Petitioner Microsoft Corporation’s Demonstratives
`
`Microsoft Corporation
`v.
`Bradium Technologies, LLC
`
`Case IPR2015-01432
`Patent No. 7,139,794 B2
`
`Oral Argument
`September 19, 2016
`
`Microsoft Corp. Exhibit 1017
`Microsoft Corp. v. Bradium Tech., IPR2015-01432
`Petitioner Demonstrative 1
`
`
`
`Microsoft Corporation
`v.
`Bradium Technologies, LLC
`
`Case IPR2015-01432
`Patent No. 7,139,794 B2
`
`Oral Argument
`September 19, 2016
`
`Microsoft Corp. Exhibit 1017
`Microsoft Corp. v. Bradium Tech., IPR2015-01432
`Petitioner Demonstrative 1
`
`
`
`PTAB Instituted Grounds
`(Institution Decision, Paper 15, at 32)
`
`Claim Challenged
`
`Basis
`
`References
`
`1
`
`2
`
`§ 103
`
`Rutledge, Ligtenberg, and Cooper
`
`§ 103
`
`Rutledge, Ligtenberg, Cooper, and
`Migdal
`
`Petitioner Demonstrative 2
`
`
`
`The ‘794 Patent
`
`• “System and Methods for
`Network Image Delivery With
`Dynamic Viewing Frustum
`Optimized for Limited Bandwidth
`Communication Channels”
`• Filed December 24, 2001
`• Earliest claimed priority date:
`December 27, 2000 (six
`provisional applications)
`
`Petitioner Demonstrative 3
`
`
`
`The ‘794 Patent
`
`
`
`••
`
`•
`•
`
`•
`
`“The Internet and other network systems provide a unique
`opportunity to transmit complex images, typically large scale
`bit-maps, particularly those approaching photo-realistic
`levels, over large distances. In common application, the
`images are geographic, topographic, and other highly
`detailed maps.” (Ex. 1001, 1:32-37) (Paper 2 at 6, Paper 27 at
`2, Ex. 1008, ¶ 29, Ex. 1015, ¶ 12)
`“Different conventional systems have been proposed to
`reduce the latency affect by transmitting the image in highly
`compressed formats that support progressive resolution
`build-up of the image within the current client field of view.”
`(Ex.1001, 1:48-58) (Paper 2 at 6 , Ex. 1008, ¶ 49)
`“[s]mall clients are generally constrained to generally to very
`limited network bandwidths, particularly when operating
`under wireless conditions.” (Ex. 1001, 3:4-39) (Paper 2 at 6,
`Paper 27 at 8, Ex. 1008, ¶ 79)
`
`Petitioner Demonstrative 4
`
`
`
`The ‘794 Patent
`
`•
`
`•
`•
`
`•
`•
`
`“In accordance with the preferred embodiments of the
`present invention, as generally illustrated in FIG. 2, a
`
`network image server system 30 stores a combination of
`source image data 32 and source overlay data 34. The
`source image data 32 is typically high-resolution bit-map
`satellite imagery of geographic regions, which can be
`obtained from commercial suppliers.” (Ex. 1001, 5: 54-
`67) (Paper 2 at 7, Paper 27 at 2, Ex. 1008, ¶ 81)
`“The source overlay data 34 is preferably pre-processed
`36 into either an open XML format, such as the
`Geography Markup Language (GML), which is an XML
`based encoding standard for geographic information
`developed by the OpenGIS Consortium (OGC;
`www.opengis.org), or a proprietary binary
`representation.” (Ex.1001, 6:27-41) (Paper 27 at 2)
`“While the present invention has been described
`particularly with reference to the communications and
`display of geographic image data, the present invention
`is equally applicable to the efficient communications and
`display of other high resolution information.” (Ex. 1001,
`11:13-20) (Paper 27 at 2)
`
`Petitioner Demonstrative 5
`
`
`
`Dispute on Motivation to Combine
`• Patent Owner’s view:
`– “2D Image-Based Methods Such as Rutledge and
`Ligtenberg Are Fundamentally Different from 3D
`Polygon-Based Methods Such as Described by
`Cooper” (Patent Owner’s Response, Paper 24 at 4)
`• Petitioner’s view:
`– “Combining 3D visualization techniques with 2D
`geographic imagery was well-known in the art of GIS”
`• Paper 2 (Petition) at 41-45, Ex. 1008 (Michalson 2015
`Declaration), ¶¶ 40-44, 64-75, 98-100, 106, 173, 196, 245, 281,
`286, 310-11, 320-24; Paper 27 (Reply) at 1-5; Ex. 2015
`(Michalson Reply declaration), ¶¶ 41-69, 118-129
`
`Petitioner Demonstrative 6
`
`
`
`The ‘794 Patent
`
`Fuller & Richer, “The MAGIC Project: From Vision to Reality” (IEEE May/June 1996) (Ex. 1008 App.
`E) (Paper 2 at 9-10; Ex. 1008, ¶ ¶ 44, 74-75; Paper 27 at 4-5, Ex. 1015, ¶ ¶ 82, 112)
`•
`“Terravision allows a user to view and navigate through (i.e. “fly over”) a representation of a
`landscape created from aerial or satellite imagery.” (Ex. 1008 App. E at 17)
`“To facilitate processing, distributed storage, and high-speed retrieval over a network, the
`DEM and images are divided into small fixed-size units known as tiles. Low-resolution tiles
`are required for terrain that is distant from the viewpoint, whereas high-resolution tiles are
`required for close-in terrain.” (Id. )
`
`•
`
`Fig. 5
`
`Fig. 5
`
`Fig. 4
`
`Petitioner Demonstrative 7
`
`
`
`Prior Art Rutledge and Ligtenberg
`
`A method of processing an input
`image for storage includes
`decomposing the input image into
`a number of images at various
`resolutions, subdividing at least
`some of these images into tiles
`(rectangular arrays) and storing a
`block (referred to as the “tile
`block”) representing each of the
`tiles, along with an index that
`specifies the respective locations
`of the tile blocks.
`- Ligtenberg (Ex. 1004), Abstract
`
`Paper 2 at 41-42, 45, 53; Ex. 1008,
`¶ ¶ 175, 178, 193, 204, 232, 239,
`259
`
`Petitioner Demonstrative 8
`
`Rutledge (Ex. 1005), Fig. 3
`
`“Many geographic information systems
`may be configured to handle both
`vector and raster data from a wide
`variety of sources including satellite
`imagery, hand digitized maps, and
`scanned images.”
`- Rutledge (Ex. 1005), col. 4, lines 43-47
`
`
`
`Prior Art Cooper
`• “Interactive computer graphics systems produce realistic-
`looking, three-dimensional models and are useful for
`applications such as architectural and mechanical CAD,
`flight simulation, and virtual reality”
`– Cooper (Ex. 1006), Col. 1, lines 12-15 (Paper 2 at 54, Paper 27
`at 12, Ex. 1008, ¶ 391, Ex. 1015, ¶ ¶ 121, 131, 133)
`
`Cooper Fig. 3A
`
`Paper 27 at 6;
`Ex. 1015, ¶ 119
`
`Petitioner Demonstrative 9
`
`
`
`Prior Art Migdal
`
`US Pat. No. 5,760,783 to Migdal (Ex. 1007)
`• “There is also a need to maintain real-time display
`speeds even when navigating through displays drawn
`from large texture maps. For example, flight
`simulations must still be performed in real-time even
`when complex and voluminous source data such as
`satellite images of the earth or moon, are used to form
`large texture motifs.”
`– Migdal (Ex. 1007), Col. 2, line 65- col. 3, line 3 (Paper
`27 at 3, Ex. 1008, ¶ ¶ 72, 243-244, Ex. 1015, ¶ ¶ 46,
`110)
`
`
`
`Petitioner Demonstrative 10
`
`
`
`Prior Art Migdal
`US Pat. No. 5,760,783 to Migdal (Ex. 1007)
`• “A large amount of texture source data, such as
`photographic terrain texture, is stored as a two-
`dimensional or three-dimensional texture MIP-
`map on one or more mass storage devices… These
`selected texture MIP-map portions forming the
`clip-map consist of tiles which contain those texel
`values at each respective level of detail that are
`most likely to be mapped to pixels being rendered
`for display based on the viewer’s eyepoint and
`field of view.”
`– Migdal (Ex. 1007) at Abstract (Paper 2 at 53, Ex.
`1008, ¶ 272)
`
`Petitioner Demonstrative 11
`
`
`
`Prior Art Migdal: FIG. 1B (Annotated)
`
`Ex. 1015 at ¶ ¶ 131-132 (Pages 62-63); Paper 27 at Page 12
`Petitioner Demonstrative 12
`
`
`
`Summary of Petitioner’s Evidence
`
`Petitioner Demonstrative 13
`
`
`
`Claim 1
`POSITA’s Motivations to Combine Rutledge, Ligtenberg and Cooper
`
`Petitioner’s Detailed Explanations and Evidence
`• Microsoft’s Petition, Paper 2
`– Motivations guided by specific prior art teachings regarding Claim 1
`•
`Pages 41-45
`– Additional motivations at the claim element level in Claim 1
`•
`Pages 46, 47, 48, 49, 50, 51, 52 and 53
`• Michalson 2015 Decl., Ex. 1008
`– Motivations guided by specific prior art teachings regarding Claim 1
`• ¶¶ 178, 181-183, 190, and 192
`• ¶¶ 193-200
`– Additional motivations at the claim element level in Claim 1
`• ¶¶ 205-206, 209, 211-213, 215, 217-218, 220, 222-223, 225, 227, 230, 233-234, 236-237, 239-240
`• Microsoft’s Petitioner Reply, Paper 27
`– Motivations guided by specific prior art teachings regarding Claim 1
`•
`Pages 2-5, 5-14, 14-15
`– Additional motivations at the claim element level in Claim 1
`•
`Pages 19-22
`• Michalson 2016 Reply Declaration, Ex. 1015
`– Motivations guided by specific prior art teachings regarding Claim 1
`• ¶¶ 35-69, 72-83, 86-90, 93-95, 99, 101-103, 111-164
`– Additional motivations at the claim element level in Claim 1
`• ¶¶ 171-175
`
`Petitioner Demonstrative 14
`
`
`
`Claim 2
`POSITA’s Motivations to Combine Rutledge, Ligtenberg, Cooper and Migdal
`
`Petitioner’s Detailed Explanations and Evidence
`• Microsoft’s Petition, Paper 2
`– Motivations guided by specific prior art teachings regarding Claim 2
`•
`Pages 53-54 and 41-45
`– Additional motivations at the claim element level in Claim 2
`•
`Pages 54, 55, 56, 57, 58, 59, and 60
`• Michalson Decl. in 2015, Ex. 1008
`– Motivations guided by specific prior art teachings regarding Claim 2
`• ¶¶ 177-178, 181-183, 190, and 192
`• ¶¶ 193-200, 242-246
`– Additional motivations at the claim element level in Claim 2
`• ¶¶ 247 (and 205-206), 252, 254-257, 259-260, 263, 264, 265, 266, 268, 270 (and 218), 272-273, and 275-276
`• Microsoft’s Petitioner Reply, Paper 27
`– Motivations guided by specific prior art teachings regarding Claim 2
`•
`Pages 2-19
`– Additional motivations at the claim element level in Claim 2
`•
`Pages 22-26
`• Michalson Rebuttal Declaration in 2016, Ex. 1015
`– Motivations guided by specific prior art teachings regarding Claim 2
`• ¶¶ 35-69, 72-83, 86-90, 93-95, 99, 101-103, 106-164
`– Additional motivations at the claim element level in Claim 2
`• ¶¶ 171-178, 180-186
`
`
`Petitioner Demonstrative 15
`
`
`
`Prior Art Evidence on Claim 1
`
`Claim Elements in Claim 1
`
`Petition
`(Paper 2)
`
`Michalson Decl.
`(Ex. 1008)
`
`Pet. Reply
`(Paper 27)
`
`Michalson
`Rebuttal Decl.
`(Ex. 1015)
`
`**
`
`¶171; see also ¶¶
`118-139 and 172-
`178
`**
`
`**
`
`**
`
`**
`
`PP. 20-22
`
`¶¶ 172-178
`
`Petitioner Demonstrative 16
`
`[1. Preamble] A client system for dynamic visualization of
`image data provided through a network communications
`channel, said client system comprising:
`[1A] a parcel request subsystem, including a parcel request
`queue, operative to request discrete image data parcels in a
`priority order
`[1B] to store received image data parcels in a parcel data store P. 47; see also
`41-45
`P. 47-48; see also
`41-45
`
`P. 45-46; see also
`41-45
`
`P. 46-47; see also
`41-45
`
`[1C] said parcel request subsystem being responsive to an
`image parcel request of assigned priority to place said image
`parcel request in said parcel request queue ordered in
`correspondence with said assigned priority
`[1D] an[sic] parcel rendering subsystem coupled to said parcel
`data store to selectively retrieve and render received image
`data parcels to a display memory
`[1E] said parcel rendering system providing said parcel request
`subsystem with said image parcel request of said assigned
`priority
`[1F] wherein said parcel rendering subsystem determines
`said assigned priority based on a determined optimal image
`resolution level
`
`P. 48-49; see also
`41-45
`
`P. 49-50; see also
`41-45
`
`P. 50; see also
`41-45
`
`
`Red and Bold = disputed claim elements
`** = not disputed in Patent Owner Response (Paper 24)
`
`¶¶ 202-206; see also
`¶¶ 172-201
`
`**
`
`¶¶ 208-209; see also
`¶¶ 172-201
`
`PP. 19-20
`
`**
`
`**
`
`**
`
`**
`
`¶¶ 211-213; see also
`¶¶ 172-201
`¶ 215; see also ¶¶
`172-201
`
`
`¶¶ 217-218; see also
`¶¶ 172-201
`
`¶ 220; see also ¶¶
`172-201
`
`¶¶ 222-223; see also
`¶¶ 172-201
`
`
`
`Prior Art Evidence on Claim 1 (Continued)
`
`Claim Elements in Claim 1
`
`Petition
`(Paper 2)
`
`Michalson Decl.
`(Ex. 1008)
`
`Pet. Reply
`(Paper 27)
`
`Michalson
`Rebuttal Decl.
`(Ex. 1015)
`
`[1G] wherein said display memory is coupled to an
`image display of predetermined resolution
`[1H] wherein said determined optimal image
`resolution level is based on said predetermined
`resolution
`[1I] wherein said assigned priority further reflects the
`proximity of the image parcel referenced by said
`image parcel request to a predetermined focal point
`[1J] wherein said discrete image data parcels are of a
`first fixed size as received by said parcel request
`subsystem
`[1K] of a second fixed size as rendered by said parcel
`rendering subsystem
`[1L] wherein said discrete image data parcels each
`includes a fixed-size array of pixel data
`
`P. 50-51; see
`also 41-45
`P. 51; see also
`41-45
`
`P. 51-52; see
`also 41-45
`
`¶ 225; see also
`¶¶ 172-201
`¶ 227; see also
`¶¶ 172-201
`
`¶¶ 229-230; see
`also ¶¶ 172-201
`
`
`P. 52; see also
`41-45
`
`¶¶ 232-234; see
`also ¶¶ 172-201
`
`P. 52; see also
`41-45
`P. 53; see also
`41-45
`
`¶¶ 236-237; see
`also ¶¶ 172-201
`¶¶ 239-240; see
`also ¶¶ 172-201
`
`**
`
`PP. 20-22
`
`**
`
`¶¶ 172-178
`
`**
`
`**
`
`**
`
`**
`
`**
`
`**
`
`**
`
`**
`
`Red and Bold = disputed claim elements
`** = not disputed in Patent Owner Response (Paper 24)
`
`Petitioner Demonstrative 17
`
`
`
`Prior Art Evidence on Claim 2
`
`Claim Elements in Claim 2
`
`Petition
`(Paper 2)
`
`Michalson Decl.
`(Ex. 1008)
`
`Pet. Reply
`(Paper 27)
`
`Michalson
`Rebuttal Decl.
`(Ex. 1015)
`
`[2.Preamble] A method of supporting dynamic
`visualization of image data transferred through a
`communications channel, said method comprising
`the steps of:
`[2A] determining, in response to user navigational
`commands, a viewpoint orientation with respect to
`an image displayed within a three-dimensional
`space
`[2B] requesting, in a priority order, image parcels
`renderable as corresponding regions of said image
`
`[2C] each said image parcel having an associated
`resolution
`
`[2D] wherein said priority order is determined to
`provide a progressive regional resolution
`enhancement of said image as each said image
`parcel is rendered
`[2E] receiving a plurality of image parcels through
`said communications channel
`
`Red and Bold = disputed claim elements
`** = not disputed in Patent Owner Response (Paper 24)
`
`P. 54 and 45-46;
`see also 53-54
`and 41-45
`
`P. 54-55; see
`also 53-54 and
`41-45
`
`P. 55-56; see
`also 53-54 and
`41-45
`P. 56; see also
`53-54
`
`P. 56-57; see
`also 53-54 and
`41-45
`
`P. 57 and 47; see
`also 53-54 and
`41-45
`
`¶¶ 242-247 and
`202-206; see also
`172-201
`
`¶¶ 243-246, 249-
`252; see also ¶¶
`242-245 and 172-
`201
`¶¶ 254-257; see
`also ¶¶ 242-246
`and 172-200
`¶¶ 259-260; see
`also ¶¶ 242-245
`and 172-201
`¶¶ 262-263; see
`also ¶¶ 242-246
`and 172-201
`
`¶¶ 264, 211-213;
`see also ¶¶ 242-
`246 and 172-201
`
`**
`
`**
`
`**
`
`**
`
`PP. 19-20,
`22
`
`¶¶ 179, 171
`
`**
`
`**
`
`PP. 22-25
`
`¶¶ 180-184
`
`**
`
`**
`
`Petitioner Demonstrative 18
`
`
`
`Prior Art Evidence on Claim 2 (Continued)
`
`Claim Elements in Claim 2
`
`Petition
`(Paper 2)
`
`Michalson Decl.
`Ex. 1008
`
`Pet. Reply
`(Paper 27)
`
`Michalson
`Rebuttal Decl.
`(Ex. 1015)
`**
`
`**
`
`**
`
`**
`
`**
`
`**
`
`PP. 20-22,
`25-26
`
`¶¶ 172-178,
`185-186
`
`**
`
`**
`
`**
`
`**
`
`Petitioner Demonstrative 19
`
`¶ ¶265, 217-218;
`see also ¶¶ 242-
`246 and 172-201
`¶ ¶266, 211-213;
`see also ¶¶ 242-
`246 and 172-201
`¶ ¶ 268,217-218;
`see also ¶¶ 242-
`246 and 172-201
`
`¶¶ 270,217-218;
`see also ¶¶ 242-
`246 and 172-201
`
`¶¶ 272-273; see
`also ¶¶ 242-246
`and 172-201
`
`¶¶ 275-276; see
`also ¶¶ 242-246
`and 172-201
`
`P. 57 and 48-49;
`see also 53-54
`and 41-45
`P. 57-58; see also
`53-54 and 41-45
`
`P. 58; see also 53-
`54 and 41-45
`
`
`P. 58-59; see also
`53-54 and 41-45
`
`
`
`P. 59; see also 53-
`54 and 41-45
`
`
`P. 59-60; see also
`53-54 and 41-45
`
`[2F] rendering said plurality of image parcels to
`provide said image
`
`[2G] wherein said step of receiving includes the step
`of storing said plurality of image parcels in an image
`store
`[2H] wherein said step of rendering provides for the
`selective rendering of said plurality of image parcels
`having the highest associated resolutions to the
`corresponding regions of said image
`[2I] wherein said step of rendering limits the
`selective rendering of said image parcels to image
`parcels having associated resolutions less than a
`predetermined level
`[2J] wherein said step of rendering selectively
`renders said plurality of image parcels as the[sic]
`unique textures for the corresponding regions of
`said image
`[2K] wherein said priority order is re-evaluated in
`response to a change in said viewpoint orientation
`
`Red and Bold = disputed claim elements
`** = not disputed in Patent Owner Response (Paper 24)
`
`
`
`Invalidity by
`A Preponderance of the Evidence
`
`• Claim 1 is obvious and invalid over
`Rutledge, Ligtenberg, and Cooper
`
`
`• Claim 2 is obvious and invalid over
`Rutledge, Ligtenberg, Cooper, and Migdal
`
`Petitioner Demonstrative 20
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