Inter Partes Review
`U.S. Patent No. 6,622,018
`
`Apple Inc. v. Uniloc Luxembourg S. A., Cases IPR2018-00394 and IPR2018-00395
`Scott T. Jarratt, Haynes and Boone, LLP
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`1
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`APPL-1043 / IPR2018-00394 and IPR2018-00395
`Apple v. Uniloc / Page 1 of 47
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`U.S. Patent No. 6,622,018
`
`Apple Inc. v. Uniloc Luxembourg S. A., Cases IPR2018-00394 and IPR2018-00395
`Scott T. Jarratt, Haynes and Boone, LLP
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`1
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`APPL-1043 / IPR2018-00394 and IPR2018-00395
`Apple v. Uniloc / Page 1 of 47
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`Three adaptive remote controllers
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`’018 Patent
`
`Ben-Ze’ev
`
`Leichiner
`
`APPL-1001, Fig. 7; ’394 Petition at 6
`
`APPL-1007, Fig. 6; ’394 Petition at 14
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`APPL-1027, Fig. 2; ’395 Petition at 14
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`2
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`2
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`The “Broadcasting” Limitation
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`The Combinations of the Primary References and the
`Idiot’s Guide
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`3
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`3
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`The “Broadcasting” Limitation
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`The Combinations of the Primary References and the
`Idiot’s Guide
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`4
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`4
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`’018 Patent, Claim 1
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`5
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`5
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`Plain and ordinary meaning of “broadcasting”
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`APPL-1012 at 5 (’394 Petition at 27; ’394 Patent Owner Response at 7)
`
`Petitioner
`
`Patent Owner
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`APPL-1003 at 54 (cited in ’394 Petition at 27, Reply at 2-3)
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`’394 Patent Owner Response at 6
`6
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`6
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`Ben-Ze’ev Teaches the “Broadcasting” Limitation
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`7
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`7
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`Ben-Ze’ev’s controller interrogates the existence of appliances
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`APPL-1007, 10:49-51; ’394 Petition at 27
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`APPL-1007, Fig. 6
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`APPL-1007, 2:58-63; ’394 Petition at 27
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`8
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`8
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`Ben-Ze’ev teaches transmitting a singular interrogation signal to
`all appliances in the vicinity
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`Claim [1.2]
`broadcasting a
`message, said message
`for locating remote
`devices within range of
`said transceiver; and
`
`APPL-1007, 10:49-60; ’394 Petition at 27
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`9
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`9
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`Ben-Ze’ev’s interrogation signal is not directed to an individual
`appliance
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`APPL-1007, 10:49-65; ’394 Petition at 27, 54; Reply at 11-12
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`10
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`10
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`Patent Owner’s characterization of “interrogation” is wrong
`
`Patent Owner Response
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`’394 Patent Owner Response at 9
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`“Interrogation” is merely defined as initiating a response:
`•
`“The sending of a signal that will initiate a response.”
`•
`“to give or send out a signal to (a device, such as a transponder) for
`triggering an appropriate response”
`“to obtain information from a computer or other machine”
`’394 Exhibit 2001 at ¶¶ 46-49 (cited in ’394 Reply at 9)
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`•
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`11
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`11
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`The record shows that an interrogation signal can be broadcast
`
`Evidence in the Record
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``
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`APPL-1032, 1:59-2:2; ’394 Reply at 8
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`APPL-1033, 2:59-3:1; ’394 Reply at 8-9
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`12
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`12
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`Leichiner Teaches the “Broadcasting” Limitation
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`13
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`13
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`Leichiner’s polling function detects the presence of new devices
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`APPL-1027, ¶ [0065]; Petition at 26; ’395 Reply at 4-5
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`APPL-1027, Fig. 2, [0017];
`’395 Petition at 15-16; ’395 Reply at 4
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`14
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`14
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`
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`Leichiner teaches transmitting a singular polling message to
`multiple devices at the same time
`
`Claim [1.2]
`broadcasting a
`message, said message
`for locating remote
`devices within range of
`said transceiver; and
`
`APPL-1027, ¶ [0022]; ’395 Petition at 25-26; Reply at 4
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`APPL-1027, ¶ [0012]; ’395 Petition at 25-26; Reply at 4
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`15
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`15
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`Patent Owner’s characterization of “polling” is wrong
`
`Patent Owner Response
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`’395 Patent Owner Response at 7
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`Leichiner
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`16
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`16
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`APPL-1027, ¶ [0012]; ’395 Petition at 25-26
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`
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`The record shows that a polling signal can be broadcast
`
`Evidence in the Record
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`APPL-1037 at 1; ’395 Reply at 12
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`APPL-1039, 6:26-32; ’395 Reply at 12
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`17
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`17
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`
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`The ‘018 Patent shows that multiple “messages” are received
`when broadcasting
`
`When a singular message is broadcast, each receiving device gets a
`copy.
`’395 Reply at 6-8 (citing Houh Supp. Dec. ¶ 5)
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`APPL-1001, Fig. 6; ’395 Reply at 7 (citing Houh Supp. Dec. ¶ 5)
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`18
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`18
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`
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`The “Broadcasting” Limitation
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`The Combinations of the Primary References and the
`Idiot’s Guide
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`19
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`19
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`It would have been obvious to use the PalmPilot’s Graffiti
`writing area to control Ben-Ze’ev/Leichiner’s devices
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`Ben-Ze’ev
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`Leichiner
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`APPL-1007, 10:45-48; ’394 Petition at 21
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`APPL-1027, [0061]; ’395 Petition at 20
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`Idiot’s Guide
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`APPL-1008 at 26; ’394 Petition at 20
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`20
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`20
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`Graffiti command advantages would have motivated a
`POSITA to pursue the combination
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`APPL-1008 at 78; ’394 Petition at 23-24
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`APPL-1008 at 68; ’394 Petition at 23-24
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`21
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`21
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`The combination would have been within the skill of a
`POSITA
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`APPL-1008 at 96; ’394 Petition at 24; Reply at 18
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`APPL-1008 at 89; ’394 Petition at 24 ’395 Reply at 20
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`22
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`22
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`POSITAs had already implemented the specific
`combination
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`APPL-1020 at 1; ’394 Petition at 22-23; ’394 Reply at 13-15
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`23
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`23
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`
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`The “Broadcasting” Limitation
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`A POSITA Would Have Combined the Primary
`References with the Idiot’s Guide
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`24
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`24
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`Additional Slides
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`25
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`25
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`The ’018 Patent utilizes the Bluetooth communication protocol
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`APPL-1001, Claim 10; ’394 Petition at 54-55
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`APPL-1001, 10:45-47; ’394 Petition at 5 and 10
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`26
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`26
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`Leichiner’s controller uses IR or radio transmissions
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`APPL-1027, [0018]; ’394 Petition at 16 and 25
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`APPL-1027, [0019]; ’394 Petition at 16 and 25
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`27
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`27
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`The ’018 Patent and Ben-Ze’ev discover devices in the same way
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`’018 Patent
`
`Ben-Ze’ev
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`APPL-1007, 2:58-63; ’394 Petition at 27
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`APPL-1001, 8:33-46; ’394 Petition at 5
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1007, 10:49-60; ’394 Petition at 27
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`28
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`28
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`
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`The ’018 Patent and Leichiner discover devices in the same way
`
`’018 Patent
`
`Leichiner
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`APPL-1001, 8:33-54; Petition at 5; ’395 Reply at 4-5
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`APPL-1027, ¶ [0065]; Petition at 26; ’395 Reply at 4-5
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`29
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`29
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`
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`Ben-Ze’ev teaches an adaptive remote controller of appliances
`that is RF based
`
`Claim [1.0]
`A method for controlling
`a remote devices over a
`wireless connection,
`said method
`comprising:
`
`APPL-1007, Abstract; ’394 Petition at 25
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`30
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`30
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`Ben-Ze’ev teaches a two-way wireless connection between the
`adaptive remote controller’s transceiver and appliances
`
`Claim [1.1]
`a) establishing said
`wireless connection
`between a transceiver
`and said remote device
`by:
`
`APPL-1007, 8:12-15; ’394 Petition at 26
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1007, 8:41-58; ’394 Petition at 26-27
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`31
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`31
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`Ben-Ze’ev teaches that appliances respond with their identification
`
`Claim [1.3]
`receiving a response
`from said remote
`device;
`
`APPL-1007, 10:49-60; ’394 Petition at 28
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`32
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`32
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`
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`Ben-Ze’ev teaches displaying icons representing the appliances
`that responded to the interrogation signal
`
`Claim [1.4]
`b) manifesting said
`remote device on a
`display device;
`
`APPL-1007, 10:66-11:4; ’394 Petition at 28-29
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`33
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`33
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`APPL-1007, Fig. 6 (annotated); ’394 Petition at 29
`
`
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`Ben-Ze’ev teaches activating buttons by pressing their location on
`the adaptive remote controller
`
`Claim [1.5]
`c) registering a position
`where contact is made
`with a surface of an
`input device,
`
`APPL-1007, 4:42-46; ’394 Petition at 29-30
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1007, Fig. 7 (annotated); ’394 Petition at 30
`
`34
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`34
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`
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`The Idiot’s Guide teaches the Graffiti area surface registering a
`“starting point” (position) where a stylus makes contact
`
`Claim [1.5]
`c) registering a position
`where contact is made
`with a surface of an
`input device,
`
`APPL-1008, p. 32; ’394 Petition at 32
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`35
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`35
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`APPL-1008, p. 66 (annotated); ’394 Petition at 32
`
`
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`Ben-Ze’ev teaches translating a particular touch screen location
`into a signal for activating a corresponding appliance feature
`
`Claim [1.6]
`wherein a particular
`position on said input
`device is translated into
`a particular command
`for controlling said
`remote device
`
`APPL-1007, 10:36-41; ’394 Petition at 33
`
`APPL-1007, 9:46-51; ’394 Petition at 33
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`36
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`36
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`
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`The Idiot’s Guide teaches the particular position of a stylus
`contact in the Graffiti area determines the character recognized
`
`Claim [1.6]
`wherein a particular
`position on said input
`device is translated into
`a particular command
`for controlling said
`remote device
`
`APPL-1008, p. 69 (annotated); ’394 Petition at 35
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1008, p. 4 (annotated); ’394 Petition at 37
`
`37
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`37
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`
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`Ben-Ze’ev teaches transmitting signals to control the appliances
`over the two-way wireless connection
`
`Claim [1.7]
`d) transmitting a
`command to said
`remote device over said
`wireless connection
`
`APPL-1007, 10:36-41; ’394 Petition at 39-40
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1007, 9:2-12; ’394 Petition at 39-40
`
`38
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`38
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`
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`Leichiner teaches an adaptive universal remote controller that
`controls devices via radio transmission
`
`Claim [1.0]
`A method for controlling
`a remote devices over a
`wireless connection,
`said method
`comprising:
`
`APPL-1027, [0009]; ’395 Petition at 24
`
`APPL-1027, [0019]; ’395 Petition at 24
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`39
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`39
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`
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`Leichiner teaches a two-way wireless link between the adaptive
`universal remote controller’s transceiver and controllable devices
`
`Claim [1.1]
`a) establishing said
`wireless connection
`between a transceiver
`and said remote device
`by:
`
`APPL-1027, Fig. 10 (annotated); ’395 Petition at 24-25
`
`APPL-1027, [0019]; ’395 Petition at 25
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`40
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`40
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`
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`Leichiner teaches the controlled device responding to the polling
`
`Claim [1.3]
`receiving a response
`from said remote
`device;
`
`APPL-1027, ¶ [0022]; ’395 Petition at 25-26
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`41
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`41
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`APPL-1027, [0020]; ’395 Petition at 26-27
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`
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`Leichiner teaches displaying icons representing the devices
`located in the immediate vicinity of the controller
`
`Claim [1.4]
`b) manifesting said
`remote device on a
`display device;
`
`APPL-1027, [0033]; ’395 Petition at 27
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1027, Fig. 2 (annotated); ’395 Petition at 27
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`42
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`42
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`
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`Leichiner teaches displaying control icons on a touch-sensitive
`display that detects control input from the user
`
`Claim [1.5]
`c) registering a position
`where contact is made
`with a surface of an
`input device,
`
`APPL-1027, [0045]; ’395 Petition at 28
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`43
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`43
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`APPL-1027, Fig. 3 (annotated); ’395 Petition at 28
`
`
`
`The Idiot’s Guide teaches the Graffiti area surface registering a
`“starting point” (position) where a stylus makes contact
`
`Claim [1.5]
`c) registering a position
`where contact is made
`with a surface of an
`input device,
`
`APPL-1008, p. 32; ’395 Petition at 30
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`44
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`44
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`APPL-1008, p. 66 (annotated); ’395 Petition at 30
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`
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`Leichiner teaches a user inputs commands into the adaptive
`remote controller via the touch-sensitive LCD display
`
`Claim [1.6]
`wherein a particular
`position on said input
`device is translated into
`a particular command
`for controlling said
`remote device
`
`APPL-1027, [0045]; ’395 Petition at 31
`
`APPL-1027, [0012]; ’395 Petition at 31-32
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`45
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`45
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`
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`The Idiot’s Guide teaches the particular position of a stylus
`contact in the Graffiti area determines the character recognized
`
`Claim [1.6]
`wherein a particular
`position on said input
`device is translated into
`a particular command
`for controlling said
`remote device
`
`APPL-1008, p. 69 (annotated); ’395 Petition at 33
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1008, p. 4 (annotated); ’395 Petition at 35
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`46
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`46
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`
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`Leichiner teaches transmitting control signals to control the
`remote devices over the two-way wireless link
`
`Claim [1.7]
`d) transmitting a
`command to said
`remote device over said
`wireless connection
`
`APPL-1027, [0063]; ’395 Petition at 37-38
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`APPL-1027, Fig. 11 (annotated); ’395 Petition at 38
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`47
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`47
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