`IPR2018‐01276
`
`U.S. Patent No. 8,971,861
`November 14, 2019
`
`1
`
`
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`’861 Patent | Technology Overview
`
`’861 Patent
`
`2
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`’861 Patent | Technology Overview
`
`’861 Patent at 6:35‐42; POR at 3
`
`3
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`’861 Patent | Technology Overview
`
`1) Particular architectural arrangement (host computer, mobile device)
`2) Use of physiological data and environmental data to select predefined content
`
`’861 Patent at 7:56‐61; POR at 4‐5
`
`’861 Patent at 9:48‐51; POR at 5
`
`’861 Patent at Fig 1; POR at 4
`
`4
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`
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`’861 Patent | Technology Overview
`
`’861 Patent Claim 1
`
`’861 Patent at Figs. 4, 5, 6; see POR at 6‐13, 19‐23 for description of algorithms
`
`5
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`
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`’861 Patent | Technology Overview
`
`’861 Patent at Fig. 3A (discussed in id. at 17:12‐26); POR at 20
`
`’861 Patent at 15:40‐52; POR at 20
`
`6
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`
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`’861 Patent | Technology Overview
`
`’861 Patent Claim 1
`
`7
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`
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`Means‐Plus‐Function | Failure to Map
`Multiple elements for which Petitioner identifies only a “computer”
`as corresponding structure also must include an algorithm
`Claim 26: Means for analyzing the physiological state data collected from the user of the mobile device
`Claim 26: Means for selecting content from a plurality of predefined content to deliver to the mobile device at
`least partially based on the physiological state data collected from the user.
`Claim 31: Means for monitoring …, means for aborting presentation of the selected content …
`Claim 32: Means for determining a similarity …, means for determining a price for presenting the content ….
`
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`Petitioner’s alternative argument that the corresponding structure is a generic microprocessor
`is also insufficient. Except for a narrow exception, the disclosure of a general purpose
`microprocessor as corresponding structure for a computer-implemented means-plus-function
`element is not sufficient―a corresponding algorithm must be disclosed.
`Carefusion Corp. v. Baxter Int’l, Inc., Case IPR2016‐01456, Paper 9 at 9 (P.T.A.B. Feb. 6, 2017); POR at 18
`
`POR at 16‐23; Villasenor Dec (Ex. 2003) at ¶ 42‐67; Sur‐Reply at 3
`8
`
`
`
`Both the Petition and Reply (which is untimely) fail to identify
`corresponding algorithms in the prior art
`Petition
`Hoffman
`
`Hjelt
`
`Reply
`Hoffman
`
`Hjelt
`Untimely
`Untimely
`
`Means‐Plus‐Function | Failure to Map
`
`Means‐Plus‐Function Element
`
`Claim 26: Means for analyzing physiological state data . . .
`
`Claim 26: Means for selecting content . . .
`
`Claim 31: Means for monitoring . . .
`
`Claim 31: Means for aborting presentation . . .
`
`Claim 32: Means for determining a similarity . . .
`
`Claim 32: Means for determining a price . . .
`
`N/A
`
`N/A
`
`N/A
`
`N/A
`
`POR at 16‐23, 42‐44; Sur‐Reply at 3‐6
`9
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`
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`Means‐Plus‐Function | Failure to Map
`
`•
`
`The Reply cannot cure:
`– Petitioner’s failure to identify sufficient corresponding algorithmic structure
`(Inst Dec at 14). See Syrinix, Inc. v. Blacoh Fluid Control, Inc., No. IPR2018‐
`00414, slip op. at 43 (P.T.A.B. May 22, 2019) (Paper 33)
`– Petitioner’s failure to provide structural comparison of the prior art to the
`applicable algorithms
`
`It is of the utmost importance that petitioners in the IPR proceedings adhere to
`the requirement that the initial petition identify “with particularity” the “evidence
`that supports the grounds for the challenge to each claim.” 35 U.S.C. § 312(a)(3).
`
`Intelligent Bio‐Systems, Inc. v. Illumina Cambridge Ltd., 821 F.3d 1359, 1369 (Fed. Cir. 2016)
`
`Sur‐Reply at 3‐4
`10
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`
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`Means‐Plus‐Function | Failure to Map
`
`The Reply cites new evidence for the Means‐Plus‐Function elements of Claim 26
`
`Not cited on page 60 of Pet.
`(discussion of Claim 26)
`
`Page relates to elements 1[a] and
`1[b]—not the “selecting” step or
`any element of Claim 26
`
`Reply at 10
`
`Sur‐Reply at 5
`11
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`
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`Means‐Plus‐Function | Failure to Map
`
`Undisputed
`Function
`
`The Reply still does not explain the untimely citations to Hjelt
`selecting content from a plurality of predefined content
`to deliver to the mobile device at least partially based
`on the physiological state data collected from the user
`PO’s disclosed algorithm
`
`Reply at 10
`
`’861 Patent at 15:40‐52; POR at 20
`Sur‐Reply at 5‐6
`12
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`
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`Hoffman | Fails to render any challenged claim unpatentable
`
`• Mapping of Hoffman fails for multiple reasons
`– Failure to disclose transmitting selected content to the mobile device
`• Hoffman describes the purported “selected content” as
`transmitted elsewhere, not to the mobile device
`• Hoffman is silent as to what type of information is transmitted to
`the mobile device
`• Petitioner failed to articulate any credible motivation to combine
`Hoffman’s deficient “transmission” disclosure of the second
`embodiment with Hoffman’s first embodiment
`– Petitioner maps examples of “environmental data” to “physiological
`state data” despite describing those two data types as “separate”
`– Failure to properly analyze means‐plus‐function elements
`
`POR at 33‐42; Sur‐Reply at 7‐13
`13
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`Hoffman | Overview
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`Hoffman | Overview
`
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`Inventors:
`
`Michael T. llofi'man. Portland. OR
`(US): 'l'omislav Lakovic. Portland.
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`14
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`
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`Hoffman | Overview
`
`First Embodiment
`
`Hoffman at Figs. 2, 4; Villasenor Dec (Ex. 2003) at ¶¶ 70‐78; POR at 25‐30
`15
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`
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`Hoffman | Overview
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`First Embodiment
`
`Hoffman at Figs. 5. 6; Villasenor Dec (Ex. 2003) at ¶¶ 70‐78; POR at 25‐30
`16
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`
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`Hoffman | Overview
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`Second Embodiment
`
`Hoffman at ¶ [0063]
`
`Hoffman at Fig. 7A
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`POR at 30‐33; Villasenor Dec (Ex. 2003) at ¶¶ 79‐82
`17
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`
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`Hoffman | Overview
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`Second Embodiment
`
`Hoffman at Fig. 8A
`POR at 30‐33; Villasenor Dec (Ex. 2003) at ¶¶ 79‐82
`18
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`
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`Hoffman | No transmitting “selected content” to the mobile device
`
`Petitioner’s purported “selected content,” i.e., “articles” (Pet at 22) or “third party”
`content (Pet at 22) are not transmitted to the remote devices (interface 803)
`
`Hoffman at ¶¶ [0070]‐[0071]; POR at 31‐35
`
`Hoffman at Fig. 8A; POR at 32
`See also Villasenor Dec (Ex. 2003) at ¶¶ 97‐100
`19
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`
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`Hoffman | No transmitting “selected content” to the mobile device
`• No disclosure of what type of information is transmitted via
`interface 803 to the remote devices
`– No disclosure of transmission to
`the remote devices (as opposed to
`transmission from the remote devices)
`
`Hoffman at ¶¶ [0070]‐[0071]; POR at 31‐35
`
`Hoffman at Fig. 8A; POR at 32
`See also Villasenor Dec (Ex. 2003) at ¶¶ 97‐100
`20
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`
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`Hoffman | No motivation to combine Hoffman’s separate embodiments
`
`Petitioner’s identified motivations are invalid because both goals are
`already achieved in each of the separate embodiments.
`
`Pet at 14
`
`POR at 37‐42; See also Inst Dec at 26 (Petitioner still must identify a reason that would have
`rendered obvious this specific combination to a POSITA); Villasenor Dec (Ex. 2003) at ¶¶ 107‐109
`21
`
`
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`Hoffman | No motivation to combine Hoffman’s separate embodiments
`
`Petitioner’s identified motivations are already present in each embodiment
`First Embodiment (Figs. 2‐6):
`
`Hoffman at ¶ [0042]
`
`Hoffman at ¶ [0057]
`
`Second Embodiment (Figs. 7A‐8D):
`
`Hoffman at ¶ [0069]
`
`POR at 37‐39; see also Villasenor Dec (Ex. 2003) at ¶¶ 107‐109
`22
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`
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`Hoffman | No motivation to combine Hoffman’s separate embodiments
`
`A “well‐known” feature does not provide a reason to modify
`Hoffman’s teachings. POR at 40; Inst Dec at 28.
`– KSR requires consideration of whether a POSITA would recognize the
`“benefit of doing so.” KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 401 (2007)
`
`POR at 40‐41; compare to SFC Co. Ltd. v. Idemitsu Kosan Co., Ltd., IPR2015‐00564, Paper 19 at 20–23 (P.T.A.B. July
`29, 2016) (prior art reference includes explicit reason to combine separate embodiments); See also Inst Dec at 28
`
`Pet at 15
`
`23
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`
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`“physiological state data” | Construction
`
`“Physiological state data” is “data about the user’s physical condition,” as Petitioner
`proposed and the Board agreed
`
`Inst Dec at 9
`
`’861 Patent 2:51‐60; POR at 15
`
`24
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`
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`“environmental data” | Construction
`
`Petitioner and its expert: “Environmental data” is “separate and apart from the user’s
`physiological state data” and is “data about the environment”
`
`Pet at 27
`
``
`
`Pet at 27
`
`Anthony Dec (Ex. 1003) at ¶ 132
`See also Inst Dec at 10; POR at 13‐14; Villasenor Dec (Ex. 2003) at ¶ 36‐37; Sur‐Reply at 8
`25
`
`’861 Patent at 6:52‐55
`
`
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`“environmental data” | Construction
`
`The claims recite “environmental data” separately from “physiological state data”
`
`’861 Patent Claim 1
`
`’861 Patent Claim 3
`
`POR at 13‐14; Sur‐Reply at 8
`26
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`
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`Hoffman | Mapped “physiological state data” is actually “environmental data”
`
`Petitioner improperly maps “athletic
`information” in Hoffman to “physiological
`state data” in Claim 1.
`
`However, the ‘861 Patent lists the “athletic information” of Hoffman as examples of
`“environmental data”—not “physiological state data”
`
`Anthony (Ex. 1003) at ¶ 99; see also Pet at 16
`
`Pet at 17
`
`Hoffman at ¶ [0038]; Pet at 17
`POR at 36; Sur‐Reply at 7‐9
`27
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`
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`Hoffman | Mapped “physiological state data” is actually “environmental data”
`
`Like the ‘861 Patent, Petitioner’s expert identifies “athletic
`information” like “movement of a user’s foot” as “environmental
`data,” not “physiological state data”
`
`Pet at 27
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``
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``
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``
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``
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`Anthony Dec (Ex. 1003) at ¶ 132
`
`POR at 13‐14; Sur‐Reply at 8
`28
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`
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`Hoffman | Mapped “physiological state data” is actually “environmental data”
`The Reply attempts to add examples of “athletic activity” that are not the “athletic
`information” identified in the Petition
`
`Petition does not cite
`Hoffman ¶[0082] or “calories
`burned, heart rate”
`
`Pet at 19
`
`Pet at 17
`
`Reply at 20
`
`Sur‐Reply at 9
`29
`
`
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`Hjelt| Fails to render any challenged claim unpatentable
`
`• Mapping of Hjelt fails for multiple reasons
`– Independent Claims
`• No disclosure of “predefined content”
`• All examples of “content” fail to meet three separate
`requirements of that content
`– Claim 3: No disclosure of selected based on “environmental data”
`because identified “environmental data” is not used in selecting
`or generating content
`– Claim 5: No disclosure of specific sensors listed in claim
`
`POR at 48‐67; Sur‐Reply at 14‐21
`30
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`
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`Hjelt| Overview
`
`Hjeltl Overview
`
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`Hjelt et al.
`
`
`
`(10) Patent No.: —
`(45) Date of Patent:
`Oct. 9, 2007
`
`5,939,200 A
`6,122,960 A
`6,356,856 B1
`6,396,416 B1
`
`11/1999 Yoshimuraetal.
`9/2000 Hutchings et al.
`3/2002 Damen et a1.
`5/2002 Kuusela eta].
`
`
`
`Inventors: Kari Hjelt, Espoo (F1); Santtu
`Naukkarinen, Espoo (Fl); Jukka
`
`‘
`
`31
`
`
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`“a plurality of predefined content”| Construction
`
`“Predefined content” must exist prior to receiving the physiological state data
`•
`Consistent with the ’861 Patent and the parties proposed constructions in district court
`
`’861 Patent at 15:42‐46
`
`Inst Dec at 12
`
`Ex. 2001 at 21
`POR at 15‐16; Villasenor Dec (Ex. 2003) at ¶ 39
`32
`
`
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`“a plurality of predefined content”| Separate from “Selecting”
`
`Hjelt’s use of the word “selecting” does not
`convey that the selected content necessarily
`existed prior to receiving the physiological
`state data (i.e., “predefined”)
`•
`Hjelt does not disclose any of the specific
`examples of content as existing prior to receiving
`“physiological information.”
`
`’861 Patent Claim 1
`
`Inst Dec at 12
`
`Hjelt at 26:65‐27:3
`
`POR at 50‐60
`33
`
`
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`“a plurality of predefined content”| Separate from “Selecting”
`
`• The claims require that the selected content meet three tests:
`(1) Be “predefined” (i.e., exist prior to receipt of the physiological state data)
`(2) Be selected “at least partially based on the physiological state data”
`(3) Not “includ[e] the physiological state data collected from the user”
`• None of the Petition’s categories of “content” meet these tests
`
`’861 Patent Claim 1
`POR at 51‐60; Reply at 21‐22; Villasenor Dec (Ex. 2003) at ¶¶ 120‐139; Sur‐Reply 14‐19
`34
`
`
`
`Hjelt| Petitioner’s mapped “predefined content”
`
`Petitioner maps Hjelt’s exercise programs, goals, alerts, and calendars to content from “a
`plurality of predefined content”
`
`Pet at 53
`
`Pet at 55
`
`Reply at 2
`
`None of the identified “predefined content”—exercise programs, user goals, alerts and
`calendars—are content from “a plurality of predefined content” as construed because
`none exist prior to receiving the “physiological information” (mapped as claim 1’s
`“physiological state data”)
`
`POR at 51‐60; Villasenor Dec (Ex. 2003) at ¶¶ 120‐139; Sur‐Reply at 14‐19
`35
`
`
`
`Hjelt| Exercise programs
`After receiving “selected activities” (mapped to “physiological state data”), Hjelt teaches
`that fitness trainer application 116 (in the mapped “host computer system”) creates or
`modifies an exercise program
`– Exercise programs do not exist prior to receiving the selected activities
`– Further, exercise programs include the “selected activities”
`New or modified exercise programs are
`created from the “selected activities”
`
`“Selected activities” are chosen or
`“automatically detected” at terminal 10
`
`Hjelt at 8:13‐32; POR at 52
`
`POR at 46
`
`Hjelt at 26:18‐33; POR at 54‐56
`Villasenor Dec (Ex. 2003) at ¶¶ 120‐139; Sur‐Reply at 17‐19
`
`36
`
`
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`Hjelt| Goals
`After receiving “user’s goals” and “selected activities” (mapped to “physiological state data”), Hjelt
`teaches that fitness trainer application 116 (in the mapped “host computer system”) modifies or
`adjusts the goals
`– Goals do not exist at the host computer system prior to receiving the user’s goals and selected activity from
`terminal 10
`
`Hjelt at 27:7‐12; POR at 57
`
`Hjelt at 13:50‐61; POR at 53
`
`POR at 46
`
`Hjelt at 26:18‐29; POR at 57
`Villasenor Dec (Ex. 2003) at ¶¶ 120‐139; Sur‐Reply at 17‐19
`37
`
`
`
`Hjelt| Calendars and alerts
`Hjelt’s calendars and alerts relate to timing and reminders, respectively, for an exercise
`schedule based on the “selected activities”
`– The calendars and alerts do not exist prior to receiving the selected activities
`– Hjelt does not identify any other pieces of information identified as “physiological information”
`related to calendars and alerts
`
`Hjelt at 26:34‐39; POR at 58
`
`POR at 46
`
`Hjelt at 26:50‐55; POR at 58
`Villasenor Dec (Ex. 2003) at ¶¶ 120‐139; Sur‐Reply at 17‐19
`38
`
`
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`Hjelt| The “selecting” limitation is not obvious
`
`• None of the cited portions of Hjelt suggest or motivate creation of a database of
`“a plurality of predefined content” (POR at 61‐63)
`– 6:1–28 “(describing the ‘terminal 10’ can store data in a database)” (Pet at 54)
`• Not describing destination 120
`– 22:41–62 “(describing a ‘data manager’ that interfaces with a[n] ‘activity detection application’
`of the ‘terminal 10’ and the ‘destinations 120’ for storing and transmitting information)” (id.)
`• No information regarding the types of data stored
`– 22:63–23:9 “(describing that the ‘destination 120’ can store information in a database).” (id.)
`• Describing a database but no indications of the type of data stored
`• Petitioner provides no rationale for incorporating into Hjelt’s disclosure the
`missing element (POR at 60‐63)
`
`39
`
`
`
`Hjelt| Claim 3 ‐ No selecting content “based on the environmental data”
`
`The Petition cites only to “presence information” as the claimed
`“environmental data”
`
`’861 Patent Claim 3
`
`Pet at 57
`
`POR at 63‐64; Sur‐Reply at 19‐21
`40
`
`
`
`Hjelt| Claim 3 ‐ No selecting content “based on the environmental data”
`
`•
`
`“Presence information” cannot be used in selecting content because Hjelt
`teaches only using “presence information” to transfer information from
`terminal 10 (i.e., the “mobile device”) to the data manager in mobile station
`60/destination 120 (i.e., the “host computer system”)
`– From terminal 10 is the opposite direction of what is recited in Claim 3 of
`“to deliver to the mobile device” (mapped to terminal 10)
`
`Hjelt at 24:2‐6; POR at 64
`
`POR at 63‐65; Sur‐Reply at 19‐21
`41
`
`
`
`Hjelt| Claim 5 ‐ No disclosure of recited physiological sensors
`
`Hjelt does not disclose any of the specific sensors listed in Claim 5
`
`’861 Patent at Claim 5; POR at 65
`
`Pet at 59; POR at 65
`
`42
`
`
`
`Hjelt| Claim 5 ‐ No disclosure of recited physiological sensors
`
`Dr. Anthony agrees Hjelt does not disclose any of the sensors listed in Claim 5
`
`Q. But Hjelt doesn't expressly mention an electrocardiogram sensor?
`A. No, it does not.
`Q. And it does not expressly mention a galvanic skin sensor?
`A.
`It does not.
`Q. And it does not expressly mention a plethysmography sensor?
`A.
`It does not.
`Q.
`It does not expressly mention a skin temperature sensor?
`A.
`It does not.
`Q. And it does not expressly mention electromyogram sensor?
`A.
`It does not. It describes broadly using physiological information and those are not an exhaustive list of the
`types of sensors that aren't included. There are many other sensors that aren't included that would also give
`physiological information.
`
`Anthony Deposition (Ex. 2002) at 91:19‐92:13 (cited in POR at 66‐67)
`
`43
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`
`
`Additional Slides
`
`Additional Slides
`
`44
`
`
`
`Claim Term
`
`Claim 26: Means for
`analyzing the
`physiological state data
`collected from the user
`of the mobile device
`
`Means‐Plus‐Function | Construction
`Sufficient corresponding structure, in the form of algorithms, exists in
`the ’861 Patent
`Because Petitioner identified
`Petitioner’s Construction
`Patent Owner’s Construction
`only general purpose
`Function: “analyzing the physiological state data
`Function: “analyzing the physiological state data
`collected from the user of the mobile device”
`collected from the user of the mobile device”
`computer components and no
`Structure: “‘host computer system 140’ and a
`Structure: an algorithm in support of this term at step
`‘computer system 800’ containing one or more
`430 of Figure 4, step 535 of Figure 5, or step 640 of
`algorithms for computer‐
`processors, storage devices, input devices, output
`Figure 6 and described in the specification at 15:13–39,
`devices, communications subsystems, and
`17:7–11, or 19:15–41, respectively.
`implemented functions, it
`memory.” Pet at 7
`POR at 19; Ex. 2003 at ¶¶ 42–45.
`Function: “selecting content from a plurality of
`Function: “selecting content from a plurality of
`failed to identify “sufficient
`predefined content to deliver to the mobile device at
`predefined content to deliver to the mobile device
`least partially based on the physiological state data
`at least partially based on the physiological state
`corresponding structure”
`collected from the user”
`data collected from the user”
`Structure: an algorithm in support of this term at step
`Structure: “‘host computer system 140’ and a
`435 of Figure 4, step 540 of Figure 5, or step 645 of
`‘computer system 800’ containing one or more
`Figure 6 and described in the specification at 15:40–52,
`processors, storage devices, input devices, output
`17:12–26, or 19:42–60, respectively.
`devices, communications subsystems, and
`POR at 20; Ex. 2003 at ¶¶ 48–51.
`memory.” Pet at 7–8.
`
`Claim 26: Means for
`selecting content from a
`plurality of predefined
`content to deliver to the
`mobile device at least
`partially based on the
`physiological state data
`collected from the user.
`
`45
`
`
`
`Means‐Plus‐Function | Construction
`
`Claim Term
`
`Claim 31: Means for
`monitoring for an indication
`that a trigger action has
`occurred at the mobile
`device.
`
`Claim 31: Means for aborting
`presentation of the selected
`content and deleting the
`selected content from the
`mobile device in response to
`the trigger action not
`occurring with a threshold
`period of time
`
`Petitioner’s Construction
`
`Patent Owner’s Construction
`Because Petitioner identified
`Function: “monitoring for an indication that a
`Function: “monitoring for an indication that a trigger
`action has occurred at the mobile device”
`trigger action has occurred at the mobile
`only general purpose
`device”
`Structure: an algorithm in support of this term at step
`Structure: “one or more processors of ‘mobile
`560 of Figure 5 and described in the specification at
`computer components and no
`device 110’ and a ‘processor 270’ of the
`17:33–42.
`‘mobile device 200.’” Pet at 9–10.
`POR at 20‐21; Ex. 2003 at ¶¶ 54–55.
`algorithms for computer‐
`Function: “aborting presentation of the selected
`Function: “aborting presentation of the
`implemented functions, it
`content and deleting the selected content from the
`selected content and deleting the selected
`mobile device in response to the trigger action not
`content from the mobile device in response
`failed to identify “sufficient
`occurring with a threshold period of time”
`to the trigger action not occurring with a
`Structure: an algorithm in support of this term at at
`threshold period of time”
`corresponding structure”
`step 560 of Figure 5 and described in the specification
`Structure: “one or more processors of the
`at 17:51–60.
`‘mobile device 110’ and a ‘processor 270’ of
`POR at 21; Ex. 2003 at ¶¶ 58–59.
`the ‘mobile device 200.’” Pet at 10.
`
`46
`
`
`
`Means‐Plus‐Function | Construction
`
`Claim Term
`Claim 32: Means for determining
`a similarity between an ideal
`physiological state associated
`with the content and the
`physiological state data collected
`from the user of the mobile
`device.
`
`Claim 32: Means for determining
`a price for presenting the content
`to the user at least partially based
`on the similarity between the
`ideal physiological state and the
`physiological state data collected
`from the user of the mobile
`device.
`
`Patent Owner’s Construction
`Petitioner’s Construction
`Function: “determining a similarity between an
`Function: “determining a similarity between an
`Because Petitioner identified
`ideal physiological state associated with the
`ideal physiological state associated with the
`content and the physiological state data
`content and the physiological state data collected
`only general purpose
`collected from the user of the mobile device”
`from the user of the mobile device”
`Structure: “‘host computer system 140’ and
`Structure: an algorithm in support of this term at
`computer components and no
`‘processor 810’ of the ‘computer system 800.’”
`step 720 of Figure 7 and described in the
`specification at 20:31–61.
`Pet at 10–11.
`algorithms for computer‐
`POR at 22; Ex. 2003 at ¶¶ 62–63.
`Function: “determining a similarity between an
`Function: “determining a price for presenting
`implemented functions, it
`ideal physiological state associated with the
`the content to the user at least partially based
`content and the physiological state data collected
`on the similarity between the ideal
`failed to identify “sufficient
`from the user of the mobile device”
`physiological state and the physiological state
`Structure: an algorithm in support of this term at
`data collected from the user of the mobile
`corresponding structure”
`step 730 of Figure 7 and described in the
`device”
`specification at 20:62–21:2.
`Structure: “‘host computer system 140’ and
`POR at 23; Ex. 2003 at ¶¶ 66–67.
`‘processor 810’ of the ‘computer system 800.’”
`Pet at 11.
`
`47
`
`
`
`Hjelt| Overview
`
`POR at 45
`
`POR at 46
`
`48
`
`
`
`Hjelt| Overview
`
`POR at 52
`
`Hjelt at 8:18‐32; POR at 52
`
`49
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`