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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`In re Inter Partes Review of:
`U.S. Patent No. 7,498,749
`Issued: Mar. 3, 2009
`Application No.: 11/928,964
`Filing Date: Oct. 30, 2007
`
`For: Intelligent Electrical Switching Device Including A Touch Sensor User
`Interface Switch
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`FILED VIA PRPS
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`REPLY DECLARATION OF PAUL BEARD IN SUPPORT
`OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,498,749
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`Ex. 1031-0001
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`Inter Partes Review of USP 7,498,749
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`I, Paul Beard, resident of Bigfork, Montana, hereby declare as follows:
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`1.
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`I previously provided a declaration in support of Apple Inc.’s
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`(“Apple”) petition in IPR2015-01172 challenging the validity of U.S. Patent No.
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`7,498,749 (the “’749 Patent”). (Ex. 1003, “Beard Decl.”).
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`I.
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`THE BEARD REFERENCE’S INFRARED TRANSCEIVER AND
`INTERFACE CIRCUITRY
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`2.
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`Figure 11 of U.S. Patent No. 5,898,290 (Ex. 1005 (“Beard”)) depicts
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`an “infrared transceiver,” labeled 235, and associated “interface circuitry,” labeled
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`233, in the battery pack 201. This infrared transceiver can be used to receive the
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`“peak, minimum and typical loading characteristics” of the portable electronic
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`device 203 when the battery pack is inserted into the device. (Beard at 11:52-57.)
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`It can also be used to transmit “battery capacity information” from the battery pack
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`to the device. (Id. at 10:26-30.)
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`3.
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`Like all active electronic components, infrared transceiver 235
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`consumes energy when it is used. Interface circuitry 233 also consumes energy
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`when it is used.
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`4.
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`As depicted in Figure 11, infrared transceiver 235 receives power
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`from the batteries 231. Interface circuitry 233 also receives power from the
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`batteries 231.
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`5.
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`Also as depicted in Figure 11, infrared transceiver 235 and interface
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`circuitry 233 receive power from the batteries 231 under control of the control
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`Ex. 1031-0002
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`Inter Partes Review of USP 7,498,749
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`circuitry 223. The control circuitry 223 is located between the batteries 231 and
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`the interface circuitry and transceiver.
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`6.
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`A person of ordinary skill in the art reviewing Figure 11 and the
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`associated text in columns 11 and 12 would understand that, while not a claimed
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`feature in the Beard patent, the arrangement of the control circuitry, batteries,
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`infrared transceiver and interface circuitry indicates that the control circuitry
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`controls power from the batteries to the transceiver and interface.
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`7.
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`In addition, it would have been obvious to implement control circuitry
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`223 to control power from the batteries 231 to the interface circuity 233 and the
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`infrared transceiver 235. In Figure 11 of Beard, the control circuitry is located
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`between the batteries and both the interface circuitry and infrared transceiver.
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`Based on this configuration, it would have been obvious that the control circuitry
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`could be used to control power from the batteries to the transceiver. For example,
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`it would have been obvious to use the control circuit to control power to the
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`infrared transceiver in order to control data transmission.
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`II. THE BEARD REFERENCE’S TIMING CIRCUIT
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`8.
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`Beard discloses in column 10 a “timing circuit” that is used to
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`automatically deactivate a display after ten seconds, when the display is activated
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`by a user pressing the touch sensor. (Beard at 10:51-54.) The “timing circuit”
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`“prevents the contact 155 from holding the display 157 and associated circuitry in
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`Ex. 1031-0003
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`Inter Partes Review of USP 7,498,749
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`an active state from more than a ten (10) second interval.” (Id.) “After the ten
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`second display period, deactivation occurs whether or not the contact 155 is being
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`touched.” (Id. at 10:54-56.)
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`9.
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`This “timing circuit” is activated when the user presses the “touch
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`contact 155.” (Beard at 10:48-50.) The touch contact sends an activation signal,
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`via the control circuitry, which activates the display and the timing circuit.
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`10. This timing circuit is automatically deactivated after ten seconds. The
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`timing circuit “prevents the contact 155 from holding the display 157 and
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`associated circuitry in an active state from more than a ten (10) second interval.”
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`At the conclusion of this ten second interval, both the display and the timing circuit
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`are automatically deactivated. The timing circuit is deactivated, among other
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`reasons, to preserve battery power.
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`Executed on June 4, 2016 in Bigfork, Montana.
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`Paul Beard
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`Ex. 1031-0004
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