UNIFIED PATENTS INC.,
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`
`IPR2018‐00952
`Patent No. 9,253,239
`
`Patent Owner’s Demonstratives
`September 17, 2019 Oral Argument
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`1
`
`Bradium Exhibit 2060
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 1 of 47
`
`
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`
`IPR2018‐00952
`Patent No. 9,253,239
`
`Patent Owner’s Demonstratives
`September 17, 2019 Oral Argument
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`1
`
`Bradium Exhibit 2060
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 1 of 47
`
`
`
`Petitioner’s Sole Ground
`
`Whether Claim 20 of the ’239 Patent is obvious
`under 35 U.S.C. 103(a) over the combination of
`Reddy, Hornbacker and Rosasco.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`2
`
`Paper 2 (Petition) at 3; Paper 31 (Institution Decision) at 41.
`
`Bradium Exhibit 2060, Page 2 of 47
`
`
`
`’239 Patent
`Claim 20
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`3
`
`Bradium Exhibit 2060, Page 3 of 47
`
`
`
`’239 Patent, Claim 20
`
`Key claim terms:
`
`(1) Two requests, each based on a different
`user‐controlled viewpoint (based on
`independent claim 1);
`
`(2) A step for “determining priority of the first
`request and the second request.” (claim 20)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`4
`
`Paper 45, 16‐17
`
`Bradium Exhibit 2060, Page 4 of 47
`
`
`
`’239 Patent, Claim 20 (Depends from Claim 1)
`
`[1 PREAMBLE] A method of retrieving images over a network
`communication channel…comprising steps of:
`[1A] issuing a first request from the user computing device…for a
`first update data parcel… [1B] selected based on a first user‐
`controlled image viewpoint on the user computing device;
`[1C] receiving the first update data parcel ….;
`[1D] displaying ….;
`[1E] issuing a second request from the user computing device ...
`for a second update data parcel … selected based on a second
`user‐controlled image viewpoint on the user computing device
`relative to the predetermined image, the second user‐controlled
`image viewpoint being different from the first user‐ controlled
`image viewpoint; [1F] receiving the second update data parcel….;
`[1G] displaying….;
`[1H] …series of K1‐N derivative images….
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`5
`
`Paper 38 at 37‐38; Paper 45 at 17.
`
`Bradium Exhibit 2060, Page 5 of 47
`
`
`
`’239 Patent, Claim 20
`
`[1A] issuing a first request…for a first update data
`parcel … [1B] selected based on a first user‐controlled
`image viewpoint…;
`….
`[1E] issuing a second request… for a second update
`data parcel…selected based on a second user‐
`controlled image viewpoint … different from the first
`user‐controlled image viewpoint;
`….
`20. A method as in claim 1, further comprising a step
`for determining priority of the first request and the
`second request.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`6
`
`Paper 38 at 37‐38; Paper 45 at 17.
`
`Bradium Exhibit 2060, Page 6 of 47
`
`
`
`Claim 20
`Unified Expert (Wilson) Deposition Testimony
`
`Q. So I want to understand, I want to ask you about
`the viewpoints. First off, so what is a user‐controlled
`image viewpoint as claimed?
`
`A. A user‐controlled viewpoint, image viewpoint,
`would be a perspective on the imagery data, or
`location space, that is controllable by the user.
`
`Q. Controllable by the user such as entering a
`particular location ‐‐ entering navigational controls?
`
`A. Yeah, entering navigational controls.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`7
`
`EX2044, 80:10‐21.
`
`Bradium Exhibit 2060, Page 7 of 47
`
`
`
`’239 Patent
`
`Specification Support for Patent
`Owner’s Plain Meaning Claim
`Interpretation
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`8
`
`Bradium Exhibit 2060, Page 8 of 47
`
`
`
`’239 Patent
`PTAB Decision IPR2016‐01897 (Apr. 5, 2017)
`
`“The ’239 Patent discloses a priority request
`queue and states that when a network
`thread becomes available, the pending
`requests in the queue are examined and the
`request with the highest priority is selected.
`Ex. 1001, 9:4‐11. As a result, requests can be
`issued out of order depending upon an
`independently assigned request priority. Id.
`at 11‐13.”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`9
`
`Paper 38 at 1; Paper 45 at 12; EX2032 (IPR2016‐01897 Paper
`17 (Institution Decision)) at 19‐20 (emphasis added).
`
`Bradium Exhibit 2060, Page 9 of 47
`
`
`
`’239 Patent
`Priority Request Queue
`
`The control block 44, based in part on
`changes in the viewing frustum,
`determines the ordered priority of image
`parcels to be requested from the
`server 12, 22 to support the progressive
`rendering of the displayed image. The
`image parcel requests are placed in a
`request queue 52 for issuance by the
`parcel request client 42. Preferably, the
`pending requests are issued in priority
`order, thereby dynamically reflecting
`changes in the viewing frustum with
`minimum latency.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`10
`
`‘239 Pat. at Fig. 3, 7:54‐62; Paper 38 at 35; Paper 45 at 18‐21.
`
`Bradium Exhibit 2060, Page 10 of 47
`
`
`
`’239 Patent
`Priority Request Queue
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`11
`
`‘239 Pat., Fig. 3; Paper 38 at 35.
`
`Bradium Exhibit 2060, Page 11 of 47
`
`
`
`’239 Patent
`Request for Multiple Viewpoints in Queue
`
`The client architecture 40 preferably
`executes in multiple process threads, with
`additional threads being utilized for
`individual network data request
`transactions. As shown in FIG. 5, an image
`parcel management process 80
`implements a loop that determines image
`parcels subject to update 82 and creates
`corresponding image parcel download
`requests 84. Navigation events that alter
`the viewing frustum are considered in
`part to determine the current field of
`view. The quad tree data structures are
`examined 86 to identify viewable image
`parcels of higher resolution than currently
`available in the parcel data store 46.
`‘239 Pat. at Fig. 5, 8:30‐40; Paper 38 at 36;
`Paper 45 at 18‐21; EX2054 at ¶¶42‐46.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`12
`
`Bradium Exhibit 2060, Page 12 of 47
`
`
`
`’239 Patent
`Requests for Multiple Viewpoints in Queue
`
`For small clients 20, the available memory for the
`parcel data store 46 is generally quite restricted. In
`order to make optimal use of the available memory,
`only currently viewable image parcels are subject to
`download. Where the size of the parcel data
`store 46 is not so restricted, this constraint can be
`relaxed. In either case, a memory management
`process 94 runs to monitor use of the parcel data
`store 46 and selectively remove image parcels to free
`memory for newly requested image parcels.
`Preferably, the memory management
`process 94 operates to preferentially remove image
`parcels that are the furthest from the current
`viewing frustum and that have the highest data
`structure depth.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`13
`
`‘239 Pat. at Fig. 3, 8:57‐9:1; Paper 38 at 36;
`Paper 45 at 18‐21; EX2054 at ¶¶42‐46.
`
`Bradium Exhibit 2060, Page 13 of 47
`
`
`
`’239 Patent
`Assign Download Priority of Each Request
`
`The download priority associated with each request is
`determined 176 by execution of a function S that operates
`on a 2D polygon argument P and returns a real number
`representing the request priority. The function argument P
`is a list of real (x, y) coordinates of the vertices of the
`current polygon in screen coordinates after being clipped
`to fit within the current viewing frustum.…Thus, the
`accumulated priority for any image parcel pending
`download is the sum of the values of returned by the
`function S for each of the viewable polygons that require
`some part of the image parcel as the source data for
`texture map rendering of the polygon. The priority
`operation of the request queue 52 is such that download
`requests will be issued preferentially for image parcels
`with the largest priority value.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`14
`
`‘239 Pat. at Fig. 3; 10:20‐52; Paper 38 at 36;
`Paper 45 at 18‐21; EX2054 at ¶¶42‐46.
`
`Bradium Exhibit 2060, Page 14 of 47
`
`
`
`’239 Patent
`Advantageous Re‐Prioritization of Requests in Queue
`
`Still another advantage of the present
`invention is that image parcel data requests
`and presentation can be readily optimized to
`use low to very low bandwidth network
`connections. The software system of the
`present invention provides for re‐prioritization
`of image parcel data requests and presentation
`in circumstances where the rate of point‐of‐
`view navigation exceeds the data request rate.
`‘239 Pat., 4:13‐20.
`
`Preferably, the pending requests are issued
`in priority order, thereby dynamically
`reflecting changes in the viewing frustum
`with minimum latency.
`‘239 Pat., 7:59‐62.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`15
`
`‘239 Pat. at 4:13‐20, 7:59‐62; Paper 38 at
`34‐36; Paper 45 at 19; EX2054 at ¶¶42‐46.
`
`Bradium Exhibit 2060, Page 15 of 47
`
`
`
`’239 Patent
`Highest Priority Request is Issued
`
`When a network request thread becomes
`available, the process 100 examines 106 all
`of the pending requests in the priority
`request queue 52 and selects 108 the
`request with the highest assigned priority.
`Thus, sequentially enqueued requests can
`be selectively issued out of order based on
`an independently assigned request priority.
`The request is then issued 110….
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`16
`
`‘239 Pat. at Fig. 3; 9:8‐14; Paper 38 at
`36; Paper 45 at 19‐20.
`
`Bradium Exhibit 2060, Page 16 of 47
`
`
`
`Asserted
`Prior Art
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`17
`
`Bradium Exhibit 2060, Page 17 of 47
`
`
`
`Petitioner’s Primary References for Claim 20
`
`Reddy
`
`Rosasco
`
`(Hornbacker not a primary
`reference)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`18
`
`Bradium Exhibit 2060, Page 18 of 47
`
`
`
`Reddy
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`19
`
`Bradium Exhibit 2060, Page 19 of 47
`
`
`
`Reddy
`
`• Reddy displays scenes based on a single,
`current user viewpoint;
`
`• The features of Reddy do not teach or
`suggest prioritization.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`20
`
`Paper 38 at 61‐67; Paper 45 at 21‐23.
`
`Bradium Exhibit 2060, Page 20 of 47
`
`
`
`Reddy
`Single Viewpoint
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`21
`
`Bradium Exhibit 2060, Page 21 of 47
`
`
`
`Reddy
`Display based on the single, current viewpoint for a scene
`
`Petition [1.B]: “Fig. 5 in Reddy is a
`screenshot illustrating a user‐selected
`viewpoint.”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`22
`
`Petition at 29; Paper 38 at 51, 61.
`
`Bradium Exhibit 2060, Page 22 of 47
`
`
`
`Reddy
`Display based on the single, current viewpoint for a scene
`
`Petition [1.E]:
`
`“When the user changes the user‐controlled
`image viewpoint, a request for retrieving
`certain image data is initiated for retrieving
`updated data parcels.”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`23
`
`Petition at 31‐32.
`
`Bradium Exhibit 2060, Page 23 of 47
`
`
`
`Reddy
`Distance‐Based
`Level of Detail (LOD)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`24
`
`Bradium Exhibit 2060, Page 24 of 47
`
`
`
`Reddy
`Distance‐Based LOD (Level of Detail) Scene
`
`Reddy Scene: Ten non‐overlapping tiles.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`25
`
`Paper 38 at 48–49; Paper 45 at 13–14.
`
`Bradium Exhibit 2060, Page 25 of 47
`
`
`
`Reddy
`Unified Expert (Wilson) Deposition Testimony
`
`Q. What's the right term for what's shown
`in the middle panel of Figure 5, or what's
`shown in Figure 1(b) [of Reddy]?
`Are those scenes?
`A. I think “scene” would be a good term for
`that.
`Q. And each scene has a user‐selected
`viewpoint from which the scene is viewed.
`Right?
`A. Correct.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`26
`
`EX2044 at 15:4‐12; Paper 38 at 44, 47.
`
`Bradium Exhibit 2060, Page 26 of 47
`
`
`
`Reddy
`Distance‐Based Level of Detail (LOD) Scene
`
`Unified Expert (Wilson) Testimony:
`Q. So distance‐based LOD would have for a
`particular scene, we have the download of ten
`tiles: three yellow, three green, four blue. Right?
`
`A. Correct.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`27
`
`Paper 45 at 14; EX2044 at 96:16‐20; EX1004 at 3.
`
`Bradium Exhibit 2060, Page 27 of 47
`
`
`
`Reddy
`“Flying” Mode
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`28
`
`Bradium Exhibit 2060, Page 28 of 47
`
`
`
`Reddy
`“Flying” Mode
`
`• Based on only the current viewpoint;
`• A distance‐based LOD scene at each viewpoint.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`29
`
`Paper 38 at 52‐55 (diagram taken from EX1005, p.121);
`Paper 45 at 22.
`
`Bradium Exhibit 2060, Page 29 of 47
`
`
`
`Reddy
`“Flying” Mode
`
`• Based on only the current viewpoint;
`• A distance‐based LOD scene at each viewpoint.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`30
`
`Paper 38 at 52‐55 (diagram taken from EX1005, p.123);
`Paper 45 at 22.
`
`Bradium Exhibit 2060, Page 30 of 47
`
`
`
`Reddy
`Pre‐Fetching
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`31
`
`Bradium Exhibit 2060, Page 31 of 47
`
`
`
`Reddy
`Prefetching
`
`Board Discussion
`of Reddy
`Paragraph 46:
`
`“We agree with Patent Owner that
`paragraph 46 of Reddy discloses only
`prefetching tiles to be immediately available
`for rendering based on extrapolating a
`current flight path.”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`32
`
`Paper 38 at 1; Paper 45 at 22; EX2032 (IPR2016‐01897 Paper 17
`(Institution Decision)) at 20; Petition at 68; EX1005 at ¶205.
`
`Bradium Exhibit 2060, Page 32 of 47
`
`
`
`Reddy
`Locally‐stored
`Image Tile Set
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`33
`
`Bradium Exhibit 2060, Page 33 of 47
`
`
`
`Reddy
`Locally‐stored Image Tile Set
`
`Board Discussion
`of Reddy
`Paragraph 44:
`
`“…Reddy discloses only that if some high
`resolution tiles have not arrived, TerraVision
`uses the highest resolution data available to
`it, e.g., from a lower resolution terrain
`representation stored in memory.”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`34
`
`Paper 38 at 1, 51; EX2032 (IPR2016‐01897 Paper 17 (Institution Decision))
`at 20; Petition at 68; EX1005 at ¶205 (citing Reddy ¶¶21, 44).
`
`Bradium Exhibit 2060, Page 34 of 47
`
`
`
`Reddy
`QuadLOD
`“Coarse to Fine”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`35
`
`Bradium Exhibit 2060, Page 35 of 47
`
`
`
`Reddy
`QuadLOD
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`36
`
`Paper 38 at 50‐51; EX1004 at p.33 (¶21).
`
`Bradium Exhibit 2060, Page 36 of 47
`
`
`
`Reddy
`Asserted Additional
`“Coarse to fine”
`Algorithm
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`37
`
`Bradium Exhibit 2060, Page 37 of 47
`
`
`
`Reddy
`Asserted Additional “Coarse to Fine” Algorithm
`
`• Asserted algorithm is not disclosed by Reddy;
`• Not necessary or beneficial, given the
`distance‐based LOD scene of Reddy.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`38
`
`Paper 38 at 51‐52; Paper 45 at 22.
`
`Bradium Exhibit 2060, Page 38 of 47
`
`
`
`Rosasco
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`39
`
`Bradium Exhibit 2060, Page 39 of 47
`
`
`
`Rosasco
`
`• Operates on a single, current viewpoint;
`
`•
`
`Sorts modulation threads, not image
`download threads;
`
`• No benefit to combining Rosasco with
`Reddy.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`40
`
`Paper 38 at 58; Paper 45 at 23‐25.
`
`Bradium Exhibit 2060, Page 40 of 47
`
`
`
`Rosasco
`Sorts Modulation Threads
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`41
`
`Paper 38 at 57.
`
`Bradium Exhibit 2060, Page 41 of 47
`
`
`
`Rosasco
`Based on Single, Current Viewpoint
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`42
`
`Paper 38 at 58.
`
`Bradium Exhibit 2060, Page 42 of 47
`
`
`
`State of the Art
`Alternative “Progressive
`Display” Method
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`43
`
`Bradium Exhibit 2060, Page 43 of 47
`
`
`
`Hornbacker
`“Progressive Display”
`
`“Progressive display” method was a well‐known, method
`that was praised in the art. The method does not practice
`the invention of the ’239 Patent.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`44
`
`Paper 45 at 25‐26; EX1003,
`12:24‐27, EX1027, ¶75.
`
`Bradium Exhibit 2060, Page 44 of 47
`
`
`
`State of the Art
`Yap
`
`Yap praises the efficiency of the “progressive transmission”
`method, in which an initial low‐resolution image is
`provided, followed by “fill in” data for higher‐resolution
`data.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`45
`
`Paper 45 at 25‐26; EX1005.4 at 403 (Yap 4:48‐
`51); EX1005.1 at ¶50 (citing Yap).
`
`Bradium Exhibit 2060, Page 45 of 47
`
`
`
`State of the Art
`Antonini
`
`Progressive transmission via image compression using
`wavelet transform was well‐known and praised.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`46
`
`Paper 45 at 27; EX1005.4 at 368 (Antonini
`p.218); EX1005.1 at ¶46 (citing Antonini p.218).
`
`Bradium Exhibit 2060, Page 46 of 47
`
`
`
`State of the Art
`Hoppe
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`47
`
`Paper 45 at 27; EX1005.4 at 439 (Hoppe p.99);
`EX1005.1 at ¶62 (citing Hoppe).
`
`Bradium Exhibit 2060, Page 47 of 47
`
`
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