Samsung Electronics Co., Ltd. et al., Petitioner
`
`v.
`
`Image Processing Technologies, LLC, Patent Owner
`
`IPR2017-00336
`Patent No. 6,959,293
`
`Patent Owner’s Demonstratives
`February 21, 2018 Oral Argument
`
`
`
`v.
`
`Image Processing Technologies, LLC, Patent Owner
`
`IPR2017-00336
`Patent No. 6,959,293
`
`Patent Owner’s Demonstratives
`February 21, 2018 Oral Argument
`
`
`
`Sole Ground for Institution – Pirim
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`
`2
`Paper 15 at 53
`
`
`
`The Examiner Considered Pirim, the Sole Asserted Reference
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`
`3
`Ex. 1004 at 243–245; Paper 21 at 4
`
`
`
`’293 Patent Claim Element 22[b]
`[22b] an input multiplexer adapted to receive data
`describing one or more parameters of the event being
`detected, and to output data describing a selected one of
`the one or more parameters in response to a selection
`signal; and
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`
`4
`Ex. 1001 at 29:61–30:18; Paper 21 at 18–19
`
`
`
`’293 Patent Claim Element 22[b] Requires
`Selecting from Among Multiple Parameters
`
`[22b] an input multiplexer adapted to receive data
`describing one or more parameters of the event being
`detected, and to output data describing a selected
`one of the one or more parameters in response to a
`selection signal;
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`5
`Ex. 1001 at 29:61–30:18; Paper 21 at 14–15, 18–19; Ex. 2009 at ¶ 26
`
`
`
`’293 Patent Polyvalent Histogram Calculation Unit Embodiment:
`Figure 31a Shows Multiple Parameter Signals Input to the Multiplexer
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`6
`Ex. 1001 at Fig. 31a, 20:63–66 (annotation in brackets); Ex. 2009 at ¶¶ 27–29; Paper 21 at 10,15–16
`
`
`
`Prior Art Pirim Does Not Teach or Suggest Element [22b]:
`Neither Multiplexer Can Select from More Than a Single Data Parameter
`
`Data
`
`Zero
`
`Data(v)
`
`Counter
`
`Only one parameter
`passes through
`multiplexers.
`
`Multiplexers 102 and 104 (yellow); input signals (blue); control signal
`(green).
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`7
`Ex. 1005 at Fig. 14; Paper 21 at 11–12, 24; Ex. 2009 at ¶¶ 39–42
`
`
`
`A POSA Would Have Understood a “Multiplexer” Means
`Multiple Input Signals, Single Output
`
`IEEE Dictionary (2000): Multiplexer
`
`(A) A device that allows the interleaving of two or more signals to
`a single line or terminal.
`(B) A device for selecting one of a number of inputs and switching
`its information to the output.
`
`The claim language requires that the multiplexer be able to
`accommodate multiple parameters.
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`
`8
`Ex. 2011; Paper 21 at 18–19
`
`
`
`Different Claims Cover Different Multiplexer Versions:
`Claim 4 describes a multiplexer with one parameter input
`
`A visual perception processor according to claim
`3, wherein the memory of the classifier is an
`addressable memory enabling real time updating
`of the selection criterion C and having a data
`input register, an address command register and
`a writing command register, receiving on its input
`register the output from the analysis memory and
`a signal End on its writing command register, the
`processor further comprising a data input
`multiplexer with two inputs and one output,
`receiving on one of its inputs a counting signal
`and on its other input the succession of data
`aijT to the address command of the memory of the
`classifier and an operator OR controlling the
`address multiplexer and receiving on its inputs an
`initialization signal and the end signal END.
`
`Alternative configuration not
`claimed in claim 22.
`
`Two inputs:
`•
`counting signal
`•
`Parameter: succession of
`data aijT
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`
`9
`Ex. 1001 at 27:60–28:6; Paper 21 at 17–18
`
`
`
`Different Claims Cover Different Multiplexer Versions:
`Claim 13 Multiplexer Receives a Single Parameter
`
`3. . . . multiple parameters (DATA (A) . . .
`(E)) . . .
`
`13. A visual perception processor according
`to claim 12, further comprising register input
`multiplexers, each being associated with
`the input of a register, and combinatory
`modules connecting the registers to one
`another, wherein the register input
`multiplexers are configured to choose
`between a sequential writing mode and a
`writing mode common to all the registers
`connected together by the combinatory
`modules.
`
`Alternative configuration not
`claimed in claim 22.
`
`Multiple input multiplexers,
`each being associated with
`the input of a register
`
`Each multiplexer receives
`data for a single parameter.
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`
`10
`Ex.1001 at 28:47–54; Paper 21 at 17–18
`
`
`
`’293 Patent Polyvalent Histogram Calculation Unit Embodiment:
`Each Unit Has Access to All Parameter Data, Unlike Pirim
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`
`11
`Ex. 1001 at Fig. 32; Paper 21 at 8
`
`
`
`The Examiner Also Considered WO98/05002
`Petitioner relies on Fig. 12 of Pirim, nearly identical disclosure in WO98/05002
`
`WO98/05002, Fig. 11
`
`Pirim, Fig. 12
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`12
`Ex. 1004 at 243; Paper 21 at 4–5 (Ex. 1005 Fig. 11 “is nearly identical to Figure 11 [sic, 12]” of Ex. 2010
`
`
`
`’293 Patent Claim 22
`
`[22pre] A device for detecting one or more events including aural and/or visual
`phenomena, the device comprising:
`[22a] a controller coupled to a controller bus and a transfer bus;
`[22b] an input multiplexer adapted to receive data describing one or more parameters of
`the event being detected, and to output data describing a selected one of the one or
`more parameters in response to a selection signal; and
`[22c] a data processing block coupled to the multiplexer, the transfer bus and the
`controller bus, the data processing block including:
`[22d] a histogram unit coupled to the input portal and configured to calculate a histogram
`for the selected parameter;
`[22e] a classification unit coupled to the input portal and the histogram unit, and
`configured to determine the data in the histogram that satisfy a selected criterion, and to
`generate an output accordingly, the classification unit supplying the output to the transfer
`bus; and
`[22f] a coincidence unit coupled to receive the output of the classification unit from the
`transfer bus and to receive selected coincidence criteria from the controller bus, the
`coincidence unit being configured to generate an enable signal for the histogram unit
`when the output of the classification unit satisfies the selected coincidence criterion.
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`
`13
`Ex.1001 at 29:61–30:18; Paper 21 at 18
`
`
`
`’293 Patent Passive Histogram Unit:
`Lacks the Ability to Process Multiple Parameters
`
`Analysis memory (100, red), classification unit (101, blue), time coincidences unit (102, purple);
`bus (111, yellow).
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`
`14
`Ex. 1001 at Fig. 3; Paper 21 at 7; Ex. 2009 at ¶ 29
`
`
`
`’293 Patent Claim 22
`
`[22pre] A device for detecting one or more events including aural and/or visual
`phenomena, the device comprising:
`[22a] a controller coupled to a controller bus and a transfer bus;
`[22b] an input multiplexer adapted to receive data describing one or more parameters of
`the event being detected, and to output data describing a selected one of the one or
`more parameters in response to a selection signal; and
`[22c] a data processing block coupled to the multiplexer, the transfer bus and the
`controller bus, the data processing block including:
`[22d] a histogram unit coupled to the input portal and configured to calculate a histogram
`for the selected parameter;
`[22e] a classification unit coupled to the input portal and the histogram unit, and
`configured to determine the data in the histogram that satisfy a selected criterion, and to
`generate an output accordingly, the classification unit supplying the output to the transfer
`bus; and
`[22f] a coincidence unit coupled to receive the output of the classification unit from the
`transfer bus and to receive selected coincidence criteria from the controller bus, the
`coincidence unit being configured to generate an enable signal for the histogram unit
`when the output of the classification unit satisfies the selected coincidence criterion.
`
`IPR2017-00336, Ex. 2013, Patent Owner Demonstrative Slides
`
`15
`Ex. 1001 at 29:61–30:18; Paper 21 at 18
`
`
`
`
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