throbber
Petitioner’s Demonstrative Exhibits for Oral Argument
`Patent 7,092,671
`
`DOCKET NO.: 2211726-00152US1
`Filed on behalf of Unified Patents Inc.
`By: David L. Cavanaugh, Reg. No. 36,476
`Daniel V. Williams, Reg. No. 45,221
`Ellyar Y. Barazesh, Reg. No. 74,096
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: David.Cavanaugh@wilmerhale.com
`
`
`
`
`
`
`
`
`
`Jonathan Bowser, Reg. No. 54,574
`Roshan Mansinghani, Reg. No. 62,429
`Jonathan Stroud, Reg. No. 72,518
`Unified Patents Inc.
`1875 Connecticut Ave. NW, Floor 10
`Washington, DC, 20009
`Tel: (202) 805-8931
`Email: jonathan@unifiedpatents.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Unified Patents Inc.
`Petitioner
`
`v.
`
`UNILOC LUXEMBOURG S.A. & UNILOC USA
`Patent Owner
`
`
`IPR2018-00199
`Patent 7,092,671
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS FOR ORAL ARGUMENT
`
`

`

`UNITED STATES PATENT AND TRADEMARK OFFICE
`----------------------------------------------------------------
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`----------------------------------------------------------------
`
`Inter Partes Review No. 2018-00199
`U.S. Patent 7,092,671
`
`PETITIONER’S ORAL ARGUMENT
`
`1
`
`

`

`Overview
`
`Technology Background
`Overview of ʼ671 Patent
`The Prior Art teaches the “transferring” and
`“controlling” claim limitations
`Summary of the Trial
`Issues Raised by Uniloc
`– Claim Construction
`– Teachings of the Prior Art
`– Real Parties-in-Interest (RPI)
`
`2
`
`

`

`Technology Background
`
`A computing device
`communicates with a
`telephone via wireless
`communication
`The computing device
`may store contact
`information, including
`telephone numbers
`Selection of a telephone
`number stored in the
`computing device causes
`automatic dialing of the
`number by the telephone
`
`Yun, Abstract, 2:1-55, 3:13-18, 3:37-57, 4:3-5:7, Figures 1, 2, IPR2018-00199, Ex. 1002; Petition at 11-
`13, IPR2018-00199; First Declaration of Herbert Cohen, ¶¶33-35, IPR2018-00199, Ex. 1007.
`
`3
`
`

`

`Overview of the ʼ671 Patent
`
`Personal information
`device (“PID”)
`communicates with a
`mobile telephone via a
`network
`PID may store contact
`information, such as a
`telephone number
`Selection of a telephone
`number from the PID
`causes automatic dialing
`of the number by the
`mobile telephone
`
`’671 Patent, 8:1-17, Figure 5, Ex. 1001; Petition at 6-7; First Declaration of Herbert Cohen, ¶¶21-22, Ex.
`1007; D.I., 3-5, Paper 7.
`
`4
`
`

`

`ʼ671 Patent – Independent Claim 9
`
`• Transfer a telephone
`number from a
`computer system to a
`telephone, and control
`the telephone so that
`the number is dialed
`
`’671 Patent, claim 9, Ex. 1001
`
`5
`
`

`

`Applied Prior Art: Yun
`
`Yun discloses “transferring the specific telephone
`number from the handheld computer system to the
`telephone using a wireless communication”
`An electronic pocketbook
`communicates with a telephone via
`an infrared signal
`The electronic pocketbook stores
`telephone numbers for various
`contacts
`A user selects a telephone number
`and dial key from the electronic
`pocketbook
`The electronic pocketbook transmits
`the infrared signal that includes the
`telephone number to a telephone
`Yun, Abstract, 2:1-55, 3:37-57, 4:3-20, 4:54-59,
`4:66-5:7, Figures 1, 2, Ex. 1002; Petition 20, 33;
`First Declaration of Herbert Cohen, ¶¶51, 97, Ex.
`1007.
`
`6
`
`

`

`Applied Prior Art: Harris
`
`Harris discloses “transferring the specific telephone
`number from the handheld computer system to the
`telephone using a wireless communication”
`A PDA communicates with a
`telephone via a wireless
`network
`The PDA stores contact
`information including phone
`numbers
`A user selects an icon or spot
`on the PDA, which sends
`information indicative of a
`telephone number to the
`telephone via the wireless
`network
`Harris, 1:47-53, 1:66-2:6, 3:33-35, Ex. 1005; Petition
`48-49, 63; First Declaration of Herbert Cohen, ¶¶156,
`206, Ex. 1007.
`
`7
`
`

`

`Applied Prior Art: Yun
`
`Yun discloses “controlling the telephone using the
`handheld computer system to cause the telephone to
`dial the specific telephone number”
`The electronic pocketbook
`transmits the infrared signal
`that includes the telephone
`number to a telephone
`The infrared signal also
`includes an electronic dial
`request that controls the
`telephone such that it dials
`the telephone number
`
`Yun, Abstract, 1:64-2:55, 3:37-57, 4:3-20, 4:41-
`59, 4:66-5:23, Figures 1, 2, Ex. 1002; Petition
`20-21, 33; First Declaration of Herbert Cohen,
`¶¶53, 99, Ex. 1007.
`
`8
`
`

`

`Applied Prior Art: Harris
`
`Harris discloses “controlling the telephone using the
`handheld computer system to cause the telephone to
`dial the specific telephone number”
`A user selects an icon or
`spot on the PDA, which
`sends information
`indicative of a telephone
`number to the telephone
`via the wireless network
`The sending of the
`information causes
`automatic dialing of the
`telephone number by the
`telephone
`Harris, 1:50-60, 2:43-47, 3:33-35, Ex. 1005; Petition
`49, 63; First Declaration of Herbert Cohen, ¶¶158,
`208, Ex. 1007.
`
`9
`
`

`

`Applied Prior Art: Dykes
`
`Dykes teaches “controlling the telephone using the
`handheld computer system to cause the telephone to
`dial the specific telephone number”
`Software on the computer
`issues a dial command
`The computer directs the
`cellular phone to “receive the
`numbers” of a telephone
`number specified by the dial
`command
`Afterward, the computer
`transfers a “SEND” command
`to the cellular phone which
`“instructs the cellular phone to
`dial” the number
`
`Dykes, 2:52-62, 3:41-61, 4:14-33, 5:60-64, 9:22-24, 9:30-34, 10:38-48, 10: 56-62, 11:9-13,
`11:65-12:5, 13:5-56, 13:47-14:10, 16:62-17:19, Ex. 1004; Petition 21-26, 33, 50-55, 63-64; First
`Declaration of Herbert Cohen, ¶¶54-62, 100, 159-168, 209, Ex. 1007.
`10
`
`

`

`Summary of the Trial
`
`The Board instituted trial on the following grounds:
`– Yun, Langlois, Dykes (Claims 1-6, 9-14)
`– Yun, Langlois, Dykes, Husemann (Claims 7, 8, 15, 16)
`– Harris, Langlois, Dykes (Claims 1-7, 9-15)
`– Harris, Langlois, Dykes, Husemann (Claims 8 and 16)
`D.I., 15, IPR2018-00199, Paper 7.
`Uniloc does not dispute Langlois’ teachings or its combinations
`with Yun and Harris
`
`Patent Owner’s Response, IPR2018-00199, Paper 13.
`Uniloc contests only the unpatentability of independent claims
`1 and 9, without providing any expert testimony
`– Uniloc does not substantively dispute the unpatentability of
`dependent claims 2-8 and 10-16
`Patent Owner’s Response, 28-41, Paper 13.
`
`11
`
`

`

`Summary of the Issues
`
`Uniloc’s proposed construction of the
`“controlling” and “transferring” recitations in
`claims 1 and 9
`
`Teachings of the prior art in relation to Uniloc’s
`proposed construction
`
`Unified is the sole RPI
`
`12
`
`

`

`Uniloc’s Proposed Construction is Incorrect
`
`Uniloc proposes “controlling the telephone…to dial the
`specific telephone number” should be separate and
`apart from “transferring the specific telephone
`number from the handheld computer system to the
`telephone”
`
`Patent Owner’s Response, 23, Paper 13.
`
`Uniloc’s proposed construction is unsupported
`attorney argument
`– No expert testimony or other evidentiary support that the
`Board hasn’t already considered
`Patent Owner’s Response, 23, Paper 13.
`The challenged claims are invalid even under Uniloc’s
`improper construction
`
`13
`
`

`

`Uniloc’s Proposed Construction: Not Supported by the Claims
`
`“transferring the specific telephone number from the
`handheld computer system to the telephone using a wireless
`communication;
`controlling the telephone using the handheld computer
`system to cause the telephone to dial the specific telephone
`number;” (claim 9)
`
`– No requirement that the claimed “controlling” be separate
`and apart from the “transferring” of a telephone number
`
`– As explained by Dr. Cohen, a person of ordinary skill in the
`art (“POSA”) would have understood that signals or portions
`of a signal that are not necessarily separate and apart may
`effectuate both the claimed transfer and control
`
`Petitioner’s Reply, 2-3, IPR2018-00199, Paper 21; Second Declaration of Herbert Cohen,
`IPR2018-00199, ¶¶4, 7-11.
`
`14
`
`

`

`Uniloc’s Proposed Construction: Not Supported by the Specification
`
`No description of particular, separate and apart
`processes that must occur for the claimed transfer and
`control
`
`“[t]he present invention provides a solution which
`enables a user’s PID to seamlessly interact with the
`user’s telephone to dial numbers and establish phone
`calls…”
`
`Petitioner’s Reply, 4, Paper 21; ’671 Patent, 2:45-48, 4:17-32, 8:17-21, Ex. 1001.
`
`15
`
`

`

`Uniloc’s Proposed Construction: Not Supported by File History
`
`During prosecution, Applicant stated:
`“As shown in blocks 805 and 806 of Figure 8 in the present application,
`the phone number to be dialed is transferred before the receiving
`wireless telephone is controlled or instructed to dial the telephone
`number. Accordingly, claim 19 recites the data exchange and control
`elements as separate limitations.”
`File History, ’727 application, Response (02/21/2006), 8, IPR2018-00199, Ex. 1015.
`Uniloc contends that these statements support why the claimed
`“transferring” must be separate and apart from “controlling”
`Patent Owner’s Response, 27-28, Paper 13.
`Instead, these statements show that control to dial a number
`on a telephone needs a number to dial
`– No separate and apart requirement as Uniloc contends
`
`Petitioner’s Reply, 4-5, Paper 21; File History, ’727 application, Response (02/21/2006), 8,
`Ex. 1015.
`
`16
`
`

`

`Yun
`
`An electronic pocketbook
`communicates with a
`telephone via an infrared
`signal
`The electronic pocketbook
`stores telephone numbers
`for various contacts
`A user selects a telephone
`number from the
`electronic pocketbook,
`which causes automatic
`dialing of the number by
`the telephone
`
`Yun, Abstract, 1:64-2:55, 3:37-57, 4:3-20, 4:41-59, 4:66-5:23, Figures 1, 2, Ex. 1002; Petition 20-
`21, 33; First Declaration of Herbert Cohen, ¶100 , Ex. 1007.
`
`17
`
`

`

`Yun discloses the claimed “controlling”
`
`An electronic pocketbook transmits an infrared signal
`including both an electronic dial request and a telephone
`number to a telephone system
`Yun, 3:51-57, 4:11-20; Petitioner’s Reply, 5-6, Paper 21; Second Declaration of Herbert
`Cohen, IPR2018-00199, ¶17; D.I., 11, Paper 7.
`
`The infrared signal is received by a telephone system,
`which then automatically dials the number contained in
`the infrared signal
`Yun, Abstract, 1:64-2:55, 3:37-42, 4:11-31 4:41-59, 5:5-23, Ex. 1002; Petitioner’s Reply, 5-6,
`Paper 21; Second Declaration of Herbert Cohen, ¶17.
`
`18
`
`

`

`Yun discloses the claimed “controlling”
`
`It is Yun’s electronic dial request that causes the telephone
`to perform dialing:
`– “if the infrared ray signal corresponding to the electronic dial
`request from the electronic pocketbook is received…the control
`unit 110 [of a telephone] determines whether the infrared signal
`contains a telephone number” and “control[s] the [telephone’s]
`dial unit 116 to automatically dial the telephone number”
`Yun, 4:54-59, 5:8-16, Ex. 1002; Petitioner’s Reply, 6-7, Paper 21; Second Declaration of
`Herbert Cohen, ¶18.
`
`In contrast to Uniloc’s assertion, as explained by Dr. Cohen,
`a POSA would have understood that the request of Yun is a
`form of control
`Petition, 21, 33; First Declaration of Herbert Cohen, ¶¶53, 99; Petitioner’s Reply, 8,
`Paper 21; Second Declaration of Herbert Cohen, ¶22.
`
`19
`
`

`

`Uniloc mischaracterizes Yun
`
`Uniloc’s distinction between Yun’s “on-hook” and “off-
`hook” disclosure regarding the claimed “controlling” is not
`relevant
`– Yun’s disclosure regarding when its telephone system is in an
`“off-hook” state describes the claimed functionality; the
`separate “on-hook” disclosure is of no consequence
`
`Yun, 4:24-31, 36-59, Ex. 1002; Petitioner’s Reply, 7-8, Paper 21; Second Declaration of
`Herbert Cohen, ¶20, Ex. 1021.
`20
`
`

`

`Harris
`
`A PDA communicates
`with a telephone via an
`wireless communication
`The PDA stores contact
`information including
`phone numbers
`A user selects an icon or
`spot on the PDS, which
`commands dialing of a
`number by the telephone
`
`Harris, 1:50-60, 2:43-47, 3:33-35, Ex. 1005; Petition 49, 63;
`First Declaration of Herbert Cohen, ¶¶158, 208, Ex. 1007.
`
`21
`
`

`

`Harris teaches the claimed “controlling”
`
`A user selects an icon or spot on a PDA associated with
`contact information
`Harris, 1:47-53, 1:66-2:6, 3:33-35, Ex. 1005; Petitioner’s Reply, 8, Paper 21; Second
`Declaration of Herbert Cohen, ¶21, Ex. 1021.
`Telephone number information associated with the
`contact information is sent to a telephone, which
`commands dialing of the number by the telephone
`Harris, 1:50-51, 1:58-60, 2:43-47, 3:33-35, Ex. 1005; Petitioner’s Reply, 8, Paper 21; Second
`Declaration of Herbert Cohen, ¶21, Ex. 1021.
`
`In contrast to Uniloc’s assertion, as explained by Dr. Cohen,
`a POSA would have understood that the command of
`Harris is a form of control
`Petition, 49, 63; First Declaration of Herbert Cohen, ¶¶158, 208, Ex. 1007;
`Petitioner’s Reply, 8, Paper 21; Second Declaration of Herbert Cohen, ¶22, Ex. 1021.
`
`22
`
`

`

`Yun and Harris do not teach away from the claimed “controlling”
`
`Uniloc’s assertion that Yun and Harris “teach[] away” from
`the controlling recitations is incorrect
`– Yun and Harris do not criticize, discredit, or otherwise discourage
`what is claimed and therefore do not teach away from the
`claimed features
`Patent Owner’s Response, 33, 35, Paper 13; Petitioner’s Reply, 8, 9, Paper 21; Second
`Declaration of Herbert Cohen, ¶23, Ex. 1021.
`Uniloc provided no expert testimony or any other evidence
`to support its assertion
`Patent Owner’s Response, 33, 35, Paper 13; Petitioner’s Reply, 8-9, Paper 21.
`
`As supported by Dr. Cohen, Yun and Harris each clearly
`disclose/teach the controlling recitations
`– Neither reference criticizes, discredits, or otherwise discourages
`what is claimed
`Petitioner’s Reply, 8-9, Paper 21; Second Declaration of Herbert Cohen, ¶23, Ex. 1021.
`
`23
`
`

`

`Dykes
`
`Like Yun and Harris, Dykes also
`describes a system including a
`computer connected to a
`cellular phone
`Software on the computer
`issues a dial command
`The computer directs the
`cellular phone to “receive the
`numbers” of a telephone
`number specified by the dial
`command
`Afterward, the computer
`transfers a “SEND” command
`to the cellular phone which
`“instructs the cellular phone to
`dial” the number
`
`Dykes, 2:52-62, 3:41-61, 4:14-33, 5:60-64, 9:22-24, 9:30-34, 10:38-48, 10:56-62, 11:9-13,
`11:65-12:5, 13:5-56, 13:47-14:10, 16:62-17:19, Ex. 1004; Petition 21-26, 33, 50-55, 63-64; First
`Declaration of Herbert Cohen, ¶¶54-62, 100, 159-168, 209, Ex. 1007.
`
`24
`
`

`

`Dykes teaches “controlling the telephone”
`
`Dykes shows how a POSA would have understood that
`a dial command, separate from a telephone number,
`would have been a standard method for implementing
`the automatic dialing described by Yun and Harris
`Petition 21-23, 33, 50-52, 63-64; First Declaration of Herbert Cohen, ¶¶55-56, 99, 160-162,
`208, Ex. 1007; Petitioner’s Reply, 9-10, Paper 21; Second Declaration of Herbert Cohen, ¶¶24-
`27, Ex. 1021.
`Dykes describes the “AT” command set
`– Includes the “ATDTn command” for instructing a modem to
`dial a phone number
`• “ATDT” = instruction to dial
`• “n” = the phone number to be dialed
`Dykes, 2:52-62, 3:41-44, 9:22-24, 10:38-43, Ex. 1004; Petition 21, 33, 50, 63-64; First
`Declaration of Herbert Cohen, ¶¶ 55-56, 99, 160-162, 208, Ex. 1007; Petitioner’s Reply, 9-10,
`Paper 21; Second Declaration of Herbert Cohen, ¶¶24-27, Ex. 1021.
`
`25
`
`

`

`Motivation to Combine Yun/Harris with Dykes
`The Petition, as credited by the Board in its institution decision,
`included several motivations to combine Yun/Harris with Dykes
`that were supported by testimony from Dr. Cohen:
`– all references are directed to systems where a device causes a telephone to dial
`a number
`– Routine substitution of Yun’s/Harris’ control for dialing a number with Dyke’s
`known control causes a predictable result: dialing a phone number
`– Implemented control from Dykes was conventional and known, and could have
`been accomplished with a high chance of success
`– Finite number of predictable solutions to the recognized problem of how to use
`command signals when controlling telephones
`– Dykes provides a known solution of sending a number first to a phone first, and
`a command to dial afterward
`– Implementation of Dykes’ system would have also provided a more flexible
`telephone control system
`Petition, 23-26, 33, 52-55, 63-64; First Declaration of Herbert Cohen, ¶¶57-62, 100, 163-
`168, 208, Ex. 1007; D.I., 10-15, Paper 7; Petitioner’s Reply, 9-10, Paper 21; Second
`Declaration of Herbert Cohen, ¶¶24-27, Ex. 1021
`Uniloc did not substantively address these motivations to
`combine in the POR
`
`26
`
`

`

`Motivation to Combine Yun/Harris with Dykes
`Uniloc asserts:
`– because Yun “teaches away from controlling limitations” it
`cannot be modified by Dykes
`– Dykes teaches away from Yun and Harris because it includes
`a “hardwired interface cable 20”
`Patent Owner’s Response, 33, 38-39, Paper 13.
`Uniloc’s assertions are unsupported attorney
`argument
`– No support from expert testimony or any other evidence
`
`Dykes is not relied on for wireless communication, and
`the Board preliminarily agreed that it does not teach
`away
`D.I. at 11-12, Paper 7.
`
`27
`
`

`

`RPI
`
`Unified certified itself as the sole RPI in the petition
`To ensure the Board had a fulsome evidential record for
`considering the RPI issue, Unified agreed to voluntary
`discovery under an agreed-upon Protective Order
`This voluntary discovery confirms that Unified is the
`sole RPI
`Uniloc provides baseless, speculative attorney
`arguments to attack Unified’s RPI certification, and
`proposes an unworkable ‘benefits-plus-relationship’
`standard for RPI
`
`Patent Owner’s Response, 1-20, Paper 13;
`Petitioner’s Reply, 10-11, Paper 21
`
`28
`
`

`

`Unified is the Sole RPI
`
`Unified is the sole RPI under the Trial Practice Guide (TPG)
`and Applications in Internet Time, LLC v. RPX Corp., 897 F.3d
`1336 (Fed. Cir. 2018) (“AIT”)
`– An RPI is defined by the TPG as “the party that desires review of
`the patent”
`– AIT endorsed the Trial Practice Guide’s fact-intensive approach to
`RPI
`– Under AIT and subsequent cases, direction, funding, and control
`remain central to the RPI analysis
`– The Board has confirmed that Unified’s specific business—targeting
`patents in certain Technology Zones—is consistent with Unified
`being the sole RPI in an IPR even when its members practice in
`those zones
`Petitioner’s Reply, 12-16, Paper 21; Realtime Adaptive Streaming, IPR2018-00883, Paper 36; Barkan
`Wireless, IPR2018-01186, Paper 24; Bradium Technologies, IPR2018-00952, Paper 31; Mobility Workx,
`IPR2018-01150, Paper 9; Plectrum, IPR2017-01430, Paper 30.
`
`29
`
`

`

`Unified is the Sole RPI
`
`Unified solely directed, controlled, and funded this IPR
`– Unified protects technology zones, not members
`– Members do not have control or even the opportunity to
`control Unified and are contractually bound otherwise
`– Unified does not work for or on behalf of members to resolve
`their litigations
`– Unified filed this IPR independently
`– Unified did not communicate or coordinate with any member
`regarding the challenged patent or seek input on the Petition
`– Unified does not have an attorney-client relationship with
`members
`– Unified’s business model prevents control by members
`Petitioner’s Reply, 16-21, Paper 21
`
`30
`
`

`

`Unified is the Sole RPI
`
`None of the salient facts in AIT exist here
`– Unified had no communication with any member regarding
`the ‘671 patent, other than a mass public email reporting the
`filing of the present petition
`– Unified shares no managers, directors, or any other officer
`with any member
`– Unified’s practices ensure it retains sole control
`– No member that is alleged to be an RPI was time barred
`when the petition was filed
`
`Petitioner’s Reply, 16-21, 21-22, Paper 21
`
`31
`
`

`

`Unified is the Sole RPI
`
`None of the salient facts in AIT exist here
`– Unified has no attorney-client relationship with its members
`– Unified alone funded this petition
`– Unified alone determines how to allocate resources;
`– No payment made just before filing
`– No membership fees designated for filing IPR challenges
`– Unified did not discuss the challenged patent or litigation
`with members
`
`Petitioner’s Reply, 16-21, 21-22, Paper 21
`
`32
`
`

`

`Uniloc’s RPI Standard is Overbroad and Contrary to AIT
`
`Uniloc’s proposed “pre-existing and established
`relationship” standard for RPI ignores the multi-factor
`approach of AIT and the Trial Practice Guide
`Uniloc’s proposed standard is over-broad
`– A non-party with any relationship with the petitioner and
`stood to benefit from filing of an IPR petition would become
`an RPI
`– An entity sued for infringement would be a presumptive RPI
`in any IPR filed by anyone with a preexisting relationship to
`the entity
`– Uniloc mixes RPI and privity principles and ends its analysis
`where the RPI inquiry begins
`Patent Owner’s Response, 9-13, Paper 13;
`Petitioner’s Reply, 22-24, Paper 21
`
`33
`
`

`

`Unified’s Members are not RPIs under Uniloc’s Proxy Theory
`
`Uniloc’s proposed proxy theory fails to lay out any
`governing rule under which the Board can determine
`whether a non-party is an RPI
`Unified is not a proxy nor agent for its members
`– Unified alone controls its decisions to file any IPR challenges
`– Unified does not resolve litigation for its members and
`Unified’s interests misalign with its members
`– Unified has not been specifically compensated by a non-party
`for filing the present petition
`– Unified has a substantial independent interest in protecting
`its designated technology zones, though it needs none
`Patent Owner’s Response, 14-18, Paper 13;
`Petitioner’s Reply, 25-26, Paper 21
`
`34
`
`

`

`Unified is the Sole RPI
`
`Unified alone funds, directs, and controls the present
`IPR
`Unified has not communicated with any member
`regarding filing the present IPR
`Membership alone is not sufficient to make a non-party
`a RPI
`Unified works to protect its Technology Zones from the
`threat of poor-quality patents
`
`Petitioner’s Reply, 10-26, Paper 21
`
`35
`
`

`

`Summary
`
`All challenged claims of the ’671 patent are
`unpatentable in view of the following combinations:
`• Claims 1-6 and 9-14 are obvious over Yun, Langlois, and
`Dykes
`• Claims 7, 8, 15, and 16 are obvious over Yun, Langlois,
`Dykes, and Husemann
`• Claims 1-7 and 9-15 are obvious over Harris, Langlois, and
`Dykes
`• Claims 8 and 16 are obvious over Harris, Langlois, Dykes,
`and Husemann
`
`36
`
`

`

`Petitioner’s Demonstrative Exhibits for Oral Argument
`IPR2018-00199
`
`Dated: February 21, 2019
`
`Respectfully Submitted,
`
`/Daniel V. Williams/
`
`David L. Cavanaugh
`Registration No. 36,476
`
`Jonathan Bowser
`Registration No. 54,574
`
`Roshan Mansinghani
`Registration No. 62,429
`
`Jonathan Stroud
`Registration No. 72,518
`
`Daniel V. Williams
`Registration No. 45,221
`
`Ellyar Y. Barazesh
`Registration No. 74,096
`
`i
`
`

`

`Petitioner’s Demonstrative Exhibits for Oral Argument
`IPR2018-00199
`
`CERTIFICATE OF SERVICE
`
`I certify that on February 21, 2019, I caused a copy of the foregoing
`
`materials:
`
`•
`
`Petitioner’s Demonstrative Exhibits for Oral Argument
`
`to be served via email, as agreed by the parties, to the attorneys of record for Patent
`
`Owner at the following email addresses:
`
`Ryan Loveless
`ryan@etheridgelaw.com
`
`Brett Mangrum
`brett@etheridgelaw.com
`
`James Etheridge
`jim@etheridgelaw.com
`
`Jeffrey Huang
`jeff@etheridgelaw.com
`
`Travis Richins (pro hac vice pending)
`travis@etheridgelaw.com
`
`Sean D. Burdick
`sean.burdick@unilocusa.com
`
`/ Jonathan E Robe /
`Jonathan E. Robe
`Registration No. 76,033
`
`ii
`
`

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