Apple, Inc.,
`
`v
`
`Uniloc 201 7 LLC,
`
`IPR2018-00394, IPR2018-OO395
`
`Patent 6,622,018
`
`Hearing Before
`Miriam L. Quinn,
`
`Charles J. Boudreau, and
`
`Garth D. Baer
`
`March 21, 2019
`
`
`
`v
`
`Uniloc 201 7 LLC,
`
`IPR2018-00394, IPR2018-OO395
`
`Patent 6,622,018
`
`Hearing Before
`Miriam L. Quinn,
`
`Charles J. Boudreau, and
`
`Garth D. Baer
`
`March 21, 2019
`
`
`
`“broadcasting”
`
`1. A method for controlling a remote devices over a wireless
`
`connection, said method comprising:
`
`a) establishing said wireless connection between a
`
`transceiver and said remote device by:
`
`broadcasting a message, said message for 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 particular position
`
`on said input device is translated into a particular
`
`command for controlling said remote device; and
`
`d) transmitting a command to said remote device over said
`wireless connection.
`
`
`
`“broadcasting”
`
`broadcasting a message [in the singular], said message for locating
`
`remote devices [in the plural] within range of said transceiver;
`
`In the present embodiment, when it is necessary to locate
`and identify compliant devices, portable computer system
`transmits a broadcast message 640 (cg, an inquiry 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 respond to
`broadcast message 640 via responses 650:1, 650!) and 650C,
`respectively. in the present embodiment, responses 650a—c
`
`
`
`“broadcasting”
`
`broadcasting a message [in the singular], said message for locating
`
`remote devices [in the plural] within range of said transceiver;
`
`In ihis embodiment, with reference also to FIG. 6, each of
`the remote devices 610—630 have sent a response 65011—6,
`respectively, to portable computer system 100 in response to
`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.g.,
`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 message for locating
`
`remote devices [in the plural] within range of said transceiver;
`
`
`
`broadcast' adj. Sent to more than one recipient. In
`communications and on networks, a broadcast mes-
`sage is one distributed to all stations. See also e-mail'
`(definition 1).
`
`broadcast2 n. As in radio or television, a transmission
`
`sent to more than one recipient.
`
`
`
`Ben-Ze’ev’s interrogating 5'5 Claimed “broadcasting”
`
`46.
`
`Ben-Ze‘ev uses ‘interrogation’.
`
`The Oxford Dictionary of
`
`Computer Science, 7th Edition, defines interrogation as follows:
`
`Dr. Easttom Decl.
`(EX. 2001) 111146-47
`
`
`_ The sending ofa Signal
`that will initiate a response. A system
`
`may interrogate a peripheral to see if it
`
`requires a data transfer. The response is
`
`normally a status byte. When a number
`
`of devices are interrogated in a sequence
`
`the process is called mailing.
`
`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."2
`
`48. Oxford’s Learners Dictionary defines interrogate (in relation to
`
`computer science) as “to obtain information from a computer or other
`
`
`
`Ben-Ze’ev’s interrogating 75 Claimed “broadcasting”
`
`49.
`
`The plain and ordinary definition of interrogate (in relation to
`
`computer science) is to communicate with an individual machine, one at a
`
`D11 Easttom DeCL
`
`time. And if one needs to communicate with multiple machines, one can
`
`(Ex. 2001) 111149-50
`
`interrogate them sequentially, in a process known as polling.
`
`50.
`
`This a substantially different process than broadcasting. In fact,
`
`the standard for network broadcasting specifically describes the disadvantages
`
`of such polling and makes it very clear that polling is different than broad cast:
`
`“When a host needs information that one or more of its 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.
`Most [P 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-Ze’ev’s interrogating 75 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 is not received within a predetermined period,
`for example, 5 minutes, the icon or text of that appliance is
`removed from the screen. In this fashion, the list of appli-
`
`
`
`Ben-Ze’ev’s interrogating 75 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 is 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
`case when a driver a
`roaches a
`
`ara e door
`
`n t 18 case, upon recerp
`
`
`
`Ben-Ze’ev’s interrogating 5'5 claimed “broadcasting”
`
`Ben-Ze’ev groups appliances in one network so that they
`
`may be interrogated one at a time:
`
`According to the present. invention each a
`
`liance is
`
`provided with a unique device code.
`
`receives a network-uni ue code,
`
`’018 patent disparages and distinggishes requiring devices
`
`to first be grouped into a local network:
`
`A more modern solution 15 to ere dev1ces together
`
`fl so that they can be controlled
`
`acen ra oca lOI] sue asa ersonalcom uter. However
`
`
`For examp e,
`
`
`0111
`
`
`
`
`'018 patent,
`1:53-56
`
`
`
`Leiohiner’s polling 75 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.
`:~
`?,'_'._ ..
`
`
`
`—See Pet 26; EX1027 11 22 (emphasis added).
`
`
`
`Leichiner’s polling 5'5 claimed “broadcasting”
`
`Leichiner (Ex.1027) at 1] 10:
`
`[0010] What is provided is an adaptive standalone remote
`control
`system which conducts polling to each of the
`controlled devices located in the inmlediate vicinity. and
`determines which device is 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 inmiediate
`
`vicinity, according to some sort of command or setting
`inputted by the user by utilizing the user interface presented
`011
`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 5'5 claimed “broadcasting’
`
`!
`
`D 1
`D E
`1" aSttom BC -
`(Ex. 2001) 111136-37
`
`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 suding a signal in a straight line and requires a direct line to the target,
`
`and can be interrupted by objects between the two devicesl. There are some
`
`specific and important disadvantages to infrared:
`
`“0 As it is line of sight, it is difiicult to control things not in line
`of sight of transmitting 1R control device.
`0 It can control one device at a time.
`
`0 Maximum data transfer rate is about 4 Mbps
`0 The device should be kept stable during the data transfer mode.
`- hard obstacles (such as doors, walls), bright SImIight, smoke,
`dust and fog affects Inflated communication.
`
`
`
` Leiohiner’s polling 5'5 claimed “broadcasting”
`
`Dr. Easttom Decl. (Ex. 2001) 111148-49:
`
`48.
`
`Leichiner instead uses polling. PC Magazine defines polling as
`
`follows (emphasis added):
`
`A communications technique that determines when a terminal is
`ready to send data. The computer continually interrogates its
`connected terminals in a round robin seguence. If a terminal
`has data to send, it sends back an acknowledgment and the
`transmission begins. Contrast with an interrupt-driven system, in
`which the terminal generates a signal when it has data to send.
`
`49.
`
`In Dr. McArdle's notes for his engineering course EE414
`
`Communication Networks, he states:
`
`“Each station on the network is polled in some predetermined order.”5
`
`
`
`Leiohiner’s polling 75 claimed “broadcasting”
`
`Dr. Easttom Decl. (Ex. 2001) ‘H 50:
`
`50.
`
`The Oxford Dictionary of Computer Science defines polling as
`
`follows:
`
`mm The process by which one station
`on aWe (the primary station)
`
`addresses another station (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 send data of
`
`its own or poll another station.
`
`Polling is a form of Zfimgdiyisicm
`
`multiplmdng. The precise polling strategy
`
`used depends upon the application. In
`
`
`
`Leiohiner’s polling 5'5 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) 11 5 1
`
`disadvantages of such polling and makes it very clear that polling is different
`
`than broad cast:
`
`“When a host needs information that one or more of its 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.
`Most [P 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
`neighbors.”6
`
`
`
`Complete Idiot’s Guide to PaImPilot and Palm III
`
`Dr. Easttom’s testimony (Ex. 2001) included the following
`
`observations concerning the Idiot’s Guide reference:
`
`\/ “These books are designed to give a completely non-technical
`reader, general insight into how to E a given product.
`
`Nothing in the book provides details on how features are
`
`implemented." (1127.)
`
`\/ “These books are not about how the particular device was
`built, nor about how the internal functionality is executed.
`
`There is absolutely no information on how the device performs
`
`the functions. Therefore, it would be impossible to create any
`
`device based on the content of this book (or any of the Idiot’s
`
`Guide series). Furthermore, since no details are provided of
`
`how the functionality is implemented, it is impossible to
`
`determine the details of the specific means and operation of
`
`any functionality, thus making it useless to a POSA in making
`
`
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