`v.
`DSS Technology Management Inc.
`
`Cases: IPR2015-00369 and IPR2015-00373
`
`U.S. Patent No. 6,128,290
`
`Petitioner’s Demonstratives
`
`APL 1016
`IPR2015-00369
`
`
`
`’290 Patent - Independent Claim 1
`
`“…said server and peripheral
`transmitters being energized in
`low duty cycle RF bursts at
`intervals determined by a code
`sequence which is timed in relation
`to said synchronizing information.”
`
`
`
`APL 1001, ’290 Patent, 11:62-12:19 APL 1001, ’290 Patent, 11:62-12:19
`
`1
`
`
`
`’290 Patent - Independent Claim 9
`
`“…said server and peripheral
`transmitters being energized in low
`duty cycle RF bursts at intervals with
`said receivers being controlled by the
`respective oscillators.”
`
`
`
`APL 1001, ’290 Patent, 13:26-14:11 APL 1001 ’290 Patent 13:26 14:11
`
`2
`
`
`
`’290 Patent (APL 1001) - Overview
`
`
`
`APL 1001, ’290 Patent, 1:48-61
`
`3
`
`
`
`Natarajan (APL 1003) - Overview
`
`
`
`APL 1003, Natarajan, FIG. 4, FIG 5, 4:20-26 APL 1003 Natarajan FIG 4 FIG 5 4:20-26
`
`4
`
`
`
`Neve (APL 1004) - Overview
`
`IPR2015-00369, Petitioner Reply, Paper 24, p. 16
`
`5
`
`
`
`Alleged Missing Element of Claims 1 and 9:
`“said server and peripheral transmitters being energized in low
`duty cycle RF bursts”
`
`• The Board was correct in finding that Natarajan discloses this element:
`
`IPR2015-00369, Institution Decision, Paper 9, p. 19
`
`6
`
`
`
`Alleged Missing Element of Claims 1 and 9:
`“said server and peripheral transmitters being energized in low
`duty cycle RF bursts”
`
`• A POSA would have understood that Natarajan’s base station operates in
`a similar manner as the mobile units:
`
`APL 1014, Hu Dec., ¶ 44
`
`7
`
`
`
`Alleged Missing Element of Claims 1 and 9:
`“said server and peripheral transmitters being energized in low
`duty cycle RF bursts”
`• At the very least, this feature would have been obvious to a POSA:
`
`
`
`APL 1014, Hu Dec., ¶ 45 ., ¶ 45
`
`8
`
`
`
`"Low Duty Cycle":
`Patent Owner's Narrowing Position
`• IPR2015-00369, Patent Owner Preliminary Response, Paper 8, p. 20
`
`• IPR2015-00369, Patent Owner Response, Paper 17, p. 11
`
`9
`
`
`
`"Low Duty Cycle":
`Mr. Dezmelyk's Incorrect Characterizations
`• APL 1011, Dezmelyk Depo. Transcript, 116:8-10
`
`• APL 1011, Dezmelyk Depo. Transcript, 106:2-4
`
`• APL 1011, Dezmelyk Depo. Transcript, 79:9-11
`
`10
`
`
`
`"Duty Cycle": Proper Interpretation
`
`APL 1014, Hu Dec., ¶ 79
`
`11
`
`
`
`Natarajan's "Duty Cycle"
`
`APL 1014, Hu Dec., ¶¶ 83-84
`
`12
`
`
`
`Natarajan Operates in a "Low Duty Cycle"
`Under Any Interpretation
`
`APL 1014, Hu Dec., ¶¶ 86, 88
`
`13
`
`
`
`HDLC is compatible with “said server and peripheral
`transmitters being energized in low duty cycle RF bursts”
`
`• The ’290 Patent uses HDLC:
`
`APL 1001, ’290 Patent, 9:66-10:4
`
`14
`
`
`
`HDLC is compatible with “said server and peripheral
`transmitters being energized in low duty cycle RF bursts”
`
`• DSS’s declarant, Mr. Dezmelyk, is not an expert in HDLC. (APL 1011,
`Dezmelyk Depo. Transcript, 26:15-16)
`
`• Apple’s declarant, Dr. Hu, is an expert in HDLC. (DSS 2018, Hu Depo.
`Transcript, 14:12-17)
`
`15
`
`
`
`HDLC is compatible with “said server and peripheral
`transmitters being energized in low duty cycle RF bursts”
`
`• Schwartz (APL 1012) is the most logical resource for information on
`Natarajan’s HDLC packet structure:
`
`APL 1003, Natarajan, 3:37-40
`
`16
`
`
`
`HDLC is compatible with “said server and peripheral
`transmitters being energized in low duty cycle RF bursts”
`
`• Schwartz provides a concise summary of the HDLC frame format:
`
`APL 1012, Schwartz, pp. 135-136
`
`17
`
`
`
`HDLC is compatible with “said server and peripheral
`transmitters being energized in low duty cycle RF bursts”
`
`• The base station transmitter does not continuously transmit under the
`HDLC protocol:
`
`APL 1012, Schwartz, p. 144
`
`18
`
`
`
`HDLC is compatible with “said server and peripheral
`transmitters being energized in low duty cycle RF bursts”
`
`• DSS’s arguments are inconsistent with the HDLC protocol:
`
`APL 1014, Hu Dec., ¶ 59
`
`19
`
`
`
`DSS’s “idle words” argument is a red herring
`
`APL 1014, Hu Dec., ¶ 73
`
`20
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