`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` ____________
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`SONY COMPUTER ENTERTAINMENT AMERICA LLC
`Petitioner
`
`v.
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`APLIX IP HOLDINGS CORPORATION
`Patent Owner
`
`____________
`
`Case No. IPR2015-00476
`Patent 7,218,313
` ____________
`
`
`
`SUPPLEMENTAL DECLARATION OF DR. GREGORY F. WELCH
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`SCEA Ex. 1042 Page 1
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`I, Gregory F. Welch, hereby declare the following:
`1.
`I have been asked to respond to certain issues raised by Patent Owner
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`(“PO”) and their experts, Dr. Karon MacLean and Mr. Peng Lim, in Patent Owner
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`Aplix IP Holdings Corporation’s Response to the Petition dated August 27, 2015
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`(“Paper No. 15”). All of my opinions expressed in my original declaration dated
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`December 23, 2014 (Ex. 1009) remain the same. I have reviewed the following
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`additional materials in connection with preparing this supplemental declaration:
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`Paper No. 11, Decision Institution of Inter Partes Review dated June
`22, 2015;
`Paper No. 15, Patent Owner Aplix IP Holdings Corporation’s
`Response to the Petition dated August 27, 2015;
`Ex. 2007, Declaration of Dr. Karon MacLean dated August 27, 2015;
`Ex. 2009, Declaration of Peng Lim dated August 27, 2015;
`Ex. 2025, Elo Touch Solutions: Tyco Electronics Introduces the
`Industry's First Multi-Touch Gestures Technology
`for Analog
`Resistive Touchscreens, December 4, 2008;
`Ex. 2030, PCMag.com review: Fingerworks iGesture Pad, February
`3, 2004;
`Ex. 1029, James Orr, FingerWorks Announces the iGesture Pad – A
`mousepad with a brain., Fingerworks Inc. dated October 22, 2001,
`http://web.archive.org/web/20020426094703/http://www.fingerworks.
`com/press_release_2.htm (accessed 11/19/2015);
`Ex. 1030, Sally McGrane, No Press, No Stress: When Fingers Fly,
`The
`New
`York
`Times,
`January
`24,
`2002,
`http://www.nytimes.com/2002/01/24/technology/no-press-no-stress-
`when-fingers-fly.html (accessed 11/19/2015);
`Ex. 1031, SK. Lee, W. Buxton, K.C. Smith, A Multi-Touch Three
`Dimensional Touch-Sensitive Tablet, ACM CHI ’85 Proceedings,
`April 1985, pp. 21-25;
`Ex. 1033, Greg Welch and James P. Williams. The easy chair: A
`microprocessor-controlled wheelchair for children with muscular
`disorders. Purdue University, E.E.T. 490/491 Senior Design Project,
`Final Report, May 1986;
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`1
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`SCEA Ex. 1042 Page 2
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`I.
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`Ex. 1034, Greg Welch. The infrared touch-pad. Purdue University,
`E.E.T. 421 Report, February 26, 1986;
`Ex. 1035, Greg Welch and James P. Williams. The easy chair: A
`microprocessor-controlled wheelchair for children with muscular
`disorders. Purdue University, E.E.T. 490/491 Senior Design Project,
`Preliminary Report, December 1985;
`Ex. 1036, James Williams and Greg Welch. The pressure sensitive
`touch-pad. Purdue University, E.E.T. 454 Project Report, April 30,
`1985;
`Ex. 1037, Transcript of the deposition of Dr. Karon MacLean taken in
`IPR2015-00396, IPR2015-00476, and IPR2015-00533, November 20-
`21, 2015;
`Ex. 1051, AMD Élan™SC400 and ÉlanSC410, Advanced Micro
`Devices, Inc., Publication No. 21028, Rev. B, December 1998;
`Ex. 1052, ARM610 Datasheet, Advanced RISC Machines Ltd,
`Document Number: ARM DDI 0004D, August 1993;
`Ex. 1053, Acorn Computers Limited. Acorn RISC Machine (ARM)
`IOC Datasheet, September 1986; and
`Ex. 1054, Advanced RISC Machines (ARM). ARM250 Datasheet,
`August 1992.
`
`OPINION
`A. Multi-Touch Sensing Is Explicitly Taught by Liebenow And Was
`Well-Known in 2003
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`2.
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`In her declaration dated 27 August 2015, Dr. MacLean offers various
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`opinions regarding touch sensing as related to the combination of Pallakoff and
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`Liebenow offered in the ‘476 Petition and in my previous declaration (Ex. 1009).
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`See Ex. 2007 at ¶¶ 81-90. In particular, Dr. MacLean opines that Pallakoff
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`“requires simultaneous activation of multiple modifier buttons” and
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`that
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`“Liebenow teaches a single function for its two back-surface touch panels: data
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`entry through typing. Liebenow makes no mention of simultaneously activating
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`SCEA Ex. 1042 Page 3
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`back-surface keyboard elements.” Id. at ¶¶ 81-82. Dr. MacLean then opines that a
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`person of ordinary skill in the art would understand that the touchpad technologies
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`taught by Liebenow, including resistive, capacitive, and ultrasonic touchpads,
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`would only sense single touches and would therefore be incapable of detecting
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`simultaneous activation of multiple modifier buttons as required by Pallakoff. Id.
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`at ¶¶ 81-83, ¶ 90. For reasons discussed below, I respectfully disagree.
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`3. Dr. MacLean opines, “Liebenow notably never raises the possibility of
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`multiple simultaneous touches being sensed.” Id. at ¶ 83. However, Liebenow
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`explicitly discloses this capability—indeed some of Liebenow’s teachings rely on
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`multiple simultaneous touches being sensed. In particular, Figure 14 of Liebenow
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`“is a flow diagram illustrating a method of aiding a user in entering information
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`into the digital information appliance by displaying indicia on the display for
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`helping locate the keys of the input device.” Ex. 1005 at [0022]. As depicted in
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`Figure 14, which is reproduced below, Step 606 calls for the touch panels to
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`“SENSE POSITION OF USER’S FINGERS” (emphasis added):
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`SCEA Ex. 1042 Page 4
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`Id. at Fig. 14.
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`4.
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` Regarding Step 606, Liebenow teaches the following:
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`
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`Referring again to FIG. 14, in an exemplary embodiment, the
`digital information appliance may further sense the position of
`the fingers of the user's hand relative to the keys of the input
`device, at step 606. For example, wherein the input device is
`comprised of a touch sensitive panel utilizing resistive or
`capacitive
`touch pad
`technology, as discussed
`in
`the
`descriptions of FIGS. 3 and 9, the touch sensitive panel may
`detect the position of the user's fingers while resting on or
`being held in close proximity to its surface. Indicia showing
`the position of the user's fingers relative to the keys of the
`input device may then be displayed, at step 608, as part of the
`indicia displayed at step 602. As shown in FIGS. 15 and 16,
`these indicia 710 may in one embodiment be comprised of
`representations 712 of the user's fingers depicting the
`positions of the fingers relative to the keys of the input device.
`Preferably, the finger representations 712 are lenticular or semi-
`transparent and overlay the key representations 704 and other
`information 706 displayed on the display 708 such that the key
`representations 704 and information 706 remain viewable.
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`4
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`SCEA Ex. 1042 Page 5
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`Wherein the position of any of the user's fingers relative to the
`keys of the input device changes, as, for example, while typing
`on the keyboard, the digital information appliance may then
`sense the new finger position (at step 610 of FIG. 14) and alter
`the displayed indicia (e.g., redisplay the finger representations
`at step 608), accordingly.
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`Id. at [0067] (emphasis added). Therefore, Liebenow explicitly teaches “utilizing
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`resistive or capacitive touch pad technology” to sense the positions of the user’s
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`fingers that are simultaneously resting on or being held in close proximity to the
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`touch pad for the purpose of providing visual feedback to the user on the display.
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`Id.
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`5.
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`The visual feedback concerning the positions of the user’s fingers is
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`shown in several figures including Figs. 15 and 16, which depict the overlaid
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`finger position representations 712 being displayed on the display 708:
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`Id. at Fig. 16. All of these examples in Liebenow (Ex. 1005) teach multiple
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`“fingers,” “positions,” and “indicia” (all plural), including all of the cited text
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`5
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`SCEA Ex. 1042 Page 6
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`above, and figures such as the flow chart in Fig. 14 and the graphical renderings in
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`Figs. 1, 7, 15, and 16.
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`6. While Liebenow may focus on one emulated key when describing the
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`act of actuating/depressing an emulated key, a skilled artisan would have realized
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`that the ability of the touch pad to simultaneously sense the positions of all of the
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`user’s fingers as explicitly taught by Liebenow would have enabled the user to
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`actuate multiple emulated keys simultaneously assuming a threshold level of
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`pressure was applied to the actuated keys. Id. at [0037] (“In an exemplary
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`embodiment, the touch sensitive panel 140 may comprise a resistive touch pad
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`suitable for generating an analog signal proportional to the amount of pressure
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`applied by the user's fingertips. . . . In the present invention, such resistive touch
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`pads would allow the user to rest his or her fingertips on the pad's surface without
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`inadvertently actuating a key. The touch pad could then sense an increase in
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`pressure applied to its surface as the user attempts to actuate a key. This increase in
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`pressure would be registered as a key press, and the information corresponding to
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`that key (i.e., the character or function) would be entered.”).
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`7. Regarding the background knowledge of a person having ordinary skill
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`in the art, Dr. MacLean seems primarily focused on alleged issues in three areas
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`related to the touch sensing aspects of the combined teachings of Pallakoff and
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`Liebenow, including: (1) the popularity of interaction techniques such as
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`SCEA Ex. 1042 Page 7
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`“multitouch,” (2) specific hardware
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`technology approaches, (3) commercial
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`availability of the technology. I respectfully disagree with Dr. MacLean on all
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`points related to each of these areas.
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`8. With respect to the first point, it is important to distinguish between the
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`affordances of the technology (hardware) and application-specific interaction
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`techniques (software) that make use of that technology. For example, Dr.
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`MacLean states “Multitouch variants and interaction techniques that exploited
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`them attained substantial visibility by the mid 1980’s (e.g., Ex. 2012, Buxton, at p.
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`1), and appeared in some commercial settings, e.g. air traffic control terminals
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`even earlier, in the 1960’s (Ex. 2017, Walker, p. 413).” Ex. 2007 at ¶ 37 (emphasis
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`added); “The iPhone, responsible for massively popularizing multitouch input in
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`handhelds, was released in 2007.” Id. at ¶ 39 (emphasis added); and “No multi-
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`touch gestures are alluded to (and indeed these would be unusual, if not unheard
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`of, in 2003).” Id. at ¶ 82 (emphasis added). The “multitouch” and “multi-touch”
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`Dr. MacLean refers to are very distinctive techniques for using fingers on touch
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`surfaces or displays to interact with data on a device. Common examples would
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`include the multitouch gesture techniques employing one or more fingers to resize
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`or rotate photos directly on the display of a device. To realize such interaction
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`techniques, the device must of course support the sensing of multiple simultaneous
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`discrete and continuous touch locations. As I discuss below, hardware has had the
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`SCEA Ex. 1042 Page 8
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`ability to sense multiple simultaneous touch locations for long before the ‘313
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`Patent.
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`9. Dr. MacLean appears to conflate the ability of hardware to detect
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`multiple simultaneous touches with the interaction techniques provides by software
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`to interpret complex multi-finger gestures. Ex. 2007 at ¶ 82 (“No multi-touch
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`gestures are alluded to (and indeed these would be unusual, if not unheard of, in
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`2003).”); Ex. 1037, MacLean Tr. at 243:13-18 (“What kind of multi-finger
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`gestures would describe the level of multi-touch you refer to? A. Gestures where
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`multiple fingers were definitively being sensed at the same time. The position of
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`multiple sensors -- of multiple fingers were being sensed at the same time.”) For
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`example, Dr. MacLean relies on a Tyco Electronics press release to show that
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`resistive touchpads were not available until 2007. Ex. 2007 at ¶ 84. However, this
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`press release describes the Tyco product’s ability to interpret multi-touch gestures
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`as the innovative feature. Ex. 2025, Tyco Electronics Introduces the Industry’s
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`First Multi-Touch Gestures Technology for Analog Resistive Touchscreens, (“Tyco
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`Electronics Elo TouchSystems, a global leader in touch technology, has developed
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`a proprietary technology that enables realtime, two finger gesture recognition on
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`analog resistive touchscreens. The new technology, named Resistive Gestures,
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`provides a richer user experience via intuitive gestures which until now had been
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`8
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`SCEA Ex. 1042 Page 9
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`possible only with higher end, costlier technologies such as projected capacitive.”)
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`(emphasis added).
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`10.
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`In order to implement the back surface touch panel of Liebenow on the
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`device of Pallakoff, the touch panel need not interpret multi-touch gestures as
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`implied by Dr. MacLean. Rather, all that would be needed is a surface capable of
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`detecting simultaneous multiple touches (e.g., first and second modifier buttons),
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`which, as discussed above, is explicitly taught by Liebenow, and as discussed
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`below, was also well known in the art at the time of the ‘313 patent.
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`11. Focusing on the specific hardware technology approaches (the second
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`point above), touch sensing in general can be accomplished via a variety of
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`mechanisms, including what are commonly called capacitive and resistive
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`methods. A person of ordinary skill in the art at the time would have been fully
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`aware of these and other common approaches (I provide some examples below)
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`and would have been capable of choosing the approach best suited to their
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`circumstances. For example, during my senior year of undergraduate studies at
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`Purdue University (1985-1986), when I was a person of considerably less
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`experience than a person of ordinary skill at the time of the ‘313 Patent, I co-
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`developed both resistive and optical touch pads as part of a senior project to
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`develop a computer-controlled wheelchair for children with muscular disorders
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`such as Cerebral Palsy. See, Exs. 1033, 1034, 1035, 1036. Our resistive touch pad
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`SCEA Ex. 1042 Page 10
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`for example used a two-dimensional array of conductive foam squares that
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`behaved as variable resistors, and multiplexing circuitry to repeatedly scan the
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`rows and columns, looking for decreased resistance (an indication of pressure on a
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`square). For the final prototype we used a two-dimensional optical approach to
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`avoid issues with the presence of saliva common to some of the children: In our
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`final report we stated “The current method of using infrared light beams, was
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`decided upon for various reasons. First of all, other touch-pad schemes such as
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`capacitive touch sensing, and pressure sensitive membrane type keypads, are all
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`open to problems because they are affected by water, or saliva in this case.
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`Secondly (and most important), breaking a light beam requires the least amount of
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`pressure of any method studied.” Ex. 1033 at p. 9 (emphasis added). So my
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`undergraduate project partner and I—both with considerably less skill than a
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`person of “ordinary skill” in the context of this case—knew about capacitive,
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`resistive, and optical approaches and were capable of choosing the approach that
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`best suited our circumstances. Indeed, there is no question in my mind that such
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`basic input technology would have been known to person of ordinary skill at the
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`time of the ‘313 Patent, as defined in my original declaration. Ex. 1009 at ¶ 36.
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`Such a person of ordinary skill would likely have seen such technology mentioned
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`in a lecture or book in their undergraduate studies; even more likely if they had a
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`“working knowledge of computers - including handheld computing devices, and
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`SCEA Ex. 1042 Page 11
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`their processing, storage, hardware—including input devices, and software;” and
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`certainly if they had “two to four years of experience (or, with a graduate degree in
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`the above-stated fields, one to two years of experience) with designing and
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`developing human-computer interfaces and the associated technologies.” Id.
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`12. Multitouch sensing technology was known/taught at least as early as
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`the timeframe of my senior project above (1985-1986). For example, in April of
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`1985 Lee, Buxton, and Smith presented their paper “A multi-touch three
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`dimensional touch-sensitive tablet” at the ACM SIGCHI Conference on Human
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`Factors in Computing Systems in which they presented their prototype “fast
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`multiple-touch-sensitive input device.” See Ex. 1031, Lee et al. The prototyped
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`tablet device uses a capacitive touchscreen to sense a number of simultaneous
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`points of contact. Id. at p. 21 (“The transducer that we have developed is a touch-
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`sensitive tablet; that is, a flat surface that can sense where it is being touched by the
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`operator's finger. This in itself is not new. Several such devices are commercially
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`available from a number of manufacturers (see Appendix A). What Is unique about
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`our tablet Is that it combines two additional features. First, It can sense the degree
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`of contact in a continuous manner. Second, it can sense the amount and location of
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`a number of simultaneous points of contact.”). In the paper they stated “But why
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`do we want multiple point sensing? A simple example would be if we had a
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`template placed over the tablet which delimited three regions of 9 cm by 2 cm.
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`SCEA Ex. 1042 Page 12
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`Where we touch each region could control the setting of a parameter associated
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`with each region. If we wanted to simultaneously adjust all three parameters, then
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`we would have to be able to sense all three regions. An even easier example is
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`using the tablet to emulate a piano keyboard that can play polyphonic music.” Id.
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`at p. 21 (emphasis added).
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`13. Dr. MacLean also asserts that “In 2003, resistive touchpads were not
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`commonly used to support sensing of multiple touches.” and “While the “resistive”
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`method can be made to work in a multitouch configuration, and commonly is used
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`this way today, this advance entered engineering practice and made first
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`appearances in products around 2007-2008.” Ex. 2007 at ¶ 84. I am unsure why
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`Dr. MacLean feels “advance entered engineering practices” and commercial
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`products are required to teach a person of ordinary skill how to practice the alleged
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`invention of the ‘313 Patent, but as indicated above I personally co-developed a
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`resistive touchpad while an undergraduate at Purdue University in 1985. I did not
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`have access to advance entered engineering facilities nor knowledge of such
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`practices. More generally, it appears Dr. MacLean was not aware of publically
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`available prior art in this area. In addition to Liebenow’s teachings regarding
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`multi-touch sensing on resistive touch pads discussed above, Dr. MacLean was
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`also apparently unaware of US Patent 5,181,030 to Itaya et al. (“Itaya”) titled Input
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`System Including Resistance Film Touch Panel and Pushed Position Detecting
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`Device, and having issued on January 19, 1993. Ex. 1028, Itaya. Itaya teaches “an
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`input system including a resistance film touch panel and a pushed position
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`detecting device for accurately detecting two or more positions pushed
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`simultaneously with a minimized number of leads.” Id. at 2:6-9 (emphasis added);
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`see also, id. at Fig. 6 reproduced below:
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`Id. at Fig. 6.
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`14. Regarding capacitive touch pads, Dr. MacLean opines “Capacitive
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`multi-touch sensing was demonstrated in a laboratory context well before 2003. . . .
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`However, capacitive multi touch sensing does not seem to have been available in
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`handheld-size formats by 2003 . . . .” Ex. 2007 at ¶ 89. Dr. MacLean appears to
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`have missed the teachings of Liebenow discussed above, and other prior art
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`references already of record that demonstrate capacitive multi touch sensing in
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`handheld-size formats. Indeed, two references cited in my original declaration
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`(and apparently not considered by Dr. MacLean) demonstrate the contrary. For
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`SCEA Ex. 1042 Page 14
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`example, I cited to U.S. Patent No. 5,543,588 to Bisset et al. (Ex. 1017) in my
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`original declaration to show that placing touchpads on the back of handheld
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`devices has been well known in the art since the 1990s. Ex. 1009 at ¶ 31. The
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`touchpad described by Bisset is a capacitive touchpad that can “can detect and
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`report if one or more points are being touched.” Ex. 1017 at 5:1-5.
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`15. Another example is U.S. Patent No. 7,088,342 to Rekimoto et al. (Ex.
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`1006), which I also described in my original declaration. Ex. 1009 at ¶¶ 56-58.
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`Rekimoto also describes a capacitive touchpad on the back of a handheld device,
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`such as a PDA, that can detect multiple simultaneous touches as shown in the
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`figure below:
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`
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`Ex. 1006 at Fig. 8; see also, id. at Fig. 4B, 4:45-52 (“When a finger touches the
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`concave 100 a on the back surface of the PDA 100, the capacitance between
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`adjacent electrodes of the first group 121 and the second group 122 varies due to
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`capacitive coupling between the finger touching the concave 100 a and the
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`SCEA Ex. 1042 Page 15
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`adjacent electrodes of the first group 121 and the second group 122. A variation in
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`the capacitance is electrically measured to detect a touch and the touch position is
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`also found.”), Fig. 7C (reproduced below) and 8:7-23 (“The back-surface touch
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`sensor of the data processing terminal 200 can detect a plurality of positions
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`simultaneously. As shown in FIG. 7C, touch position pointers 213 and 214
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`corresponding-to the respective touch positions of a finger f2 of a left hand Lh and
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`a finger f3 of a right hand Rh on the back surface may be displayed with the data
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`processing terminal 200 held with a left hand Lh and a right hand Rh. When a
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`plurality of positions is touched simultaneously, a particular input operation may
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`be performed on the data processing terminal 200 so that the two touch positions
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`move apart in the respective arrow directions in FIG. 7C (or the reverse operation).
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`For example, when the data processing terminal 200 is operated so that the two
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`touch positions are moved apart, characters and graphics displayed may be
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`enlarged; and when operated so that the two touch positions are moved closer, the
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`characters and graphics may be reduced.”). See Fig. 7C included below:
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`SCEA Ex. 1042 Page 16
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`Id. at Fig. 7C.
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`16. As I discussed above, Lee also developed a prototype of a handheld
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`tablet device with a multi-touch touchscreen in 1985. Ex. 1031. These are just a
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`few examples of capacitive multi-touch sensing in handheld size formats that were
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`known before the ‘313 patent. As such, a person having ordinary skill in the art
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`would not have encountered any difficulties enabling the modified device of
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`Pallakoff to detect multiple simultaneous touches as this technology would have
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`been well within the background knowledge of a skilled artisan. Additionally, a
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`person of ordinary skill in the art at the time would have been fully aware of at
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`least the different technological approaches to sensing one or more fingers
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`described above, and would be capable of choosing the approach best suited to
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`their circumstances.
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`SCEA Ex. 1042 Page 17
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`17. Finally, MacLean seems to believe that commercial availability of the
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`technology is a requirement to enable a person of ordinary skill at the time of the
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`‘313 Patent to practice the alleged invention. Dr. MacLean opines that “Capacitive
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`multi-touch sensing was demonstrated in a laboratory context well before 2003.
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`However, capacitive multi touch sensing does not seem to have available in
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`handheld-size formats by 2003; the earliest relevant commercial product was
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`released in early 2004, the Fingerworks’ iGesture Pad, which retailed briefly for
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`$189 before the company was acquired by Apple and its technology incorporated
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`into the iPhone. Ex. 2030.”1 Ex. 2007 at ¶ 89 (emphasis in original). However, it is
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`my understanding that a lack of evidence of commercial realization is irrelevant.
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`Many things are possible that are not commercialized for many reasons. The
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`relevant question is whether or not the various methods for touch sensing were
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`known to a person of ordinary skill and realizable at the time of the ‘313 Patent—
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`and they were.
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`B. Liebenow’s Input Controller is Compatible with the Device of
`Pallakoff
`18. Regarding claims 23 and 55, Mr. Lim opines that Liebenow “is a tablet
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`computer similar to the typical architecture for personal computers such as laptops,
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`notebooks, and other similar personal computers.” Ex. 2009 at ¶ 74. Based on this
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`1 I note that Dr. MacLean relies the date of a product review as evidence of a 2004 release date for the
`iGesture Pad. Ex. 2030. However, the original press release for the iGesture Pad indicates that it
`was commercially available as early as November 2001. Ex. 1029; see also, Ex. 1030.
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`SCEA Ex. 1042 Page 18
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`assumption, Mr. Lim further assumes that in 2003 an Intel or AMD processor “are
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`typically used in PC . . . architecture like Liebenow.” Id. at ¶ 76. And then further
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`assumes that “Liebenow controller/chipset is CPU specific. Since PC architecture
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`like Liebenow is Intel/AMD x86 based processor, Liebenow chipset would only
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`work with one of these CPUs.” Id. at ¶ 80. Based on the assumption that
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`Liebenow’s input controller would only work with an Intel/AMD x86 based
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`processor for a personal computer, Mr. Lim concludes that the handset described
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`by Pallakoff would not support the input controller taught by Liebenow. Id. at ¶¶
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`78-79, ¶ 81.
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`19. Mr. Lim’s assumptions and resulting conclusions are incorrect on
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`multiple levels. First, nowhere does Liebenow support the notion that it is limited
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`to personal computers such as laptops and notebooks. Liebenow explicitly teaches
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`exemplary digital information appliances such as “electronic books, personal
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`digital assistants (PDAs) and portable information handling systems” and that “it is
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`desirable that appliance’s housing have a compact, hand-held form factor.” Ex.
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`1005 at [0002]. Therefore, Mr. Lim’s conclusion that the input controller
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`described by Liebenow would be inappropriate for the device described by
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`Pallakoff is unsupported by Liebenow.
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`20. Second, Mr. Lim’s assumption that an Intel/AMD x86 based processor
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`would not work in anything other than a PC is also unfounded. For example,
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`SCEA Ex. 1042 Page 19
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`AMD offered a family of embedded x86 processors for use with low-power
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`devices in the 1990s. Ex. 1051, AMD Élan™SC400 and ÉlanSC410 at p. 1.
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`21. Finally, there were processor families that supported I/O controllers for
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`small, handheld devices, such as that described by Pallakoff, for many years prior
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`to the ‘313 Patent. One example is the ARM610 processor that was developed in
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`1993 specifically for portable devices such as PDAs and communication devices.
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`Ex. 1052, ARM610 Datasheet at p. ii (“The ARM610 is ideally suited to those
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`applications requiring RISC performance from a compact, power efficient
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`processor. These include: Personal computer devices e.g. PDAs . . . Portable
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`telecommunications . . . Data communications equipment”). The ARM610
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`processors were “compatible with the ARM processor family and can be used
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`with ARM support chips, eg IO, memory and video.” Id. at p. 3 (emphasis added).
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`ARM has made such “IO” (input/output) support chips at least since 1986 (Ex.
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`1053, IOC Datasheet), and by at least 1992 AMD offered complete “computer
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`system on a chip” chips such as the ARM250 (Ex. 1054, ARM250 Datasheet) that
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`included an input/output controller (IOC). Among other features, the ARM250
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`offered a “Flexible I/O Controller,” a “Small footprint 160 PQFP package,” and
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`“Low power consumption,” and was “suitable for a wide range of cost-sensitive
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`embedded control, portable and consumer games applications – particularly (but
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`not only) those which require a video display.” Id. at p. 1. As I opined in my
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`SCEA Ex. 1042 Page 20
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`original declaration, U.S. Patent No. 5,878,276 to Aebli et al. (Ex. 1020) provides
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`a further example of handheld devices using input controllers as an interface
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`between input elements and the microprocessor. Ex. 1009 at ¶ 34. Therefore, a
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`person of ordinary skill would not have found Liebenow’s disclosure of an input
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`controller to be in any way incompatible with the handheld device described by
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`Pallakoff.
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`II. CONCLUSION
`22.
`I declare that all statements made herein of my knowledge are true, and
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`that all statements made on information and belief are believed to be true, and that
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`these statements were made with the knowledge that willful false statements and
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`the like so made are punishable by fine or imprisonment, or both, under Section
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`1001 of Title 18 of the United States Code.
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`Date:
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`08 DEC 2015
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`____________________________
`By:
`Gregory F. Welch
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`SCEA Ex. 1042 Page 21