Petitioner’s Demonstratives
`
`September 17, 2019
`
`IPR2018-00952
`
`Unified Patents Inc.
`v.
`Bradium Technologies LLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Page 1 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`September 17, 2019
`
`IPR2018-00952
`
`Unified Patents Inc.
`v.
`Bradium Technologies LLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Page 1 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Summary
`
`Patent Overview
`
`Reddy, Hornbacker, and Rosasco Render Claim 20 Obvious
`
`The Board Should Not Terminate the Proceeding
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`2
`
`Page 2 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`U.S. 9,253,239
`Problem
`
`Transmitting full resolution
`images over the Internet on an
`“as-needed basis”
`• “complex images” such as
`“geographic, topographic,
`and other highly detailed
`maps”
`
`Improving transfer latency
`
`(Ex. 1001, 1:36-63)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Petition, 6; Ex. 1005, ¶85
`
`3
`
`Page 3 of 31
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`Unified Patents Exhibit 1031
`
`
`
`U.S. 9,253,239
`
`Proposed Solution
`
`Ex. 1001, 3:65-4:3
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 5-9; Ex. 1005, ¶¶88-89
`
`Ex. 1001, 7:54-63
`
`4
`
`Page 4 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Claim 20
`
`Element 1: issuing a first
`request . . . for a first update
`data parcel . . . selected based
`on a first user-controlled
`image viewpoint . . .
`
`Element 2: issuing a second
`request . . . for a second
`update data parcel . . .
`selected based on a second
`user-controlled image
`viewpoint . . .
`
`Element 3: a step for
`determining priority of the
`first request and the second
`request
`
`Provides no specifics
`regarding how prioritization
`must be conducted
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 5-7; Reply, 12-15; Ex. 1001, 12:29-13:3, 14:41-43
`
`5
`
`Page 5 of 31
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`Unified Patents Exhibit 1031
`
`
`
`Reddy Renders Claim 20 Obvious
`
`Reddy discloses a
`“progressive coarse-to-fine
`algorithm to load and display
`new data”
`
`Ex. 1004, ¶44
`
`Reddy prioritizes:
`1)
`lower resolution tiles
`(i.e., yellow tiles)
`2) medium resolution
`tiles (i.e., green tiles)
`3) high resolution tiles
`(i.e., blue tiles)
`
`Ex. 1004
`
`This operation of Reddy undisputed
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 9, 13-17; Reply, 18-20; Ex. 1005, ¶¶205-06, 234-42 Ex. 1027, ¶¶34-38
`
`6
`
`Page 6 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Summary
`
`Patent Overview
`
`Reddy, Hornbacker, and Rosasco Render Claim 20 Obvious
`
`The Board Should Not Terminate the Proceeding
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`7
`
`Page 7 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Disputed Issues
`
`Issue 1: Whether “a step for determining priority of the first
`request and the second request” requires the prioritization to
`be based on changes in the user viewpoint
`
`Issue 2: Whether the combination of Reddy, Hornbacker, and
`Rosasco renders obvious “a step for determining priority of the
`first request and the second request”
`
`Issue 3: Whether there is a motivation to combine Reddy and
`Rosasco
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`8
`
`Page 8 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`“Determining Priority” Limitation Interpretation
`
`“a step for determining priority of the first
`request and the second request”
`
`ID, 40
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Reply, 14-17
`
`9
`
`Page 9 of 31
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`Unified Patents Exhibit 1031
`
`
`
`Prioritization Described Within Each Viewpoint
`
`“a step for determining priority of the first
`request and the second request”
`
`Ex. 1001, 3:65-4:3
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Reply, 14-17
`
`10
`
`Page 10 of 31
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`Unified Patents Exhibit 1031
`
`
`
`Prioritization Described Within Each Viewpoint
`
`“a step for determining priority of the first
`request and the second request”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Reply, 14-17
`
`11
`
`Ex. 1001, 10:56-64
`
`Page 11 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Prioritization Also Described Based on Changes in Viewpoints
`
`“a step for determining priority of the first
`request and the second request”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Reply, 14-17
`
`12
`
`Ex. 1001, 7:54-63
`
`Page 12 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Bradium Acknowledges the Two Types of Prioritization
`
`Sur-Reply, 20
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`13
`
`Page 13 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`“Determining Priority” Limitation Interpretation
`
`Patent Owner wrongly rewrites Claim 20 without construction
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Reply, 14-17
`
`14
`
`POR, 61
`
`Page 14 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Improper to Import Limitations From Specification
`
`Superguide Corp. v. DirecTV Enterprises, Inc., 358 F. 3d 870, 875 (Fed. Cir. 2004):
`
`“Though understanding the claim language may be aided by explanations contained
`in the written description, it is important not to import into a claim limitation that
`are not part of the claim. For example, a particular embodiment appearing in the
`written description may not be read into a claim when the claim language is
`broader than the embodiment”
`
`Claim should be construed to include both embodiments
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Reply, 14-17; Sur-Reply, 20
`
`15
`
`Page 15 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Disputed Issues
`
`Issue 1: Whether the limitation “a step for determining priority
`of the first request and the second request” requires the
`prioritization to be based on changes in the user viewpoint
`
`Issue 2: Whether the combination of Reddy, Hornbacker, and
`Rosasco renders obvious “a step for determining priority of the
`first request and the second request”
`
`Issue 3: Whether there is a motivation to combine Reddy and
`Rosasco
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`16
`
`Page 16 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Reddy Discloses Low to High Resolution Priority
`
`Reddy discloses a
`“progressive coarse-to-fine
`algorithm to load and display
`new data”
`
`Ex. 1004, ¶44
`
`Reddy prioritizes:
`1)
`lower resolution tiles
`(i.e., yellow tiles)
`2) medium resolution
`tiles (i.e., green tiles)
`3) high resolution tiles
`(i.e., blue tiles)
`
`Ex. 1004
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 9, 13-17; Reply, 18-20; Ex. 1005, ¶¶205-06, 234-42 Ex. 1027, ¶¶34-38
`
`17
`
`Page 17 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Reddy Discloses Two User-Controlled Viewpoints
`
`Ex. 1004, FIG. 5
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex. 1004, ¶37
`Pet., 28-30, 41, ; Reply, 21-23; Ex. 1005, ¶¶174, 182, 191-93 Ex. 1027, ¶¶36-38
`
`18
`
`Page 18 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Reddy Discloses Prioritization for Each Viewpoint
`
`When the viewpoint changes,
`Reddy repeats the
`prioritization for the tiles
`associated with the new
`viewpoint
`
`For the second user-
`controlled viewpoint, Reddy
`prioritizes:
`1)
`lower resolution tiles
`(i.e., red tiles) first
`2) medium resolution
`tiles (i.e., green tiles)
`second
`3) high resolution tiles
`(i.e., blue tiles) third
`
`Ex. 1004
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 13-17, 33-41, 68-71; Reply, 18-20; Ex. 1005, ¶¶166, 191-93, 205-06, 234-42; Ex. 1027, ¶¶36-38
`
`19
`
`Page 19 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Reddy Discloses Prioritization Between Viewpoints
`
`• Reddy’s “prefetching” and “flyover” features prioritize
`requests between two viewpoints:
`
`• Reddy prioritizes image requests along the user-controlled
`flight path
`
`• Reddy prioritizes image requests from earlier viewpoints
`before the image requests from later viewpoints to create
`“flyover” effect
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 68-71; Reply, 17-18, 20-25; Ex. 1005, ¶¶205-06, 234-42; Ex. 1027, ¶¶25-26, 42-49
`
`20
`
`Page 20 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Reddy’s Viewpoints Are “User-Controlled”
`
`• Reddy’s “prefetching” and “flyover” features involve two
`“user-controlled image viewpoints” (i.e., two viewpoints
`controlled by the user, e.g., by user navigational controls)
`
`• Bradium’s definition, accepted by Unified, does not require
`direct selection of the viewpoint by the user (e.g., input of
`specific coordinates)
`
`• Rather, Bradium’s definition of “user-controlled” allows the
`user to use navigational controls to control the viewpoint
`• For example, setting a flight path using a mouse to control
`direction and speed
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 68-71; Reply, 17-18, 20-25; Ex. 1005, ¶¶205-06, 234-42; Ex. 1027, ¶¶25-26, 42-49; POR, 40
`
`21
`
`Page 21 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Disputed Issues
`
`Issue 1: Whether the limitation “a step for determining priority
`of the first request and the second request” requires the
`prioritization to be be based on changes in the user viewpoint
`
`Issue 2: Whether the combination of Reddy, Hornbacker, and
`Rosasco renders obvious “a step for determining priority of the
`first request and the second request”
`
`Issue 3: Whether there is a motivation to combine Reddy and
`Rosasco
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`22
`
`Page 22 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Rosasco Discloses Prioritization
`
`Rosasco discloses:
`
`1) a user inputs a texture modulation request
`
`2)
`
`3)
`
`the system determines which image sets are needed to
`fulfill request
`
`image sets are prioritized based on the viewpoints of the
`user
`Ø “[s]ets more closely parallel with the line sight are
`given priority in the sorting” to provide “helpful and
`informative display[s]” to the user
`
`Ex. 1018, 3:27-30; 9:24-27
`
`4)
`
`image sets are obtained based on prioritization
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 67-71; Reply, 19-20, 24-25; Ex. 1005, ¶¶234-42; Ex. 1027, ¶¶38-40, 48
`
`23
`
`Page 23 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Reddy and Rosasco Are Analogous Art
`
`• Reddy and Rosasco address common technical issues of
`visualizing volumetric data using higher- and lower-end
`hardware
`
`• Reddy and Rosasco are both applicable to mapping related
`applications
`
`• The problems described by Reddy related to limited
`computing resources are addressed by Rosasco’s
`prioritization being relevant on clients with limited means
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 67-71; Reply, 19-20, 24-25; Ex. 1005, ¶¶234-42; Ex. 1027, ¶¶38-40, 48
`
`24
`
`Page 24 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Reddy and Rosasco Are Analogous Art
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`ID, 39-40
`
`25
`
`Page 25 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`A POSA Would Have Applied Rosasco’s Teachings to Reddy
`
`• A POSA would have applied Rosasco’s teachings to Reddy by
`having Reddy’s system obtain the tiles in the order that
`would be most “helpful and informative" to the user.
`
`• Reddy discloses obtaining tiles from multiple viewpoints.
`
`• Reddy provides examples of which tiles could be prioritized:
`those that are nearer and those that are of lower resolution.
`
`• Applying Rosasco’s teachings to Reddy would result in Reddy
`prioritizing tile requests (e.g., based on nearness or
`resolution) and issuing the requests according to the
`assigned priorities.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 67-71; Reply, 19-20, 24-25; Ex. 1005, ¶¶234-42; Ex. 1027, ¶¶38-40, 48
`
`26
`
`Page 26 of 31
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`Unified Patents Exhibit 1031
`
`
`
`Reddy and Rosasco Do Not Teach Away From Each Other
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`ID, 39-40
`
`27
`
`Page 27 of 31
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`Unified Patents Exhibit 1031
`
`
`
`Appendix – Claim 1
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`28
`
`Page 28 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Appendix – Claim 20
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`29
`
`Page 29 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Reddy’s “Prefetching”-Two User-Controlled Viewpoints
`
`Ex. 1004, ¶46
`
`• Extrapolation based on “current flight path” NOT
`“current viewpoint.”
`
`• The user controls the “current flight path.”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 68-71; Reply, 20-25; Ex. 1005, ¶¶205-06, 234-42; Ex. 1027, ¶¶25-26, 42-49
`
`30
`
`Page 30 of 31
`
`Unified Patents Exhibit 1031
`
`
`
`Reddy’s “Flyover”-Two User-Controlled Viewpoints
`
`Ex. 1004, ¶3
`
`Prioritizes earlier user-controlled viewpoints over later user-
`controlled viewpoints along the flight path
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Pet., 68-71; Reply, 20-25; Ex. 1005, ¶¶205-06, 234-42; Ex. 1027, ¶¶25-26, 42-49
`
`31
`
`Page 31 of 31
`
`Unified Patents Exhibit 1031
`
`
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