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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`Apple Inc.,
`Petitioner
`
`
`v.
`
`Qualcomm Inc.,
`Patent Owner
`
`
`
`Inter Partes Review No. IPR2018-01277
`Inter Partes Review No. IPR2018-01278
`
`Patent No. 8,497,928
`
`
`
`
`DECLARATION OF DR. DANIEL ALIAGA
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`
`
`Table of Contents
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`
`I. BACKGROUND AND QUALIFICATIONS ................................................. 6
`II. UNDERSTANDING OF THE LAW ............................................................... 8
`A. THE LEVEL OF ORDINARY SKILL IN THE ART .................................................... 8
`B. CLAIM CONSTRUCTION ................................................................................... 10
`C. OBVIOUSNESS ................................................................................................. 11
`III. OVERVIEW ................................................................................................. 14
`A. AUTOFOCUS .................................................................................................... 14
`B. THE ‘928 PATENT ........................................................................................... 17
`C. THE CHALLENGED CLAIMS ............................................................................. 19
`D. THE SUBSTITUTE CLAIMS ............................................................................... 21
`IV. CLAIM CONSTRUCTION ........................................................................ 28
`A. “FOCAL POINT” ............................................................................................... 28
`B. “FOCUSING THE LENS COMPONENT . . . WHILE THE IMAGE IS BEING DISPLAYED”
`33
`V. ANALYSIS BASED ON HYODO AS A MAIN REFERENCE ................. 36
`A. SUMMARY OF THE REFERENCES ...................................................................... 36
`i. U.S. Patent 6,919,927 Hyodo ..................................................................... 36
`ii. U.S. Patent Publication 2006/0055814 (“Okawa”) (Ex. APPLE-1006) ... 37
`iii. U.S. Patent 6,151,073 (“Steinberg’073”) (Ex. APPLE-1007) .................. 38
`iv. U.S. Patent 7,852,381 (“Abe”) (Ex. APPLE-1009) ................................... 39
`B. THE COMBINATION OF HYODO, OKAWA, AND STEINBERG’056 DOES NOT
`RENDER OBVIOUS CLAIM 7 ................................................................................... 40
`i. Hyodo does not disclose or suggest focusing while an image is being
`displayed............................................................................................................ 41
`ii. Okawa does not disclose focusing while an image is being displayed ...... 47
`iii. Hyodo’s predetermined areas are not the same as the focal points in claim
`7 55
`iv. Hyodo’s selection of the principal subject by a user is not a selection of
`the second focal point........................................................................................ 62
`v. The combination of Hyodo and Steinberg’078 does not disclose selecting a
`flash level value based on a selected or intended center of interest ................. 64
`C. CLAIMS 8, 10, 11, AND 13 ............................................................................... 66
`D. THE COMBINATION OF HYODO, OKAWA, AND STEINBERG FAILS TO RENDER
`OBVIOUS SUBSTITUTE CLAIMS 17-21 .................................................................... 67
`i. Hyodo-Okawa-Steinberg’073 combination does not render obvious
`substantially real-time preview of the view through the lens component” ...... 68
`
`“focusing the lens component . . . while the image is being displayed as a
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`second focal point that is selected to be centered at a set of coordinates of the
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`ii. The Hyodo-Okawa-Steinberg’073 combination does not render obvious a
`first type of user input. ...................................................................................... 71
`iii. Claims 18 and 20 Are Patentable Over Petitioner’s Hyodo-Okawa-
`Steinberg’076 .................................................................................................... 73
`iv. Claim 21 is Patentable over Hyodo-Okawa-Steinberg’076-Abe ............... 73
`VI. VALIDITY ANALYSIS BASED ON KONICEK AS THE MAIN
`REFERENCE ......................................................................................................... 74
`A. SUMMARY OF THE REFERENCES ...................................................................... 74
`i. U.S. Patent Publication No. 2007/0086764 (“Konicek”) (Ex. APPLE-
`1011) .................................................................................................................. 74
`ii. U.S. Patent Publication 2003/0193600 (“Kitamura”) (Ex. APPLE-1012)
`76
`iii. U.S. Patent 6,977,687 (“Suh”) (Ex. APPLE-1013) ................................... 77
`iv. U.S. Patent Publication 2006/0204056 (Steinberg’056) (APPLE-1014) .. 77
`v. U.S. Patent Publication 2004/0189856 (Tanaka) (APPLE-1015) ............. 78
`vi. U.S. Patent 7,253,836 (Suzuki) (APPLE-1016) ......................................... 78
`B. THE COMBINATION OF KONICEK, KITAMURA, SUH, AND STEINBERG’056 DOES
`NOT RENDER OBVIOUS CLAIM 7, 8, 10, 11, AND 13 ................................................ 79
`i. Konicek Describes Separate Hardware Elements on a Digital Camera
`Which Perform Different Functions .................................................................. 79
`ii. Konicek-Kitamura-Suh-Steinberg’056 does not disclose the two different
`types of user input recited by claim 7 ............................................................... 83
`iii. Petitioner relies on hindsight bias in order to combine the elements of
`on a touchscreen for selecting a second focal point ......................................... 91
`iv. Konicek-Kitamura-Suh-Steinberg’056 does not disclose “selecting a
`point to the second focal point” ........................................................................ 93
`C. CLAIMS 8, 10, 11, AND 13 ............................................................................... 95
`D. THE COMBINATION OF KONICEK, KITAMURA, SUH, AND STEINBERG’056 FAILS
`TO RENDER OBVIOUS SUBSTITUTE CLAIMS 17-21 ................................................... 96
`i. Konicek-Kitamura-Suh-Steinberg’056 do not render obvious “in response
`view through the lens component” ................................................................... 96
`ii. Claims 18 and 20 Are Patentable Over Konicek-Kitamura-Suh-
`Steinberg’056-Tanaka .....................................................................................100
`
`to receiving a first type of user input on the touchscreen display: selecting a
`second focal point for the image the second focal point being selected to be
`centered at a set of coordiates of the first type of user input, and automatically
`focusing the lens component from the first focal point to the second focal point
`while the image is being displayed as a substantially real-time preview of the
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`
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`Konicek and Suh to disclose the different first and second types of user input
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`second focal point” and “focusing the lens component from the first focal
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`iii. Claim 21 is Patentable over Konicek-Kitamura-Suh-Steinberg’056-Suzuki
`100
`VII. CONCLUSION AND OTHER COMMENTS ........................................101
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`I, Daniel Aliaga, declare as follows:
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`1.
`
`I make this declaration based upon my own personal knowledge and,
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`if called upon to testify, would testify competently to the matters contained herein.
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`2.
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`I have been retained as a technical expert on behalf of patent owner
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`Qualcomm Incorporated in connection with the above-captioned inter partes
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`reviews (“IPR”) of U.S. Patent No. 8,497,928 (“the ’928 Patent”). I understand that
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`Apple Inc. (“Petitioner” or “Apple”) has filed two petitions (IPR2018-01277
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`(“1277 Petition” or “1277 Pet.”) and IPR2018-01278 (“1278 Petition” or “1278
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`Pet.”), collectively “Petitions”) for Inter Partes Review of Claims 7, 8, 10, 11, and
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`13 of U.S. Patent No. 8,497,928 (“the ’928 Patent”). I am being compensated for
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`my time at a rate of $500 per hour. My compensation is not dependent in any way
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`upon the outcome of these matters.
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`3.
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`I submit this declaration in support of Qualcomm’s Patent Owner
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`Responses to Apple’s petitions. I reserve the right to supplement my opinions
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`should I be requested to provide additional analysis in connection with the
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`patentability of claims 7, 8, 10, 11, and 13 of the ’928 Patent (“Challenged
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`Claims”). As part of my work on this declaration, I have reviewed relevant
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`portions of the 1277 and 1278 Petitions, the supporting declaration of Dr. Wright
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`and other supporting exhibits, the ‘928 patent, the prosecution history of the ‘928
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`patent, and the prior art asserted by Petitioner.
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`I.
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`BACKGROUND AND QUALIFICATIONS
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`4.
`
`In 1991, I received my undergraduate B.Sc. in Computer Science
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`degree magna cum laude from Brown University and wrote an Honor’s Thesis
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`related to computer graphics. I then proceeded to study computer science,
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`focusing on computer graphics, at the University of North Carolina at Chapel Hill
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`where I received my M.S. in Computer Science in 1993 and my Ph.D. in 1999.
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`Subsequently, I worked as a full-time graphics and image processing researcher at
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`Lucent Technologies Bell Labs (formerly known as Bell Telephone Laboratories)
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`until December 2002. Afterwards, I obtained a researcher position at Princeton
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`University and then began my academic career at Purdue University in August
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`2003 as an Assistant Professor of Computer Science. In August 2010, I received
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`tenure and became an Associate Professor of Computer Science and currently hold
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`that position today.
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`5.
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`In addition, I was a visiting professor in the Department of Computer
`
`Science at ETH Zurich and in the Department of Architecture at ETH Zurich
`
`during 2011, I was a visiting professor in the Visual Computing Center at King
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`Abdullah University of Science and Technology (KAUST) during Fall 2018, have
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`received an Organization for Economic Co-operation and Development (OECD)
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`Fellowship, and was a Discovery Park Faculty Research Fellow.
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`6.
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`To date I have published over 115 peer reviewed publications and
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`chaired and served on numerous ACM and IEEE conference and workshop
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`committees, including being a member of more than 65 program committees,
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`conference chair, papers chair, invited speaker, and invited panelist. In addition, I
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`have served on several National Science Foundation (“NSF”) panels and on the
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`equivalent grant funding agencies for other countries, on the editorial board of
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`Computer Graphics Forum and of Graphical Models, and am a member of ACM
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`SIGGRAPH. My research has been whole or partially funded by over $7.5 million
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`dollars in funds from NSF, IARPA, Metropolitan Transportation Commission (of
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`the State of California), Microsoft Research, Google, and Adobe Inc.
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`7.
`
`During my graduate school education, subsequent research position,
`
`and current academic position, I have been performing research and publishing
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`papers mostly in computer graphics but also in visualization and computer vision.
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`The major part of my computer graphics work has been developing 3D modeling
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`and rendering algorithms, including novel camera models, camera design, and
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`camera calibration algorithms.
`
` Camera calibration includes mathematical
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`modelling of how a camera renders images, based on, for example, determining
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`parameters of the mathematical model which mimics the physical camera. These
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`parameters relate to, for example, image plane distortion, focal points, the
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`positioning of a camera relative to the image and to the scene, and pixel
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`dimensions. Many of these techniques are employed in digital cameras and digital
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`projectors as well as modern GPUs (graphic processing units) and GPU
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`programming. In addition, I am the instructor for computer graphics courses that
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`includes teaching concepts related to digital cameras and digital camera models,
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`their operation, and their use.
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`8.
`
`I have also had four years of industry experience at Lucent
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`Technologies from 1998 to 2002 in the Image and Video Processing Lab, where I
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`created a new omnidirectional camera, published papers and filed patents related to
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`such camera technology. The systems I developed and wrote about used focusing
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`methods, including contrast and phase-based focus.
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`9.
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`Further information, including other citations and awards, can be
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`found in my curriculum vitae at Exhibit 2002.
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`II. UNDERSTANDING OF THE LAW
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`10. My opinions are also formed by my understanding of the relevant law,
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`as set forth below. I understand that the patentability of a patent is analyzed on a
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`claim-by-claim basis, from the perspective of a hypothetical person of ordinary
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`skill in the art (“POSA”).
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`11.
`
`I understand that earlier publications and patents, which may be
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`referred to as “prior art,” may act to render a patent unpatentable for one of two
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`reasons: (a) anticipation, and (b) obviousness. I further understand that the prior art
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`must be viewed from the perspective of a POSA at the time of the invention.
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`A. The Level of Ordinary Skill in the Art
`12. When interpreting a patent, I understand that it is important to view
`
`the disclosure and claims of that patent from perspective of one of ordinary skill in
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`the relevant art at the time of the invention. I understand that the ’928 Patent was
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`filed on July 31, 2007 (hereinafter the “Filing Date”). For purposes of this
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`declaration, I have taken the perspective of a person of ordinary skill as of the
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`Filing Date.
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`13.
`
`I understand that Dr. Wright asserts that a Person of Ordinary Skill in
`
`the Art (“POSA”) as of the Filing Date would have had “a Master of Science
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`Degree in an academic area emphasizing electrical engineering, computer
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`engineering, optics design, or an equivalent field (or a similar technical Master’s
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`Degree, or higher degree).” Ex. 1003 (“Wright”), ¶¶25-26. Alternatively, “a
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`POSITA would have had a Bachelor’s Degree (or higher degree) in an academic
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`area emphasizing one or more of these technical disciplines and three or more
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`years of corresponding industry work experience. Such an individual would also
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`have education or industry experience in the area of user-interface design.” Id.
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`14.
`
`In my opinion, the POSA as of the Filing Date would have also had
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`on year of camera design education or experience, whether in academia or in
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`industry. This would include experience or study in camera user interface design,
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`camera calibration, or camera focusing schemes. Based on either my or Dr.
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`Wright’s description, my qualifications at the time of the Filing Date exceeded the
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`level of a POSA. By July 2007, I had received my Ph.D in Computer Science,
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`specializing in Computer Vision, performed academic research relating to
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`computer graphics and had industry experience in the Image and Video Processing
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`Lab at Lucent Technologies. Further, by July 2007, I was an Assistant Professor in
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`the Computer Science Department at Purdue, having published several papers on
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`camera imaging and rendering.
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`B. Claim Construction
`15.
`I understand that before claims may be analyzed for anticipation or
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`obviousness based on the prior art, the scope of the claims must be defined. I
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`understand that when the definition of a claim term is in dispute, it will be defined
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`through a process called “claim construction.”
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`16.
`
`I understand that this proceeding is an inter partes review (“IPR”)
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`proceeding before the Patent Trial and Appeal Board (“PTAB”). I understand that,
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`in an IPR proceeding, claim terms are given their “broadest reasonable
`
`construction” in light of the patent specification. I understand that claim terms are
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`generally given their ordinary and customary meaning, which is the meaning that
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`the term would have to a POSA at the time of the invention, consistent with the
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`broadest reasonable construction.
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`17.
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`I have been informed and understand that “claim construction” is the
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`process of determining a patent claim’s meaning. I reserve the right to offer
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`constructions for additional terms, should those terms become relevant to either
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`this or other proceedings. I understand that Petitioner has not offered constructions
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`for any claim terms, but that Dr. Wright has opined on the meaning of some claim
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`terms in his declaration.
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`C. Obviousness
`18.
`I understand that the prior art may render a patent claim “obvious.” I
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`understand that one or more prior art references (e.g., articles, patents, or other
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`publications) that individually disclose fewer than all elements of a patent claim
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`may nevertheless be relied upon to render a patent claim obvious if the claimed
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`invention would have been obvious to a POSA based on the collective teachings of
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`the prior art and the knowledge of a POSA at the time of the invention. A patent
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`claim is obvious if the differences between the subject matter sought to be patented
`
`and the prior art are such that the subject matter as a whole would have been
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`obvious at the time the invention was made to a person having ordinary skill in the
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`art to which said subject matter pertains.
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`19.
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`I understand that obviousness is based on the scope and content of the
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`prior art, the differences between the prior art and the claim, the level of ordinary
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`skill in the art, and secondary indications of obviousness and non-obviousness to
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`the extent they exist. Under the doctrine of obviousness, a claim may be invalid if
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`the differences between the invention and the prior art are such that the subject
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`matter as a whole would have been obvious at the time the invention was made to a
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`POSA.
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`20.
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`It is also my understanding that there are additional considerations
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`that may be taken into account when evaluating whether a claim is obvious,
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`including whether:
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` the claimed invention is simply a combination of prior art elements
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`according to known methods to yield predictable results;
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` the claimed invention is a simple substitution of one known element
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`for another to obtain predictable results;
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` the claimed invention uses known techniques to improve similar
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`devices or methods in the same way;
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` the claimed invention applies a known technique to a known device or
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`method that is ready for improvement to yield predictable results;
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` the claimed invention would have been “obvious to try” choosing
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`from a finite number of identified, predictable solutions, with a
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`reasonable expectation of success;
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` there is known work in one field of endeavor that may prompt
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`variations of it for use in either the same field or a different one based
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`on design incentives or other market forces if the variations would
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`have been predictable to one of ordinary skill in the art;
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` there existed at the time of invention a known problem for which there
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`was an obvious solution encompassed by the patent’s claims; and
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` there is some teaching, suggestion, or motivation in the prior art that
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`would have led one of ordinary skill to modify the prior art reference
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`or to combine prior art reference teachings to arrive at the claimed
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`invention.
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`21.
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`I understand that evidence of objective indicia can consist of praise of
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`the invention by those in the relevant field, commercial success enjoyed by the
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`products practicing the invention, licensing of the invention, long-felt but
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`unsatisfied need for the invention, and evidence of copying of the claimed
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`invention. I further understand that where patent claims recite a range, a patent
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`holder can rebut a case of obviousness by showing the criticality of that range. This
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`can be done, for example by showing that the claimed range is critical, yields some
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`special or critical outcome, produces a difference in kind rather than degree, or
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`achieves unexpected results.
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`22.
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`I further understand that obviousness cannot be sustained by mere
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`conclusory statements; instead, there must be some articulated reasoning with
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`some rational underpinning to support the legal conclusion of obviousness.
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`Obviousness must be established by providing a sufficient explanation of how the
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`references may be combined, from the perspective of one with ordinary skill in the
`
`art, to arrive at the claimed invention, and why the proffered combination accounts
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`for all the features of each claim. In particular, I understand that an obviousness
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`theory must explain why a person of ordinary skill in the art would have combined
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`elements from specific references in the way the claimed invention does.
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`23.
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`I further understand that an IPR petition constitutes a challenge to the
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`patentability of one or more claims of a patent based on earlier publications and
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`patents.
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`III. OVERVIEW
`A. Autofocus
`24. The ’928 Patent relates to the field of digital cameras and autofocus.
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`Autofocus functions assist the user of a digital camera “to obtain the correct focus
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`on a subject rather than requiring the operator to adjust focus manually.” APPLE-
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`1001, 1:13-16. On many digital cameras, autofocus consists of three main phases.
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`First, an area of a frame is identified. Second, the camera initiates a focusing
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`procedure, where lenses in the camera move relative to each other in order to
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`achieve a certain amount of contrast in an image, with particular emphasis on the
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`identified area of the frame. Third, once the focusing procedure is complete, the
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`relative position of the lens is locked, or held in place. Once the focus has been
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`locked, a user can quickly capture a photograph when the user is ready.
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`25. The focusing procedure involves several parts on a digital camera. A
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`set of lenses is moved relative to each other through a fine motor, which makes
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`small changes to the focal length produced by the set of lenses. The focal length
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`changes the focusing distance of the digital camera. Generally, the longer the focal
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`length, the greater the focusing distance of a digital camera and thus there, further
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`away objects from the digital camera can appear in focus. The changes in the focal
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`length cause a change in the focus quality of the photo, whether measured by the
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`contrast in the photo or by phase detection, or in some cases, by both
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`measurements factored into a hybrid focus detection scheme. Autofocus sensors
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`measure how much focus has improved through each adjustment in the lens, and a
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`processor (e.g., a CPU) evaluates the improvement to determine whether to
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`continue adjusting the set of lenses. Once the processor determines that adequate
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`focusing quality has been achieved, the focus position is then locked.
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`26. Digital cameras are typically manufactured with a limited number of
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`areas in a frame where the autofocus system will measure contrast or phase
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`changes while the lens components are adjusted. This is usually due to the
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`computational expense, cost, and the arrangement limitations to produce a
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`compact, handheld form of the digital camera. In the state of the art of digital
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`cameras prior to the ‘928 Patent, autofocus mechanisms could “have trouble
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`getting the focus right when [] shooting a complex scene.” See APPLE-1017,
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`Digital Photography for Dummies, 5th Edition, at 87. In such instances, a user may
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`have to resort to manual focus for finer control of the camera lens than what
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`autofocus can provide. In addition, the result of using different focal points can be
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`very significant. For example, placing the focal point on a person in the
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`foreground versus a background object may only be a difference of a few pixels in
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`the scene as displayed in the camera’s display screen. However, this difference
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`may completely change lens positioning, microphone focusing, white balance or
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`exposure. Often, the foreground and background will be at significantly different
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`distances from the observer and this will cause large focus changes.
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`27. From a user interface perspective, autofocus systems prior to the 2007
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`timeframe involved a multi-step process for a user to place a subject in an intended
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`area of a frame and set the focus before finally capturing a photo with the intended
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`focus or center of interest. Prior to the invention of the ‘928 Patent, users selected
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`a subject of focus by pointing the camera at a subject and “performing a button half
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`press or other convoluted user interaction to achieve the desired focus.” APPLE-
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`1001 at 1:16-19. As explained by Digital Photography for Dummies, the user must
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`“place the subject within the area that the autofocus mechanism reads” and then
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`perform a half button press which initiates a focusing process and then “locks in”
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`the focus (e.g., lock in place the relative lens position) before taking the picture.
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`APPLE-1017, 156. The focus remains correctly locked on one subject “as long as
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`[the user keeps] the shutter button halfway down” and the distance between the
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`camera and the subject doesn’t change. Id. at 157. If any part of the scene
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`changed during the half-button press or afterwards, the camera would no longer
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`have optimal focus for a scene. This is also alluded to in Digital Photography for
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`Dummies: “Be careful that the distance between the camera and the subject doesn't
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`change, or your focus will be off.” APPLE-1017 at 157. If the scene is dynamic
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`(i.e., has moving objects/people) or if the camera is moving (i.e., handheld), it is
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`hard to not change the distance between camera and scene; this would require
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`continually re-half-pressing the button and squinting through the EVF, re-half-
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`pressing the button and hoping the photograph is just framed correctly, or manually
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`adjusting the focus.
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`B.
`The ‘928 Patent
`28. To overcome burdensome user interactions with a digital camera, the
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`‘928 Patent discloses improved techniques “to allow users to more easily
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`determine the area of the photograph they wish to focus on.” APPLE-1001 at
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`1:19-21. Such improved techniques can be used with a digital camera or a mobile
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`electronic device (such as a cellular phone) that comprises “a digital camera having
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`a lens component and lens position component.” Id. at 1:41-43. The disclosed
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`techniques “are particularly directed to automatically focusing a digital camera
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`using a display device.” Id. at 1:38-39. The ‘928 Patent enabled more complex
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`focus setups, which are often desirable. For instance, what is centered-on and what
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`is focused on may not be the same entity. Further, the center of interest might be
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`different for focus, white-balance, microphone, or flash.
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`29.
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`In one embodiment, the digital camera “display[s] an image with a
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`first focal point.” Id. at 10:55-59. The displayed image can be shown on a touch
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`sensitive LCD screen as “a substantially real-time preview of the image to allow
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`for framing and previewing before capturing a photograph.” Id. at 9:1-4. The user
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`can then “select[] a second focal point for the image” through a first type of user
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`input, such as applying pressure to an area of the display. Id. at 10:60-64; 9:8-21.
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`The first and second focal points refer to “the intended center of interest of a
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`photograph and is typically the point where the image will be in the clearest
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`focus.” Id. at 9:4-6. While the image is being displayed, the digital camera
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`“focus[es] on the second focal point” and may also select “a flash level value
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`representing a flash intensity” based on the second focal point. Id. at 10:55-11:3,
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`11:5-7; see also Id. at Fig. 3. The user can capture the image, based on the selected
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`flash level value, in response to a second type of user input on the touchscreen
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`display that is different from the first type of user input. The specification
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`describes, as examples of a second type of user input, “a double tap on the
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`touchscreen display or pressure applied to the touchscreen display in the area of the
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`selected second focal point” as a way “to indicate that the image on the display is
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`ready to be committed to memory.” Id. at 11:12-15.
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`30. Focusing on the second focal point can include generating a set of
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`coordinates for the second focal point and focusing a lens on the second focal
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`point. Id. at 10:66-11:3. The lens position component can receive control signals
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`that indicate where a user “wishes to focus on a particular portion of an object.”
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`Id. at 8:58-60. The lens position components can then configure the lens
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`component to “deliver the desired focus” based on the area selected by the user.
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`Id. at 8:60-63, 9:7-20. In certain embodiments, implementation of this technique
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`involves a focal point selection module coupled to a display, and a focus control
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`module that is coupled to the focal point selection module and the lens position
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`component “to provide focus control signals to the lens position component 206 to
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`focus the lens component 204 on the second focal point.” Id. at 9:22-34. Further,
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`a white balance setting value for the image may be modified based on the second
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`focal point. Id. at 10:3-7. The white balance of an image may affect the overall
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`mixture of colors in an image and refers to the relative amounts of red, green, and
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`blue colors in the image. Id. at 10:10-13.
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`31. The disclosed technique improves a user’s ability to adjust focus on
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`different focal points, e.g., different intended areas of interest in an image. The
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`specification describes an example use case where the user can easily switch the
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`intended center of interest from a friend to a background waterfall through simple
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`inputs on a touchscreen. Id. at 12:25-43. This described use case is an example of
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`how the ‘928 Patent improves the usability of autofocus. By only requiring that
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`the user “tap the portion of the touchscreen display of the mobile electronic device
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`to set the focal point on a different, desired location” without further adjustment or
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`extra steps on the camera (such as a half-button press or placing the friend within a
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`particular location in the frame), the user can quickly confirm that the focus is at
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`the correct location in the image (the friend, not the waterfall) through the
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`substantially real-time preview on the camera’s display. Id. With a second user
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`input on the screen, the user can then confidently capture the intended photo.
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`C. The Challenged Claims
`32. Below is a summary of Challenged Claims 7, 8, 10, 11, and 13 of the
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`‘928 Patent.
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`7. A method for operating a mobile device, the method being
`performed by one or more processors and comprising:
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`displaying, on a touchscreen display, an image having a first
`focal point, the image being provided by a lens component;
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`selecting a second focal point for the image in response to
`receiving a first type of user input on the touchscreen display, the
`second focal point corresponding to a location on the image displayed
`on the touchscreen display;
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`focusing the lens component from the first focal point to the
`second focal point while the image i