UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`MICROSOFT CORPORATION and MICROSOFT MOBILE, INC.
`Petitioners
`
`v.
`
`GLOBAL TOUCH SOLUTIONS, LLC
`Patent Owner
`________________
`
`Case IPR2015-01151
`Patent No. 8,288,952
`________________
`
`
`
`PATENT OWNER’S
`
`DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`
`
`________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`MICROSOFT CORPORATION and MICROSOFT MOBILE, INC.
`Petitioners
`
`v.
`
`GLOBAL TOUCH SOLUTIONS, LLC
`Patent Owner
`________________
`
`Case IPR2015-01151
`Patent No. 8,288,952
`________________
`
`
`
`PATENT OWNER’S
`
`DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`
`
`Patent Owner
`Global Touch Solutions, LLC
`Demonstratives
`
`IPR 2015-01151
`US Patent No. 8,288,952
`
`August 4, 2016
`
`1
`
`
`
`Instituted Ground
`
`(cid:1) Ground 1: Claims 1-4, 14, 16, 17, 19, 22-24, 26, 27,
`and 38-40 obvious under 35 U.S.C. § 103(a) over U.S.
`Patent No. 6,125,286 ("Jahagirdar") (Ex. 1004) in view
`of U.S. Patent No. 4,053,789 ("Schultz") (Ex. 1005).
`
`2
`
`
`
`'952 Patent: Overview
`
`Ex. 1001 at FIG. 1
`
`Ex. 1001 at 7:12-31 (cited in Paper 14 at 3-4)
`
`Ex. 1001 at FIG. 2
`
`3
`
`
`
`'952 Patent: Overview
`
`Ex. 1001 at 9:46-57 (cited in Paper 14 at 5)
`
`Ex. 1001 at FIG. 11 (cited in Paper 14 at 5)
`
`4
`
`
`
`'952 Patent: Claim 1
`
`‘S352 Patent: Claim 1
`
`l . A ntethod for intpletnenting, at user interface ofe p1'CIIIi11CiI_.
`the product eotnprising st power source, or e eonneetion for s
`power source and at least one energy CCIflSl_1II1i11g load, said
`method inelnding the step of using an eleetronje ntodnle
`eontprising an electronic eirenit inelndin_
`
`_ wherein the visible ittdieetiott provides
`ittforntstion to at user on at least one item from the following
`
`group:
`at state or eondition of the prodnet,
`loeetion of the user interfeee,
`e better}; power level inazliestion
`
`5
`
`
`
`'952 Patent: Claim 26
`
`6
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`Ex. 1004 (Jahagirdar) at FIGs. 1 and 2, annotated at Paper 2 (Petition) at 25
`(cited in Paper 14 at 15)
`
`(cid:1) Issue: Would it have been obvious to replace push-button
`keys 144 with touch sensor disclosed in Schultz?
`
`7
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`(cid:1) Issue: Would it have been obvious to replace push-button
`keys 144 with touch sensor disclosed in Schultz?
`
`Legal Standards
`
`Merely teaching or suggesting each claim
`element is not sufficient to establish
`obviousness, as "there must be some
`articulated reasoning with a rational
`underpinning to support the legal conclusion of
`obviousness"
`
`“[C]ombinations that [1] change the ‘basic
`principles under which the [prior art] was
`designed to operate,’ . . . or that [2] render the
`prior art ‘inoperable for its intended purpose,’ . .
`. may fail to support a conclusion of
`obviousness.”
`
`KSR Int’l Co. v. Teleflex Inc., 550
`U.S. 398, 418 (2007)
`
`Plas-Pak Industries, Inc. v. Sulzer
`Mixpac AG, 600 Fed. Appx. 755,
`757 (Fed. Cir. 2015)
`
`Paper 14 at 9 and 19
`
`8
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`(cid:1) Issue: Would it have been obvious to replace push-button
`keys 144 with touch sensor disclosed in Schultz?
`
`(cid:1) Petitioner:
`
`Paper 2 (Petition) at 30 (cited in Paper 14 at 13)
`
`9
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`(cid:1) Issue: Would it have been obvious to replace push-button
`keys 144 with touch sensor disclosed in Schultz?
`
`(cid:1) Petitioner:
`
`Paper 2 (Petition) at 33
`
`10
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`(1)
`
`"The touch sensor of Schultz would not (1) minimize
`accidental actuation"
`
`Paper 14 at 13
`
`Ex. 1014 (Horenstein Dec) at 64
`(cited in Paper 14 at 14)
`
`Ex. 1005 (Schulz) at 1:20-22 (cited
`in Paper 14 at 14)
`
`11
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`(1)
`
`"The touch sensor of Schultz would not (1) minimize
`accidental actuation"
`
`Paper 14 at 13
`
`Ex. 2002 (Morley Dec) at 56
`
`Ex. 1004 (Jahagirdar) at FIGs. 1 and 2
`
`12
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`(2)
`
`The touch sensor of Schultz would not (2) eliminate
`the problems of contamination/mechanical failure
`
`Paper 14 at 16
`
`Ex. 2002 (Morley Dec) at 63
`
`Ex. 1001 ('952 Patent) at 8:13-24
`(cited in Paper 14 at 17)
`
`13
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`(3)
`
`"The touch sensor of Schultz would not (3) enhance
`convenience and aesthetics for the user"
`
`Paper 14 at 17
`
`Ex. 1006 (Norimatsu) at FIG. 4, annotated in Paper 2 at 32
`
`Ex. 1004 (Jahagirdar) at FIGs. 1 and 2
`
`14
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`(3)
`
`"The touch sensor of Schultz would not (3) enhance
`convenience and aesthetics for the user" Paper 14 at 17
`
`Ex. 1017 (Morley Depo) at 181:20-182:10
`
`15
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`(3)
`
`"The touch sensor of Schultz would not (3) enhance
`convenience and aesthetics for the user"
`
`Paper 14 at 18
`
`Ex. 1009 (Roudeski) at 1:16-20 (cited in Paper 2 at 33)
`
`Ex. 1004 (Jahagirdar) at FIGs. 1 and 2
`
`16
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`(4)
`
`Not combination of prior art elements according to
`known methods to yield predictable results
`
`Ex. 1017 (Morley Depo) at 176:5-16 and 177:2-4
`(cited in Paper 16 (Petitioners' Reply) at 6)
`
`17
`
`
`
`Jahagirdar in View of Schulz: Claims 1 and 26
`"Touch Sensor Forming Part Of The User Interface"
`
`(4)
`
`Not combination of prior art elements according to
`known methods to yield predictable results
`
`Ex. 1017 (Morley Depo) at 177:5-13, 177:17-
`178:1, 178:3-5, and 178:8-16 (cited in part in
`Paper 16 (Petitioners' Reply) at 6)
`
`18
`
`
`
`Jahagirdar in View of Schulz: Claim 23
`"Automatically Deactivating the Visible Indication…"
`
`Ex. 1014 (Horenstein Dec) at 73
`
`Ex. 2002 (Morley Dec) at 56
`
`Ex. 1004 (Jahagirdar) at FIG. 8A, annotated in Paper 2
`(Petition) at 38
`
`19
`
`
`
`END
`
`20
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a copy of the attached Patent Owner's
`
`Demonstrative Exhibits and this Certificate of Service are being served on August
`
`1, 2016 by electronic mail upon the following:
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`/Fadi N. Kiblawi/
`Fadi N. Kiblawi
`Registration No. 61,973
`
`
`Daniel J. Goettle
`John F. Murphy
`Sarah C. Dukmen
`dgoettle@bakerlaw.com
`johnmurphy@bakerlaw.com
`msft-gt@bakerlaw.com
`
`
`
`Date: August 1, 2016
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