61-62.) 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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`7
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`BLACKBERRY EX. 1006, pg. 7
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`(Ex. 1001 17:50-57, 61-62.) Button 601 is coupled to a first pin 609, and
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`button 603 is coupled to a second pin 610. (Ex. 1001 17:50-57, 61-62.)
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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 17:58-65.) 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 18:3-6.) The conductive lines 606 and 607 may be
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`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 18:6-11.)
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`24. The ‘973 patent also describes measuring capacitance variations. For
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`example, the ‘973 patent describes that capacitance variation δ1and δ2 are
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`measured on pins 609 and 610, respectively. (Ex. 1001 18:38-48.) If the
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`capacitance variation δ1, measured on the first pin 609, is greater than zero, and
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`the capacitance variation δ2, measured on the second pin 610 is equal to
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`approximately zero, then it is determined that the first button 601 has been pressed.
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`(Ex. 1001 18:38-48.) Similarly, if the capacitance variation δ1, measured on the
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`first pin 609, is equal to the capacitance variation δ2 measured on the second pin
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`8
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`BLACKBERRY EX. 1006, pg. 8
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`610, then it is determined that the second button 602 has been pressed. (Ex.
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`1001 18:38-48.) If the capacitance variation δ1, measured on the first pin 609 is
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`equal to approximately zero, and the capacitance variation δ2, measured on the
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`second pin 610 is greater than zero, then it is determined that the third button 603
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`has been pressed. (Ex. 1001 18:38-48.)
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`V. CLAIM CONSTRUCTION
`In comparing the claims of the ‘973 patent to the known prior art, I
`25.
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`have carefully considered the ‘973 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 ‘973 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 1-8, 11, 12, and 14-20, whether directly or through
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`dependency, use the term “sense elements.” Under its broadest reasonable
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`construction in light of the specification, the term “sense element” should be
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`defined as “areas on which capacitance changes are to be measured.” The
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`specification of the ‘973 patent describes “sensor elements” as regions over which
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`the sensing device can discriminate the presence of a conductive object. For
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`example, the ‘973 patent states that “three or more button operations performed by
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`9
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`BLACKBERRY EX. 1006, pg. 9
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`the conductive object on three or more sensor elements” are realized on two pins of
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`a processing device. (Ex. 1001 3:6-9; see also 3:50 – 4:17, 17:50 – 18:22, 19:12 –
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`22:42, Figs. 5-7). The claim term “sense element” does not appear in the
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`specification, but appears to correspond to “sensor element” as used in the patent.
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`27. Each pin, in turn, corresponds to an electrically isolated sensing area.
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`“For example, a three-button scheme using two pins includes one sensor element
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`that has 100% of the first sensing area, the second sensor element has 50% of the
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`first sensing area and 50% of the second sensing area, and the third sensor element
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`has 100% of the second sensing area.” (Ex. 1001 3:50-54; see also Ex. 1001 3:54
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`– 4:17, 17:50 – 18:22, 19:12 – 22:42, Figs. 5-7). Because each sensing area, and
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`not sensor element or button area, corresponds to a pin on the processing device,
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`the ‘973 patent purports to provide an advantage over conventional sensing devices
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`that “require a one-to-one configuration of pins to touch sensor buttons.” (Ex.
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`1001 1:61 – 2:4, 3:17-33.)
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`28. This arrangement of pins directly corresponding to sensing areas, and
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`the number of sensor elements and button areas being greater than the number of
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`pins is consistently described throughout the specification. Claim 1 of the ‘973
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`patent also generally tracks this arrangement because, although the claim states
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`that there should be less sense elements than button areas, the claim does not
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`specify a number of pins corresponding to the sense elements.
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`10
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`BLACKBERRY EX. 1006, pg. 10
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`29. Accordingly, the term “sense element” has been interpreted to simply
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`correspond to an “area on which capacitance changes are to be measured,” which
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`encompasses a “sensing area” as described in the specification, or other area that
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`can be used to discriminate the presence of a conductive object based upon
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`capacitance changes.
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`VI. DESCRIPTION OF THE PRIOR ART
`The idea of using fewer sensors than the number of active buttons on
`30.
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`a capacitance sensing device predates the alleged invention of the ‘973 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
`Piguet issued on December 30, 1980 and describes a capacitive
`31.
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`sensing device formed of a plurality of electrodes that form “sensing areas” as
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`described in the specification of the ‘973 patent. The activation of Piguet’s electrodes
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`controls the device display. (Ex. 1004 Abstract, 3:13-21.)
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`32.
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`Piguet describes that the “N electrodes 101 of ... a sensor are capable
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`of defining 2N-1 different positions of ... [a] finger,” with buttons corresponding
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`to 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
`11
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`BLACKBERRY EX. 1006, pg. 11
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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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`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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`33.
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`I note that the Fig. 7 of Piguet, reproduced below, does not
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`precisely follow the described equation 2N-1 equals the number of button areas.
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`Rather, in Fig. 7, the number of button areas is equal to 2N, with N being the
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`number of electrodes. This difference is simply a result of the electrodes in Fig. 7
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`being arranged in a circle, rather than linearly and, with this arrangement, an extra
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`button area is realized based upon the combination of the first electrode and the
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`last electrode in sequence. In other words, when arranged in a circle, the
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`combination of the first and sixth electrodes 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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`34.
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`The above teaching of Piguet represents the precise feature that the
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`later-filed ‘973 patent alleges to be inventive – the detection of one or more button
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`operations when the presence of a conductive object is detected on two different
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`sensors. (See, e.g., Ex. 1001 Abstract, 2:55-60, 3:6-33.) As shown in Fig. 7 of
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`Piguet below, a capacitance sensing device may detect activation of buttons even
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`12
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`BLACKBERRY EX. 1006, pg. 12
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`when there are fewer sensors (labeled “senor elements”) than buttons (labeled “1”
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`through “9,” “F” and “C” in Fig. 7).
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` (Ex. 1004 Fig. 7)
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`35.
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`There is nothing novel or non-obvious about this feature of the
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`‘973 patent—it was well-known that a capacitance sensing device may use fewer
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`sensors than buttons to detect activation of the buttons. While Piguet applies this
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`concept of using fewer sensing areas than buttons to a one-dimensional sensing
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`device, where adjacent sensing areas are arranged along a line or circle, it was also
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`well-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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`on an array of sensing areas overlapping each other in the x and y directions—in
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`other words, on the rows and columns of sensing areas found in modern touch
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`sensitive displays.
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`13
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`BLACKBERRY EX. 1006, pg. 13
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`B. Overview of Binstead’s Teachings
`Binstead describes a multiple input touchpad system that can be
`36.
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`used 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. (Ex.
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`1002 6:66 – 7:6, Fig. 7.)
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`(Ex. 1002 Fig. 7)
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`37.
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`As shown in Fig. 7 of Binstead, which I have annotated above, it
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`was well-known in the art to arrange sensing areas in a two-dimensional array of
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`overlapping rows and columns, where each conductive element 12-2 through 12-4
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`14
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`BLACKBERRY EX. 1006, pg. 14
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`and conductive element 14-1 through 14-5 represents a separate sensing areas of
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`the described device.
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`C. Overview of Boie’s Teachings
`Boie describes a capacitive position sensor comprised of an
`38.
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`electrode array 100 of electrodes 101 arranged in a grid pattern of rows and
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`columns. (Ex. 1003 2:50-52.) The x and y location of a finger or other
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`conductive object can be determined based upon the centroid of capacitances
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`measured from the electrodes. (Ex. 1003 3:5-15.) As shown in Fig. 7 of Boie,
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`annotated below, the capacitance electrode array 100 is a 4x4 grid that includes 8
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`sensing areas defined by the horizontal rows 1-4 and the vertical columns 1-4.
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`Each element within a row is electrically connected with the other elements
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`within the same row, and each element within a column is electrically connected
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`to the other elements in the same column. (Ex. 1003 3:16-36, 3:52-56, Fig. 2.)
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`Thus, just as in Binstead, Boie teaches that each row and column of a sensor
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`array may constitute a separate sensing area.
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`15
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`BLACKBERRY EX. 1006, pg. 15
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`(Ex. 1003 Fig. 7)
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`39.
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`Boie also teaches that each square of the sensor array 100, such
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`as the area defined by the space x=2 and y=3 on the 4x4 grid of Fig. 7, may be
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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. (Ex. 1003 4:13-20, 6:62-64.)
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`40.
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`It is therefore my opinion, as explained in greater detail below,
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`that it was known to those of ordinary skill in the art that a capacitance sensing
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`device may use fewer sensing areas than buttons and, as a result, fewer pins than
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`buttons, to detect the presence of a conductive object in both one-dimensional and
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`two-dimensional sensor arrays.
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`VII. ANALYSIS
`It is my opinion that claims 1-8, 11, 12, and 14-20 of the ‘973 patent
`41.
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`are individually anticipated by Binstead and also by Boie. At the request of
`16
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`BLACKBERRY EX. 1006, pg. 16
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`counsel, I have divided the claims into elements denoted [preamble], [a], [b], [c],
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`etc. to correspond to the discussion of the same elements in the petition for inter
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`partes review
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`42. Claim 1, as annotated, reads as follows:
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`[Preamble] A method, comprising:
`[a] determining capacitance variations of a first number of two or more
`sense elements of a touch screen device
`[b] using a processing device to detect a presence of a conductive object on
`any one of a second number of three or more button areas of the touch
`screen device,
`[c] wherein the first number of sense elements is less than the second
`number of button areas; and
`[d] recognizing an activation of one of the three or more button areas using
`the determined capacitance variations of the first number of two or
`more sense elements.
`
`
`43. Claim 2, as annotated, reads as follows:
`
`[Preamble] The method of claim 1,
`[a] wherein the first number is two and the second number is three, and
`wherein the recognizing comprises:
`[b] detecting the presence of the conductive object at a first button area when
`the capacitance variation of a first sense element is greater than a
`reference value and the capacitance variation of a second sense element
`is not greater than the reference value;
`
`
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`17
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`BLACKBERRY EX. 1006, pg. 17
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`[c] detecting the presence of the conductive object at a second button area
`when the capacitance variation of the first sense element is not greater
`than the reference value and the capacitance variation of the second
`sense element is greater than the reference value; and
`[d] detecting the presence of the conductive object at a third button area
`when the capacitance variation of the first sense element and the
`capacitance variation of the second sense element are both greater
`than the reference value.
`
`
`44. Claim 3 reads as follows:
`
`The method of claim 2, wherein the determining the capacitance variations
`comprises measuring a first capacitance of the first sense element and
`a second capacitance of the second sense element.
`
`
`45. Claim 4 reads as follows:
`
`The method of claim 2, wherein the determining the capacitance
`variations comprises: measuring a first capacitance of the first
`sense element on a first pin of the processing device; and
`measuring a second capacitance of the second sense element
`on a second pin of the processing device.
`
`
`46. Claim 5 reads as follows:
`
`The method of claim 1, wherein the recognizing comprises: determining a
`combination of the capacitance variations of the first number of two or
`more sense elements; and recognizing the activation using the
`determined combination.
`
`
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`18
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`BLACKBERRY EX. 1006, pg. 18
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`47. Claim 6 reads as follows:
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`The method of claim 1, wherein the second number is nine, and wherein the
`recognizing comprises recognizing the activation of one of the nine
`button areas using the determined capacitance of the first number of
`two or more sense elements.
`
`
`48. Claim 7 reads as follows:
`
`An apparatus comprising:
`
`a processing device coupled to a first number of two or more sense elements
`of a touch screen device, wherein the processing device is configured
`to determine capacitance variations of the first number of two or more
`sense elements to detect a presence of a conductive object on any one
`of a second number of three or more buttons areas of the touch screen
`device, wherein the first number of sense elements is less than the
`second number of button areas, and wherein the processing device is
`configured to recognize an activation of one of the three or more
`button areas using the determined capacitance variations of the first
`number of two or more sense elements.
`
`
`49. Claim 8, as annotated, reads as follows:
`
`[Preamble] The apparatus of claim 7,
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`[a] wherein the first number is two and the second number is three, and
`wherein the processing device is configured to:
`[b] detect the presence of the conductive object at a first button area when
`the capacitance variation of a first sense element is greater than a
`
`
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`19
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`BLACKBERRY EX. 1006, pg. 19
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`reference value and the capacitance variation of a second sense
`element is not greater than the reference value;
`[c] detect the presence of the conductive object at a second button area when
`the capacitance variation of the first sense element is not greater than the
`reference value and the capacitance variation of the second sense
`element is greater than the reference value; and
`[d] detect the presence of the conductive object at a third button area when
`the capacitance variation of the first sense element and the capacitance
`variation of the second sense element are both greater than the
`reference value.
`
`
`50. Claim 11, as annotated, reads as follows:
`
`[Preamble] The apparatus of claim 7,
`[a] wherein the first number is two and the second number is three, and
`wherein the processing device is configured to:
`[b] detect a conductive object proximate to a first button area based on a first
`change in capacitance of a first sense element;
`[c] detect the conductive object proximate to a second button area based on a
`first change in capacitance of a second sense element; and
`[d] detect the conductive object proximate to a second button area based on a
`second change in capacitance of the first sense element and a second
`change in capacitance of the second sense element.
`
`
`
`
`
`20
`
`BLACKBERRY EX. 1006, pg. 20
`
`

`

`51. Claim 12 reads as follows:
`
`The apparatus of claim 7, wherein the processing device comprises one or
`more capacitance sensing circuits configured to measure capacitance
`of the first number of two or more sense elements.
`
`
`52. Claim 14 reads as follows:
`
`The apparatus of claim 12, wherein the processing device comprises a first
`pin coupled to one or more capacitance sensing circuits; and a second
`pint [sic] coupled to one or more capacitance sensing circuits.
`
`
`53. Claim 15 reads as follows:
`
`The apparatus of claim 7, wherein the processing device is configured to
`determine a combination of the capacitance variations of the first
`number of two or more sense elements and to recognize the activation
`using the determined combination.
`
`
`54. Claim 16 reads as follows:
`
`The apparatus of claim 7, wherein the second number is nine, and wherein
`the processing device is configured to recognize the activation of one
`of the nine button areas using the determined capacitance variations of
`the first number of two or more sense elements.
`
`
`55. Claim 17, as annotated, reads as follows
`
`[Preamble] A system comprising:
`
`
`
`21
`
`BLACKBERRY EX. 1006, pg. 21
`
`

`

`[a] a touch screen device comprising a first number of two or more sense
`elements and a second number of three or more button areas, wherein
`the first number of sense elements is less than the second number of
`button areas; and
`[b] a processing device coupled to the touch screen device, wherein the
`processing device is configured to determine capacitance variations of
`the two or more sense elements of the touch screen device, and to
`recognize an activation of one of the three or more buttons areas using
`the capacitance variations of the two or more sense elements.
`
`
`56. Claim 18, as annotated, reads as follows:
`
`[Preamble] The system of claim 17,
`
`[a] wherein the first number is two and the second number is three, and
`wherein the processing device is configured to:
`[b] detect the presence of the conductive object at a first button area when
`the capacitance variation of a first sense element is greater than a
`reference value and the capacitance variation of a second sense
`element is not greater than the reference value;
`[c] detect the presence of the conductive object at a second button area when
`the capacitance variation of the first sense element is not greater than
`the reference value and the capacitance variation of the second sense
`element is greater than the reference value; and
`[d] detect the presence of the conductive object at a third button area when
`the capacitance variation of the first sense element and the capacitance
`variation of the second sense element are both greater than the
`reference value.
`
`
`
`22
`
`BLACKBERRY EX. 1006, pg. 22
`
`

`

`57. Claim 19 reads as follows:
`
`The system of claim 17, wherein the processing device is configured to:
`determine a combination of the capacitance variations of the two or
`more sense elements; and recognize the activation using the
`determined combination.
`58. Claim 20 reads as follows:
`
`The system of claim 17, wherein the second number is nine, and wherein the
`processing device is configured to recognize the activation of one of
`the nine button areas using the determined capacitance variations of
`the two or more sense elements.
`
`
`A. CLAIMS 1-8, 11, 12, and 14-20 ARE ANTICIPATED BY
`BINSTEAD
`Claim 1[a]: “determining capacitance variations of a first number of
`two or more sense elements of a touch screen device”
`
`59. Binstead describes a multiple input touchpad system that can be used
`
`as a touchscreen, for example, where predetermined areas of the touchpad are
`
`interpreted as discrete keypads or boxes. (Ex. 1002 1:17-20, 2:18-22.) Binstead
`
`employs interpolation so that the number of keys or boxes can be arbitrarily
`
`arranged over the surface of the touchpad, and the number of keys or “boxes” may
`
`be greater than the number of sense elements. (Ex. 1002 6:66 – 7:6, Fig. 7.)
`
`
`
`23
`
`BLACKBERRY EX. 1006, pg. 23
`
`

`

`(Ex. 1002 Fig. 7)
`
`60. Binstead provides “a multiple input proximity detector in which the
`
`juxtaposition of two or more independent sensor inputs are used to determine the
`
`proximity of a finger.” (Ex. 1002 2:63-66.) The touchpad comprises “an
`
`electrically insulating membrane with a first series of spaced apart conductors
`
`[elements 12] on a first face of the membrane and a second series of spaced apart
`
`conductors [elements 14] on or proximal thereto, in which there is no electrical
`
`contact between the first and second series of conductors, each conductor 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
`
`3:7-14, interpolation added; see also Ex. 1002 3:47-55.)
`
`61.
`
`“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.) Thus, it is my opinion that the
`
`first series of conductor elements 12 and the second series of conductor elements
`24
`
`
`
`BLACKBERRY EX. 1006, pg. 24
`
`

`

`14 teaches “a first number of two or more sense elements of a touch screen
`
`device,” as I now described in greater detail.
`
`62. Binstead Fig. 6 shows that conductor elements 12-1 through 12-n and
`
`conductor elements 14-1 through 14-n form an x and y matrix. (Ex. 1002 6:52-54).
`
`(Ex. 1002 Fig. 6)
`
`63. Specifically, Binstead describes that “[a] finger or other object at
`
`position 40 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 12-1 compared with element
`
`12-2.” (Ex. 1002 6:54-58.)
`
`64. As shown in Fig. 8, each conductor element is connected at one end to
`
`resistor 71 and at the other end to multiplexer 75 to output line 72. (Ex. 1002 6:2-
`
`12.) Further, “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
`25
`
`
`
`BLACKBERRY EX. 1006, pg. 25
`
`

`

`operative to receive the data from divide-by-

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