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`Paper No.
`Filed: December 11, 2019
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
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`v.
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`UUSI, LLC d/b/a NARTRON
`Patent Owner
`____________________
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`Case IPR2016-00908
`Patent No. 5,796,183
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`Petitioner’s Response to
`Board’s December 4th, 2019 Email Order
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`Petitioner submits this paper explaining the relevance of statements in UUSI’s
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`Patent Owner Response (Ex. 1019) filed in Apple, Inc. v. UUSI, LLC, IPR2019-
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`00358. 1 One issue here is whether a PHOSITA would have reasonably expected
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`success in modifying the Ingraham I-Caldwell combination such that the
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`microcontroller is able to provide multiple frequencies to a touch pad array by
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`selecting a frequency from multiple available frequencies. Specifically, Samsung
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`submits that a PHOSITA would have modified the microcontroller in the Ingraham
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`I-Caldwell combination based on Gerpheide’s teachings, to vary the oscillator
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`frequency so that the microcontroller selectively provides multiple frequencies (as
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`opposed to a single frequency) to the touch terminals. (See, e.g., Pet. at 26-29; Ex.
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`1002, ¶¶ 69-72.) UUSI’s statements in IPR2019-00358 confirm that a POSITA
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`would have expected success in making such a modification because UUSI admits
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`that variable frequency oscillators whose frequency could be manipulated by a
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`microcontroller were well-known and common at the time of the alleged invention
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`and would have been readily implemented using well-known techniques. (Ex. 1019
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`at 21-25, citing Ex. 1020.) Although these statements were in the context of written
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`description, they reflect the understanding of a PHOSITA and are relevant here.
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`1 Samsung reserves its rights to seek appropriate relief under Arthrex, Inc. v. Smith
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`& Nephew, Inc., No. 18-2140, 2019 WL 5616010 (Fed. Cir. Oct. 31, 2019).
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`Case No. IPR2016-00908
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`Dated: December 11, 2019
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`Respectfully submitted,
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`By: /Naveen Modi/
` Naveen Modi
` Reg. No. 46,224
` Counsel for Petitioner Samsung
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`2
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`CERTIFICATE OF SERVICE
`Pursuant to 37 C.F.R. § 42.6(e), I certify that I caused to be served on the
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`counsel for Patent Owner a true and correct copy of the foregoing Petitioner’s
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`Response to Board’s December 4th, 2019 Email Order by electronic means on the
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`date below at the following address of record:
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`sunderwood@glaserweil.com
`jweir@glaserweil.com
`lhadley@glaserweil.com
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`Dated: December 11, 2019
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`Respectfully submitted,
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`By: /Naveen Modi/
` Naveen Modi
` Reg. No. 46,224
` Counsel for Petitioner Samsung
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