`Petitioner
`v.
`LoganTree, LP,
`Patent Owner
`IPR2018-00564 (Patent 6,059,576) and IPR2018-00565 (Same)
`Presentation of Petitioner
`Oral Hearing –June 4, 2019
`
`IPR2018-00564/IPR2018-00565
`Garmin EX1022
`
`Demonstrative Exhibit – Not Evidence
`
`1
`
`
`
`IPR2018-00564 – Disputes Now Center Around Only Two
`Grounds
`
`Combination
`
`Ground 1: Stewart + Rush
`Ground 4: Richardson +
`Stewart
`
`Claim(s)
`
`20-26, 29, 104-107, 110, 113-
`116, 118, 121, 126-128, 134-
`135, 175
`20, 138
`
`NOTE: All citations to the record are from the IPR2018-00564 proceeding.
`Demonstrative Exhibit – Not Evidence
`
`2
`
`
`
`IPR2018-00565 – Disputes Center Around Same Two Grounds
`
`Combination
`
`Ground 1: Stewart + Rush
`Ground 3: Richardson +
`Stewart
`
`Claim(s)
`
`1, 2, 4-5, 9, 10, 12
`1, 7, 8, 13, 14, 56-58, 140, 144,
`146
`
`Demonstrative Exhibit – Not Evidence
`
`3
`
`
`
`Independent Claim 20
`
`EX1001 at Claim
`20 (emphasis
`added)
`
`Demonstrative Exhibit – Not Evidence
`
`4
`
`
`
`PO Raises Arguments for Nearly Every Limitation
`
`• Five Main Arguments
`–(1) Measuring unrestrained movement
`–(2) Interpreting, using a microprocessor…
`–(3) Storing said data in memory
`–(4) Detecting, using a microprocessor…
`–(5) Storing, in said memory…
`
`Demonstrative Exhibit – Not Evidence
`
`5
`
`
`
`Stewart’s Helmet System
`
`• A portable system designed
`to measure and record
`acceleration of the body or
`body parts during normal
`activity
`• The system uses
`accelerometers, a processor,
`and memory
`• Stewart detects an event, by
`comparing the accelerometer
`data to a predetermined
`threshold
`
`EX1004, Fig. 2; Petition, at 11-14; I.D., at 7-9.
`Demonstrative Exhibit – Not Evidence
`
`6
`
`
`
`Rush’s Helmet
`
`• A monitoring device in a
`football helmet that uses
`sensors to detect impacts
`• The sensor is adjustable to
`accommodate different
`thresholds or levels of
`impacts
`• The monitoring device also
`will record the time and date
`of each potentially harmful
`impact
`
`EX1006, Fig. 20; Petition, at 13-14; I.D., at 10.
`Demonstrative Exhibit – Not Evidence
`
`7
`
`
`
`Stewart Measures “unrestrained movement in any direction”
`
`EX1001 at Claim 20 (emphasis
`added)
`• LoganTreeArgues that Stewart is “Restrained”:
`• Stewart is clear
`
`Sur-Reply, at 6
`
`EX1004 at 6:22-29; Reply, at 4.
`
`8
`
`Demonstrative Exhibit – Not Evidence
`
`
`
`Stewart Measures “unrestrained movement in any direction”
`
`EX1001 at Claim 20 (emphasis
`added)
`• PO Argues that Stewart is “Restrained” to a particular sport:
`Sur-Reply, at 5.
`• Stewart is clear
`
`Demonstrative Exhibit – Not Evidence
`
`EX1004 at 5:12-22; I.D., at 7-9;
`Petition at 14-15.
`
`9
`
`
`
`PO’s Construction of Unrestrained Fails
`
`• PO’s narrow construction of “unrestrained” is inconsistent with
`the file history
`
`EX1002, at 110; Reply, at 5.
`
`Demonstrative Exhibit – Not Evidence
`
`10
`
`
`
`Stewart Discloses the Microprocessor “interpreting”
`Measurement Data
`
`EX1001 at Claim 20 (emphasis
`added)
`• LoganTreeis inconsistent about the existence (and role) of the
`processor:
`
`EX2001, at ¶ 44-45.
`
`Demonstrative Exhibit – Not Evidence
`
`11
`
`
`
`Stewart Discloses the Microprocessor “interpreting”
`Measurement Data
`
`• LoganTree’ssecond processor argument:
`
`PO Response, at 18.
`
`Demonstrative Exhibit – Not Evidence
`
`12
`
`
`
`Stewart Discloses the Microprocessor “interpreting”
`Measurement Data
`
`• Stewart discloses a broader role for its processor:
`
`EX1004, at 8:58-62, 5:5-11
`and 5:7-11.
`
`Demonstrative Exhibit – Not Evidence
`
`13
`
`
`
`Stewart Discloses Storing Measurement Data
`
`EX1001 at Claim 20 (emphasis
`added)
`
`EX1004 at 4:60-64
`
`EX1004 at Fig. 1 (emphasis
`added)
`
`14
`
`Demonstrative Exhibit – Not Evidence
`
`
`
`Stewart + Rush Discloses Storing the First Event Information
`and First Time Stamp Information in Memory
`
`EX1001 at Claim 20 (emphasis
`added)
`• PO misapprehends the combination:
`Stewart: EX1004 at 4:60-64
`
`Rush: EX1006 at 10:26-28
`
`Demonstrative Exhibit – Not Evidence
`
`15
`
`
`
`Stewart + Rush Discloses Detecting a First User-Defined Event
`
`EX1001 at Claim 20 (emphasis
`added)
`
`Stewart: EX1004 at 14:6-11
`
`Rush: EX1006 at 9:48-58
`
`Demonstrative Exhibit – Not Evidence
`
`16
`
`
`
`Richardson + Stewart
`
`•
`
`•
`
`IPR2018-00564
`Ground 4: Richardson +
`Stewart
`IPR2018-00565
`Ground 3: Richardson +
`Stewart
`
`Combination
`
`Combination
`
`Claim(s)
`
`20, 138
`1, 7, 8, 13, 14, 56-58, 140, 144,
`146
`
`Claim(s)
`
`Demonstrative Exhibit – Not Evidence
`
`17
`
`
`
`Richardson Discloses Storing the First Time Stamp Information
`Reflecting a Time at Which the Movement Data Occurred
`
`EX1001 at Claim 20 (emphasis
`added)
`
`Petitioner’s Reply, Paper 16
`at 22
`
`Richardson: EX1009 at 6:26-
`32
`
`Demonstrative Exhibit – Not Evidence
`
`18
`
`
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