`
`V.
`Uniloc 2017 LLC,
`
`IPR2018-00394, IPR2018-00395
`Patent 6,622,018
`
`Hearing Before
`Miriam L. Quinn,
`Charles J. Boudreau, and
`Garth D. Baer
`
`March 21, 2019
`
`
`
`“broadcasting”
`
`1. A methodfor controlling a remote devices over a wireless
`connection, said method comprising:
`a) establishing said wireless connection between a
`transceiver and said remote deviceby:
`broadcasting a message, said messagefor locating
`remote devices within range of said transceiver; and
`receiving a response from said remote device;
`b) manifesting said remote device on a display device;
`c) registering a position where contact is made with a
`surface of an input device, wherein a particularposition
`on said input device is translated into a particular
`commandfor controlling said remote device; and
`d) transmitting a commandto said remote device over said
`wireless connection.
`
`
`
`“broadcasting”
`
`broadcasting a message[in the singular], said message for locating
`remote devices[in the plural] within rangeof said transceiver;
`
`In the present embodiment, when it is necessary to locate
`and identify compliant devices, portable computer system
`transmits a broadcast message 640 (c.g., an inguiry 504) that
`is received by compliant remote devices 610-630. For
`example, a user with portable computer system 100 enters a
`room containing remote devices 610—630. Portable com-
`puter system 100, either automatically or in response to a
`user input, transmits broadcast message 640 for the purpose
`of discovering compliant devices in the room.
`As compliant devices, remote devices 610-630 respondto
`broadcast message 640 via responses 650a, 650b and 650c,
`respectively. In the present embodiment, responses 650a—c
`
`
`
` “broadcasting”
`
`broadcasting a message[in the singular], said messagefor locating
`remote devices[in the plural] within range of said transceiver;
`
`In this embodiment, with reference also to FIG. 6, each of
`the remote devices 610-630 have sent a response 650a—c,
`respectively, to portable computer system 100 in responseto
`broadcast message 640. Accordingly, each of remote devices
`
`671 patent(Ex.
`1001) at 9:8-11
`
`(FIG. 5) is used. In response to the broadcast message, each
`of remote devices 610-630 sends a response to portable
`computer system 100. In the Bluetooth embodiment, the
`broadcast message and the responses are transmitted using
`radio signals.
`
`Id. at 10:42-46
`
`In step 1120 of FIG. 11, each of the remote devices(e.¢.,
`remote devices 610-630) responding to the broadcast mes-
`sage is manifested on portable computer system 100. In one
`
`Id. at 10:57-59
`
`
`
`“broadcasting”
`
`broadcasting a message[in the singular], said messagefor locating
`remote devices[in the plural] within range of said transceiver;
`
`
`
`broadcast! adj. Sent to more than onerecipient. In
`communications and on networks, a broadcast mes-
`sage is one distributedto all stations, See also e-mail’
`(definition 1).
`broadcast? n. Asin radio or television, a transmission
`sent to more than onerecipient.
`
`
`
`Ben-Zeevs interrogating # claimed “broadcasting "
`
`46.
`
`Ben-Ze‘ev uses ‘interrogation’.
`
`The Oxford Dictionary of
`
`ComputerScience, 7th Edition, defines interrogation as follows:
`
`Dr. Easttom Decl.
`(Ex. 2001) 9946-47 1 The sendingof a signal
`that will initiate a response. A system
`may interrogate a peripheral to see ifit
`requires a data transfer. The responseis
`normally a status byte. When a number
`of devices are interrogated in a sequence
`the processis called “polling.
`
`47. Merriam-Webster defines interrogate (in relation to computer
`
`science) as “to give or send out a signal to (a device, such as a transponder)
`
`for triggering an appropriate response.””
`
`48. Oxford’s Learners Dictionary defines interrogate (in relation to
`
`computer science) as “to obtain information from a computer or other
`
`
`
`Ben-Zeevs interrogating # claimed “broadcasting "
`
`Dr. Easttom Decl.
`(Ex. 2001) 7949-50
`
`49.
`
`The plain and ordinary definition of interrogate (in relation to
`
`computer science) is to communicate with an individual machine, one at a
`
`time. And if one needs to communicate with multiple machines, one can
`
`interrogate them sequentially, in a process knownaspolling.
`
`50.
`
`This a substantially different process than broadcasting. In fact,
`
`the standard for network broadcasting specifically describes the disadvantages
`
`of such polling and makesit very clear that polling is different than broad cast:
`
`“When a host needs information that one or moreofits neighbors
`might have, it could have a list of neighbors to ask, or it could
`poll all of its possible neighbors until one responds. Use of a
`wired-in list creates obvious network management problems
`(early binding is inflexible). On the other hand, asking all of
`one's neighbors is slow if one must generate plausible host
`addresses, and try them until one works. On the ARPANET,for
`example, there are roughly 65 thousand plausible host numbers.
`MostIP implementations have used wired-in lists (for example,
`addresses of "Prime" gateways.) Fortunately, broadcasting
`provides a fast and simple way for a host to reach all of its
`
`
`
`Ben-Zeevs interrogating # claimed “broadcasting "
`
`Ex. 1007 (Ben-Ze’ev) 10:49-57
`the
`According to one embodiment of the invention,
`remote controller periodically interrogates the existence of
`all appliances in its vicinity. More particularly, the remote
`controller initiates a signal containing the remote controller
`device code, and an interrogation code asking the device to
`identify itself. Upon receipt and identification of the signal,
`the appliance sends to the remote controller an identification
`signal including the device code of the remote controller and
`the appliance identification section 41. The interrogation
`
`Id. at 11:4-7
`appliance, an icon 121, or both. If an identification signal
`from a device 1s not received within a predetermined period,
`for example, 5 minutes, the icon or text of that appliance is
`removed trom the screen. In this tashion, the list of appli-
`
`
`
`Ben-Zeevs interrogating # claimed “broadcasting "
`
`Ex. 1007 (Ben-Ze’ev) 12:59-64
`The remote controller of the invention can also be easily
`provided with an additional status (or state) interrogating
`command,
`that can be sent
`to a specific appliance,
`the
`keyboard of which ts displayed on the remote controller
`screen, in order to acquire in one command the appliance
`current status. This can be done by the remote controller
`
`Id. at 14:7-11
`
`controller may be used for opening a garage door. In this
`
`
`
`Ben-Zeevs interrogating # claimed “broadcasting "
`
`Ben-Ze’ev groups appliances in one network sothat they
`maybeinterrogated one ata time:
`According to the present invention, each appliance is
`
`provided with a unique device code.
`
`receives a network-unique code,
`
`Ex. 1007,
`8:65-9:2
`
`’018 patent disparages and distinguishes requiring devices
`to first be groupedinto a local network:
`
`
`A more modern solution is to wire devices together
`'018 patent,
`
`
`Gereneae so that they can be controlled from 4.53.56
`
`
`
`location such as a personal computer. However,this
`a central
`
`
`
`For example,
`
`
`
`Leichiner's polling # claimed “broadcasting "
`
`The Petition relies solely on Leichiner for the limitation “‘establishing said
`
`wireless communication between said transceiver and said remote device by:
`
`broadcasting a message, said messagefor locating remote devices within range of
`
`said transceiver.” as recited in independent claims 1 and 11 (and similarly recited
`
`in independent claim 21). In doing so, however, the Petition acknowledges that
`
`Leichiner does not disclose “broadcasting a message”, as required by the claim
`language. Instead. thePetition a
`
`
`vicinity.”See Pet 26; EX1027 § 22 (emphasis added).
`
`
`
`Leichiner's polling # claimed “broadcasting”
`
`Leichiner (Ex.1027) at J 10:
`
`[0010] What is provided is an adaptive standalone remote
`control
`system which conducts polling to each of the
`controlled devices located in the immediate vicinity, and
`determines which device 1s available and what properties the
`available device has.
`The remote control system of the
`present
`invention provides to the user a single hand-held
`remote controller which constitutes a suitable user interface
`relative to each of the available devices or apparatuses
`located in the vicinity thereof.
`In this case, the user interface
`is utilized, for example,
`in a manner so that the user can
`control
`the available controlled devices in the ummediate
`vicinity, according to some sort of command orsetting
`inputted by the user by utilizing the user interface presented
`on the user
`interface screen of the controlled device.
`Communications
`of
`information
`between
`the
`remote
`controller and the controlled device are performed,
`for
`
`
`
`Leichiner's polling # claimed “broadcasting’ ]
`
`Dr. Easttom Decl.
`(Ex. 2001) 936-37
`
`36.
`
`Furthermore,
`
`Leichiner
`
`explicitly
`
`relies
`
`on
`
`infrared
`
`communications. This is clear from the following excerpts from Leichiner:
`
`“Between the controller and the controlled device, infrared-ray
`(IR) communication links (106 and 110) are provided”
`
`"The wireless system of the present invention comprises the
`controller, which is a hand-held wireless infrared-ray remote
`control unit in one working example of the present invention."
`The ‘018 patent explicitly relies on Bluetooth communications.
`
`37.
`
`This is a significant and substantial difference. Infrared communication works
`
`by sending a signalin a straight line and requires a direct line to the target,
`
`and can be interrupted by objects between the two devices’. There are some
`
`specific and important disadvantagesto infrared:
`
`“e Asit is line of sight, it is difficult to control things not in line
`of sight of transmitting IR control device.
`* It can control one device at a time.
`* Maximum data transfer rate is about 4 Mbps
`* The device should be kept stable during the data transfer mode.
`* hard obstacles (such as doors, walls), bright sunlight, smoke,
`dust and fog affects Infrared communication.
`* Even though wecan notsee Infrared waves, it can damage eyes
`
`
`
` Leichiner's polling # claimed “broadcasting "
`
`Dr. Easttom Decl. (Ex. 2001) 948-49:
`
`48.
`
`Leichiner instead uses polling. PC Magazine defines polling as
`
`follows (emphasis added):
`
`A communications technique that determines when a terminalis
`ready to send data. The computer continually interrogates its
`connected terminals in a round robin sequence. If a terminal
`has data to send, it sends back an acknowledgment and the
`transmission begins. Contrast with an interrupt-driven system, in
`whichthe terminal generates a signal whenit has data to send.
`In Dr. McArdle's notes for his engineering course EE414
`
`49.
`
`Communication Networks, hestates:
`
`“Fach station on the network is polled in some predetermined order.”
`
`
`
`Leichiner's polling # claimed “broadcasting "
`
`Dr. Easttom Decl. (Ex. 2001) J 50:
`
`50.
`
`The Oxford Dictionary of Computer Science defines polling as
`
`follows:
`
`polling The process by which onestation
`on a ‘multidropline(the primary station)
`addresses anotherstation (a secondary
`station), giving the secondary station
`access to the communication channel.
`The secondary station is then able to send
`status information and/or data to the
`primary. The primary station resumes
`control of the line and may senddata of
`its own or poll anotherstation.
`Polling is a form of
`“timedivision
`multiplexing. The precise polling strategy
`used depends upontheapplication. In
`
`
`
`Leichiner's polling # claimed “broadcasting "
`
`51.
`
`Polling a substantially different process than broadcasting. In
`
`fact,
`
`the standard for network broadcasting specifically describes the
`
`Dr. Easttom Decl.
`(Ex. 2001) 7 51
`
`disadvantages ofsuch polling and makesit very clear that polling is different
`
`than broad cast:
`
`“When a host needs information that one or more ofits neighbors
`might have, it could havea list of neighbors to ask, or it could
`poll all of its possible neighbors until one responds. Use of a
`wired-in list creates obvious network management problems
`(early binding is inflexible). On the other hand, asking all of
`one's neighbors is slow if one must generate plausible host
`addresses, and try them until one works. On the ARPANET,for
`example, there are roughly 65 thousand plausible host numbers.
`Most IP implementations have used wired-in lists (for example,
`addresses of "Prime" gateways.) Fortunately, broadcasting
`provides a fast and simple way for a host to reach all ofits
`neighbors.’
`
`
`
`Complete Idiot's Guide to PalmPilot and Palm Ill
`
`Dr. Easttom’s testimony(Ex. 2001) included the following
`observations concerning the Idiot’s Guide reference:
`
`Y “These booksare designedto give a completely non-technical
`reader, generalinsight into how to use a given product....
`Nothingin the book provides details on how features are
`implemented.” (27.)
`
`Y “These booksare not about howthe particular device was
`built, nor about how theinternal functionality is executed.
`There is absolutely no information on howthe device performs
`the functions. Therefore, it would be impossible to create any
`device based on the contentof this book (or any of the Idiot’s
`Guide series). Furthermore, since nodetails are provided of
`howthe functionality is implemented,it is impossible to
`determinethe details of the specific means and operation of
`any functionality, thus making it useless to a POSA in making
`
`