UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner,
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`v.
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`QUALCOMM INCORPORATED,
`Patent Owner.
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`IPR2018-01252
`Patent 8,683,362 B2
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`Record of Oral Hearing
`Held: November 21, 2019
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`Before DANIEL N. FISHMAN, MICHELLE N. WORMMEESTER, and
`SCOTT B. HOWARD, Administrative Patent Judges.
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner,
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`v.
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`QUALCOMM INCORPORATED,
`Patent Owner.
`____________
`
`IPR2018-01252
`Patent 8,683,362 B2
`____________
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`Record of Oral Hearing
`Held: November 21, 2019
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`Before DANIEL N. FISHMAN, MICHELLE N. WORMMEESTER, and
`SCOTT B. HOWARD, Administrative Patent Judges.
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`IPR2018-01252
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`APPEARANCES:
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`ON BEHALF OF THE PETITIONER:
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`W. KARL RENNER, ESQUIRE
`TOM ROZYLOWICZ, ESQUIRE
`CRAIG CARLSON, ESQUIRE
`Fish & Richardson, P.C.
`1000 Maine Avenue SW, Suite 1000
`Washington, D.C. 20024
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`ON BEHALF OF THE PATENT OWNER:
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`CHAD C. WALTERS, ESQUIRE
`CHARLES Y. YEH, ESQUIRE
`Baker Botts, LLP
`2001 Ross Avenue
`Dallas, Texas 75201
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`The above-entitled matter came on for hearing on Thursday, November
`21, 2019, commencing at 9:00 a.m., at the U.S. Patent and Trademark
`Office, 600 Dulany Street, Alexandria, Virginia.
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`USHER: All Rise.
`JUDGE WORMMEESTER: Good morning Counsel. Welcome
`back, we have our final hearing in Case IPR 2018-01252, Apple Inc. v.
`Qualcomm Incorporated, which concerns U.S. Patent Number 8,683,362.
`I’m Judge Wormmeester. Judges Howard and Fishman are appearing
`remotely. Let's get the parties’ appearances, please. Who do we have for
`Petitioner?
`MR. ROZYLOWICZ: Yes, Your Honor. My name is Tom
`Rozylowicz on behalf of Apple Incorporated. I’m joined by my colleagues,
`Karl Renner and Craig Carlson.
`JUDGE WORMMEESTER: Thank you, welcome. And for Patent
`Owner, who do we have?
`MR. WALTERS: For Patent Owner, I’m Chad Walters on behalf of
`Qualcomm. With me is my colleague Charles Yeh, and we also have some
`representatives of our client, Qualcomm, here in the hearing room with us.
`Thank you.
`JUDGE WORMMEESTER: Thank you, welcome. We set forth the
`procedure for today’s hearing in our trial order but, just a reminder, each
`party will have 60 minutes to present arguments including any rebuttal and
`any sur-rebuttal.
`Petitioner has the burden and will go first. Patent Owner will then
`respond. Please speak into the microphone so that Judges Howard and
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`Fishman can hear you. And, when referring to any demonstrative, please
`state the slide number so that they can follow along.
`Please also remember that the demonstratives you submitted are not
`part of the record. The record of the hearing will be the transcript. Are there
`any questions before we proceed?
`Okay. Counsel, will you be reserving any time?
`MR. ROZYLOWICZ: Yes, Your Honor. I'd like to reserve 30
`minutes for rebuttal.
`JUDGE WORMMEESTER: 30 minutes, okay. I don't know what
`time; I think the light shows up at about 30 seconds.
`MR. ROZYLOWICZ: Okay.
`JUDGE WORMMEESTER: So, you get a 30 second warning. I’ll
`try to give you a warning before that if you want.
`MR. ROZYLOWICZ: Yes, Your Honor.
`JUDGE WORMMEESTER: When you're ready.
`MR. ROZYLOWICZ: Good morning, Your Honors, may it please
`the Court. This morning we believe that we have a complete written record
`in front of us demonstrating why the challenged 362 claims are indeed
`unpatentable.
`Turn to Slide 2. We will discuss (inaudible) to the grounds of the
`existing claims of the 362 Patent, provide a brief overview of the 362 Patent,
`indeliment (phonetic) of the merits of Ground 1, that the claims are
`unpatentable over the combination of Jin in view of Elias. Next slide.
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`Turning to Slide 4, we plan first to speak to the overview of the
`combination of Jin and Elias. Then, we plan to speak to Jin and Elias in the
`combination demonstrating dragging the window.
`Second, we plan to speak to dismissing a window being obvious based
`on the Jin and Elias combination.
`Finally, and time permitting, we plan to speak to secondary
`considerations that they do not overcome a finding of obviousness in this
`case. Next slide.
`Turning to Slide 6, here we see a bibliographic overview of the 362
`Patent; next slide.
`And for convenience, here we see a copy of Claim 1. This morning
`we will be focusing on the highlighted limitations. Go to Slide 10, please.
`Now first, we provided overview of the Jin Reference. Turning to
`Slide 10 we see that Jin provides displaying windows simultaneously, as
`show on the figure on the left-hand side. In particular, with these different
`windows, we see that they are opaque, transparent, folding fanned, and tiled
`settings.
`Turning to the highlighted white top portion, we see that Jin’s mobile
`device provides a screen display method for mobile terminal where a
`plurality of applications, in execution, can be simultaneously displayed on
`the screen.
`Turning to the highlighted bottom portion, we see that the applications
`and executions displayed in the application display method, can include a
`phone book, a notepad, calculator, scheduler, and remote control.
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`Together, we see that the tiles that are shown in the figure could
`include any of those applications or more. And thus, we believe that Jin
`discloses displaying multiple windows corresponding to the multiple
`applications in execution.
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`Turning to Slide 11, here we note that Jin executes a single window
`movement request. Turning to the highlighted upper right-hand portion, Jin
`(inaudible) to user can touch acard to be moved or rotating a wheel to move
`the card.
`Turning to the highlighted bottom right-hand portion, we see that in
`response to input of a single window movement request, the control unit 107
`performs a window movement operation, S209.
`The control unit 107 rearranges the content windows, so that the front
`content window becomes the last window, and the second content window
`becomes a new front window, as illustrated in Figure 8E.
`Thus, Figure 8E on the left-hand portion of the slide, demonstrates the
`movement of window AAA to the back, and window BBB to the front, in
`response to a single window movement request.
`Turning to Slide 12, here we note that Jin executes a multiple window
`movement request. Turning to the highlighted bottom left portion, we see
`that as illustrated in Figure 9C, if the display unit 109 has a touchscreen
`capability, the control unit 107 can recognize the dragging from the front
`window to the back window on the display 109 as a multiple window
`movement request.
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`Turning to the bottom highlighted right-hand portion, we see that in
`response, visible windows (either application or content windows) become
`invisible and non-visible windows become visible on the display unit 109; as
`is illustrated in Figure 9E. Thus, Jin enables users to perform dragging on
`windows, and in response, general rearrange the windows based on the
`dragging. Turn to Slide 14, please.
`Now, turning to Slide 14, we see that Jin discloses a single display
`request. We want to draw your attention to the highlighted bottom left-hand
`portion of the corner in which Jin discloses that that is the control unit 107
`recognizes selection of the artist AAA and displays a descriptive listing of
`the selected artist AAA on the display unit 109.
`As a result, and speaking to Figure 6D and 4, when a user selects one
`of the windows appearing in Figure 6D, they interact with the window in
`order to invoke the single window display afterwards, as a result as shown in
`Figure 4.
`Thus, we note the user interacts with the window, not the display, in
`order to achieve the functionality and to invoke the particular window. Turn
`to Slide 32, please.
`Now, turning to Slide 32, we would first call your attention to Figure
`11 on the left. In Step S919, we see a box labeled, Perform Requested
`Function. This function corresponds to other requests that can be
`accommodated.
`Jin itself has a limited gesture dictionary. But this flowchart in Figure
`11 invites us to include other gestures.
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`Now we will turn to Elias which speaks to a dictionary of gestures.
`Slide 15, please.
`Turning to Slide 15, we now consider the gesture dictionary in Elias
`that can be referenced by Jin in Step S919. Turning to the highlighted
`bottom left-hand portion, Elias offers a dictionary of multiple touch gestures
`that is interactively presented to a user of a computer system having a multi-
`touch user interface.
`Turning to the top portion of the slide, we see an exemplary user
`gesture dictionary for GUI related commands and associated gestures. And,
`turning to the bottom right-hand portion of the slide, we see some examples
`of these gestures.
`For example, there is “next application”, associated with the rightward
`motion 506; “previous application” associated with leftward motion 504;
`“exit”, i.e. close application, associated with clockwise rotation 511.
`Thus, Elias’ gesture dictionary offers a variety of gestures that may be
`performed by a user and interacting with the computer system. Slide 17,
`please.
`Turning to Slide 17 and calling your attention to the highlighted upper
`left-hand portion, we see that Elias’ gesture dictionary can be included as a
`dictionary application that can run in the background while other
`applications on the computer system are used.
`Elias tells you not to integrate it piecemeal, but instead to bring in the
`dictionary application itself.
`Turning to the highlighted bottom left-hand portion, we see that a
`POSITA would look to Elias’ teaching to modify and thus complement this
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`technology by allowing Jin to accept gestures for other requests using Elias’
`gesture dictionary. Slide 16, please.
`Turning to Slide 16, we see that Elias’ gesture dictionary further
`enables assigning and changing of functions and gestures.
`Turning to the highlighted left-hand portion, Elias’ gesture dictionary
`can -- I quote -- “assign meaning to a gesture in a variety of ways.”
`We see that Elias is not limited to the five pages of gestures shown in
`Figures 1 through 5. Instead, we see that Elias is flexible to accommodate a
`universe of options.
`In particular, if we turn to Figure 7 appearing in the upper left-hand
`portion, we see various gestures that can, in fact, be defined, and indeed
`labeled, as shown in the text entry box appearing in the lower left-hand
`portion of Figure 7.
`These gestures allow users to assign meaning to unassigned gestures,
`such as that shown in Figure 7. The gestures which have been defined, can
`be assigned to macros that are shown on the right-hand side. This is shown
`in Elias at paragraph 52, which is relied upon in our Petition, on page 13.
`Turning to the highlighted bottom right-hand portion, we see that
`Elias describes an exemplary dictionary that enables users to perform
`dragging, typically accomplished in a conventional graphical user interface
`system, by holding a mouse button while moving the mouse. Slide 18,
`please.
`We then proceed to Issue 1, and speak to how Jin and Elias
`demonstrate dragging a window. Slide 19.
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`Turning to Slide 19, Jin discloses window movements based on finger
`movements corresponding to the same. For example, I’m looking at the left-
`hand column that describes tapping, Jin discloses, “touching a window to be
`moved, for example, the front window, is a single window movement
`request.”
`Again, Jin discloses that users can drag from the front window to the
`last window on the display unit 109, as a multiple window movement
`request.
`Turning to the right-hand portion, in a response to the drag, Figure 9E,
`shown in the next slide, illustrates the first card AAA that has changed
`position relative to display along the first direction. Slide 20, please.
`Turning to Slide 20, we see that Figure 9A indicates the initial
`position and orientation of the windows. In the middle figure, appearing in
`Figure 9C, we see that the user has a finger starting in the lower right-hand
`portion, and they move it diagonally upwards to the left, in order to achieve
`a rotation. As a result of this movement, Figure 9E illustrates the final
`position of the windows.
`Jin’s control unit rearranges the content windows so that the back
`windows become visible. Thus, we know AAA has moved in response to
`the drag from the initial position to the position illustrated by the finger drag.
`JUDGE HOWARD: Does Jin say when rearrangement takes place?
`Is it during the movement of the fingers, or is it after the movement of the
`fingers?
`MR. ROZYLOWICZ: Your Honor, I believe it says, “as a result of
`the movement.”
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`JUDGE HOWARD: Thank you.
`MR. ROZYLOWICZ: Turning to Slide 22, Jin discloses that content
`windows are rearranged, or moved in response to a user performing window
`movement operations, such as a drag or a touch.
`In particular, and turning to the upper left-hand portion, we see that
`display unit 109 moves content windows to display the rearranged content
`windows.
`Turning to the upper right-hand portion, we see that the control unit
`107 rearranges content windows so that the content windows in display
`become invisible, and content windows not in display become visible on the
`display unit 109.
`Finally, and turning to the lower highlighted portion, we see that the
`control unit 107 can recognize dragging from the front window to the last
`window on the display unit 109, as a multiple window movement request.
`Thus, and as discussed with Figures 9A, 9C, and 9E, Jin clearly
`illustrates the dragging of a window with the initial position, movement of
`the drag, and finally, position of the windows. This is consistent further
`with Jin’s Claims 23, and 24, which were originally filed and recite shifting
`windows forwards and backwards.
`JUDGE HOWARD: Do you contend that this section that you cited
`from Column 7, describes dragging the window along with the finger
`movement, or again, is this after the finger movement is done.
`MR. ROZYLOWICZ: Your Honor, I think it’s as a result of the
`finger movement being done.
`JUDGE HOWARD: Okay, thank you.
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`MR. ROZYLOWICZ: Turning to Slide 23, we see that the record
`reveals what drag means, as set forth in Jin, and supported by Elias.
`Turning to the upper left-hand portion, we see that Dr. Sears confirms
`during deposition that a dragging operation is one in which you click on an
`object, and touch an object, and you then move the mouse curser of the
`finger to drag that object on the screen. Thus, Dr. Sears provides a
`definition of dragging, which came up during his deposition.
`Turning to the upper right-hand portion, we see that Elias similarly
`defines the term “dragging.” In particular, Figure 3 illustrates that dragging
`is one common gesture.
`Given that Elias’ gesture dictionary is storing a variety of meanings
`and commands, a POSITA would have understood the meaning of drag
`within the context of the Jin and Elias combination.
`Now, turning to the lower left-hand portion, we see how Figure 3 was
`actually relied upon in the record. We see definitionally that Elias discloses
`-- and I am quoting from the highlighted portion -- “the dictionary entry 300
`enables enabling users to perform dragging, typically accomplished in a
`conventional graphical user interface system by holding a mouse while
`moving the mouse.”
`Again, Petitioner’s Reply at pages 8 and 9 featured at the above
`Exhibits when used to explain what is meant by “dragging.” And
`additionally, Figure 3 clearly shows a command corresponding to a gesture
`for performing a drag.
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`Turning to Slide 25, in the last sentence of the left-hand portion, we
`see that a POSITA would understand that windows move in the direction of
`the dragging, and along the dragging axis.
`Turning to the highlighted portion in the upper right-hand column, we
`see that the stack of the cards shown in Figure 9E remains in the same order
`as Figure 9A but rearranged accordingly in the direction of the drag.
`Turning to the lower right-hand column, we see that as a user drags
`the front window towards the back, the rear window -- GGG and HHH, that
`are displayed as a dashed line in a box in Figure 9A -- to denote windows
`that are not displayed on the display unit 109, rotate towards the front of the
`display unit 109, as illustrated in Figure 9E.
`We believe that all of these indicated portions speak to a directional
`component in a window movement.
`Turning to Slide 26, we call your attention to Figure 9A on the left,
`illustrating the initial position of the windows, in which window AAA is not
`displayed. Turning to Figure 9C, Jin illustrates the movement of the drag.
`Finally, again turning to the right figure, Figure 9E, Jin shows the
`resulted windows, where the behind content, such as window HHH, now
`become visible in the manner that reflects the direction of the movement.
`Your Honors, on Slide 31, we are now turning to Issue 2, dismissing a
`window being obvious based on the combination of Jin and Elias.
`Now in Slide 32, we briefly touched upon Figure 11 appearing on the
`left-hand side. Seeing how this integrates with Elias, in the upper right-hand
`portion, Petitioner notes that Elias provides an exit gesture highlighted in
`yellow.
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`Now turning to the highlighted portion of the Petition in the lower
`right-hand portion, we note that moving the card to the second direction,
`illustrated in the clockwise direction 511 exits, i.e. closes the application
`corresponding to the first card. Turning to Slide 33 --
`JUDGE HOWARD: Just so I’m clear, are you relying on Jin, or
`Elias, or is it a combination of the two of them, for showing movement of a
`card in a given direction?
`MR. ROZYLOWICZ: Your Honor, I submit that in the first instance
`that Jin gets you the movement, but further, we are, in fact, relying on the
`combination.
`JUDGE HOWARD: And where is that in the Petition where you're
`relying on the combination to show movement? And I’m not necessarily
`talking about in the second direction, I’m just -- in any direction.
`MR. ROZYLOWICZ: Sure. Your Honor, I think what's clear is that
`the user interfaces with a card itself, I think, as we described -- was it Slide
`15. And then, as a result of the user interacting with the window -- not the
`display, but the window -- thus any operations that are performed, are
`performed with respect to that window.
`And that’s as a result of the drag, with which the window has selected
`in the upper left-hand direction, there is movement responsive to the user
`dragging their finger associated with that window.
`JUDGE HOWARD: I’m not sure that answered by question.
`Because I’m trying to -- looking at your Reply --
`MR. ROZYLOWICZ: Mm-hmm --
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`JUDGE HOWARD: And starting on Page 16, where you're
`responding that Qualcomm is arguing that Elias doesn’t teach performing
`the exit gesture causes the window to move in the clockwise direction. And
`then you respond, and you say, “However, Dr. Sears does not rely on Elias
`for this feature but relies on Jin.”
`But then elsewhere, you seem to be relying on -- at least in the Reply -
`- on Elias for the movement in -- I guess I’m looking at the -- I want to
`focus mostly on the Petition, though, is it in the Petition where you're relying
`on Jin to show movement, or the combination. And, if it’s the combination,
`if you could direct me to where?
`MR. ROZYLOWICZ: Yes, Your Honor. I’ll speak to a few things.
`First, I think I think -- is it Pages 10 and 11 of the Petition, we actually speak
`that it’s the gesture dictionary itself that is brought in as an application in the
`background. And in association with that, while it’s true, we certainly relied
`a great deal on Jin for this point, we also note that Elias itself also teaches
`aspects of movement.
`For example -- and I’ll have the quote momentarily -- but I note that
`in describing how the gesture dictionary application operates, it notes that
`the windows -- and, forgive me, I don’t quite have the citation right now, but
`I’ll have it momentarily -- does, in fact speak to the fact that the gesture
`dictionary application in defining a gesture, you can also provide visible or
`audible feedback as a result of executing a gesture.
`JUDGE HOWARD: Okay, and if you can point that out to me where
`in the Petition that is, I'd appreciate that.
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`MR. ROZYLOWICZ: Yes, Your Honor. So, Your Honor, for
`example, I call your attention to middle of Petition, Page 39.
`JUDGE HOWARD: Okay.
`MR. ROZYLOWICZ: In establishing our basis for relying on the
`combination, we say that “Jin in view of Elias, provides responding to a
`directional contact of moving the first card along a second direction (such as,
`clockwise direction illustrated in 511 . . . ) that is different from the first
`direction.”
`We then note, “[a]dditionally, moving the card in the second direction
`(illustrated in clockwise direction 511) exits, i.e., closes the application
`corresponding to the first card.”
`So, we then conclude, a POSITA would have found the clockwise
`direction as a matter for implementing a second direction, considering Elias
`allows users to assign the meaning to one or more gestures.
`JUDGE HOWARD: But are you relying on -- I understood you're
`argument from reading is, Jin teaches that you can make a motion dragging a
`card and the card then goes in that direction, and that you're using Elias for,
`we’re going to do the specific clockwise rotation, and that’s going to lead to
`exiting, but that you weren’t using Elias that teaches -- you actually moved
`the card in the counterclockwise direction.
`MR. ROZYLOWICZ: Mm-hmm.
`JUDGE HOWARD: Am I not understanding the Petition, and if not,
`where is it in the Petition where you point to portions of Elias to teach the
`movement?
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`MR. ROZYLOWICZ: Your Honor, I think there's a few different
`aspects. First, again, we indicate we are bringing the whole gesture
`dictionary application, and not just Figure 5 piecemeal, right? I mean, if
`Elias tells you that you should bring in the application to run in the
`background, unless you bring in all that Elias teaches, including, for
`example, the drag operation that appears in Figure 3.
`JUDGE HOWARD: All right, well I’m looking at Page 38 and 39 in
`your Petition, and you're relying on Figure 5, so that’s what I’m focusing in
`on, but is there anywhere -- I guess -- anywhere in the Petition that you cited
`something where Elias says that while there's a finger movement going, the
`card is going to be moving in that direction in the application window,
`whatever Elias uses.
`MR. ROZYLOWICZ: Your Honor, I'd like to revisit that point. Off
`the top of my head I’m just not familiar with that part of the record that
`might be more responsive to your question then what I've already said.
`JUDGE HOWARD: Okay, thank you.
`MR. ROZYLOWICZ: Turning now to Slide 33, we see that
`Qualcomm alleges that the Jin and Elias combination does not move a card
`along in a second direction. We respectfully disagree with this argument for
`two reasons.
`First, Jin in view of Elias discloses moving a card or window along in
`a first direction, as shown here in figures 9A, 9C, and 9E, touching a
`window to move a card in the same direction. This is one form of
`functionality of movement.
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`Second, Jin offers other functionalities to be performed that can be
`executed by the control unit, such as recognizing a swipe in a second
`direction to dismiss and close the card.
`Jin describes moving the card and illustrates a visual movement, and
`Elias discloses closing an application corresponding to the card.
`Turning to Slide 35, here we see how it comes --
`JUDGE FISHMAN: Can I ask a question? This is Judge Fishman.
`MR. ROZYLOWICZ: Yes, Your Honor.
`JUDGE FISHMAN: Does Jin show movement in two directions
`regardless of what the function is? Does Jin show the possibility of moving
`in either of two directions?
`MR. ROZYLOWICZ: No, Your Honor. My understanding is that Jin
`itself provides three particular gestures.
`It provides scrolling -- at least insofar as you're using the touch
`display interface -- it describes scrolling -- which I don’t think we spent very
`much time on -- it describes the single movement, and it describes the
`multiple window movement request. But again, Jin, in Figure 11 Step S919,
`invites other functions to be performed.
`So, Your Honor, I agree with you that we relied upon Jin and its
`movement in that one direction as the foundation for this.
`JUDGE FISHMAN: Okay.
`MR. ROZYLOWICZ: So, turning to Slide 35, and seeing how we
`believe this combination comes together, we have the claim limitation at
`issue appearing in the lower right-hand portion.
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`First, turning to the top middle box, we see the box entitled “tapping
`in a particular card,” we said a particular window is selected. Again, it’s the
`user that interfaces with the window, not just the display.
`Second, and turning to the upper right-hand box; the box entitled,
`“dragging cards,” we see how a particular selected window can be dragged.
`Finally, and turning to Elias Figure 5 appearing in the bottom central
`portion of the slide, a user can dismiss a selected window from the display
`by performing a clockwise gesture 511.
`JUDGE HOWARD: Okay, and maybe this answers the question that
`I asked before, but in -- on Slide 35 you recite Limitation 1(j), and you have
`different colors on different sections.
`For example, you have the first part which begins, “a response to the
`directional contact of moving the first card, or the second card, along a
`second direction that is different from the first direction on the touch
`sensitive display screen by 1.” And with that, you point to two different
`portions of the Petition, with reference to Exhibit 1005.
`You then have a yellow section identifying one of the first card, or
`second card as being selected based on a directional contact along the
`second direction. And that gets directed to portions that are referring to
`Exhibit 1006, and certain pages, also of the Petition, that refer to Exhibit
`1005 and 1006.
`And then for the remainder of the claim you have it pointing towards
`Exhibit 1006. Is that showing how you're using the combination of Jin and
`Elias to teach the various portions of the claim limitation?
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`MR. ROZYLOWICZ: Yes, Your Honor, with the understanding that
`Elias’ is predicated upon the gestures that it, in fact -- and the movement
`that, among other things, exists in Jin to move the multiple window display.
`JUDGE HOWARD: Okay. Thank you, that answers the question I
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`had.
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`MR. ROZYLOWICZ: Thank you, Your Honor.
`JUDGE WORMMEESTER: Counsel, you have about four minutes
`left before you go into rebuttal.
`MR. ROZYLOWICZ: Thank you, Your Honor. So, with this I will
`ask my colleague, Mr. Renner, to maybe speak to the motivation to combine,
`and perhaps the secondary considerations.
`MR. RENNER: Good morning, Your Honors. Karl Renner for
`Apple. I expect to be brief on this. If we could turn to Slide 39, please.
`As mentioned in the (inaudible) our direct, I’ll be speaking to
`motivation to combine Jin and Elias, as well as the perceived problems with
`the Patent Owner’s attempt to establish secondary considerations.
`In the slide in the upper left we see Jin’s primary objective to enable
`an easy transition between windows.
`We see in the upper right the integration of Elias’ gesture function
`dictionary improves Jin in several ways. Some of those are indicated here,
`others in the slides to follow we’ll hit.
`The first one here, if we look at this text -- it’s pretty small there -- it’s
`to improve upon Jin’s primary motivation of “enabling easy transitions
`between content windows to provide additional gestures.” Primarily, it
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`allows for various things like dismissing a selecting window to close and
`access another window.
`In there, you’ve got two different things. One, is the provision of
`additional gestures. The second is a hint there, the control of window
`population, as we see discussed also in Slides 41 and 40.
`Let's go to Slide 40, if we could though first. And finally, you'll see
`us mention freeing memory, but let's talk about Slide 40 here for a moment.
`We've got various clips here from the Petition that are provided on
`this slide to reinforce the motivations that we saw discussed with respect to
`the last slide, such as that window population, where you can see that
`discussed in the lower right, “A POSITA would understand,” in the
`highlighted section of the lower right.
`It says “A POSITA would understand that by closing windows no
`longer in use, users would better understand what applications are running
`and find it easier to navigate between them.” It’s quite obvious that that’s a
`goal that people might want to pursue.
`Additionally, in the lower left, there's a clip from the Petition that
`shows Dr. Sears, his comments regarding the combination of Jin and Elias
`where he says -- and again, I’ll quote -- “A POSITA would look to Elias’
`teaching to modify, and thus (phonetic) compliment Jin’s technology by
`allowing Jin to accept gestures for other requests using Elias’ gesture
`dictionary application.”
`As my colleague had pointed out, the point of the combination was
`indeed just that. That it was to pull the gesture dictionary broadly defined by
`Elias into Jin, by virtue of Jin’s call for additional functionality.
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`Jin sets forth three examples of things that it contemplates being done
`based on activity by the user. Those are in the flowchart of Figure 11, but at
`the end if that flowchart, as Mr. Rozylowicz pointed out, there is the call for
`other requests. And thereafter, of course, the corresponding functionalities
`that would provide.
`Looking to see what that would be, the Jin Reference is actually quite
`quiet (phonetic). It’s just opening this up much like an API. Elias then
`brings a d
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