UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CANON, INC.
`Petitioner,
`
`v.
`
`CELLSPIN SOFT, INC.
`Patent Owner.
`
`CASE: IPR2019-001271
`Patent No. 9,258,698
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`PATENT OWNER CELLSPIN’S DEMONSTRATIVE EXHIBITS
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`1 GoPro, Inc., Garmin International, Inc. and Garmin USA, Inc. were joined as
`parties to this proceeding. Paper 27.
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CANON, INC.
`Petitioner,
`
`v.
`
`CELLSPIN SOFT, INC.
`Patent Owner.
`
`CASE: IPR2019-001271
`Patent No. 9,258,698
`
`PATENT OWNER CELLSPIN’S DEMONSTRATIVE EXHIBITS
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`1 GoPro, Inc., Garmin International, Inc. and Garmin USA, Inc. were joined as
`parties to this proceeding. Paper 27.
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`Pursuant to 37 C.F.R. § 42.70(b) and the Trial Hearing Order dated December 23, 2019
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`IPR2019-00131
`U.S. Pat. No. 9,258,698
`
`(Paper 37), Patent Owner Cellspin submits the attached demonstrative exhibits for use at
`
`the January 28, 2020 Oral Hearing. Hard copies of these demonstrative exhibits will be
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`provided to the Panel members and the court reporter prior to the start of the oral
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`argument. Counsel for Petitioner has been timely served with a copy of these
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`demonstrative exhibits.
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`Dated: January 22, 2020
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`Respectfully submitted,
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`
`
`/s/ John J. Edmonds
`John J. Edmonds, Reg. No. 56,184
`EDMONDS & SCHLATHER, PLLC
`355 South Grand Avenue, Suite
`2450 Los Angeles, CA 90071
`Telephone: 213-973-7846
`Facsimile: 213-835-6996
`Email: pto-edmonds@ip-lit.com
`
`Stephen F. Schlather, Reg. No. 45,081
`EDMONDS & SCHLATHER, PLLC
`2501 Saltus Street
`Houston, TX 77003
`P: 713-234-0044
`F: 713-224-6651
`E: sschlather@ip-lit.com
`
`Counsel for Patent Owner, Cellspin Soft, Inc.
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`1
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`January 22, 2020
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`IPR2019-00131
`U.S. Pat. No. 9,258,698
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`CERTIFICATE OF SERVICE
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`the herein
`that a copy of
`The undersigned hereby certifies
`DEMONSTRATIVE EXHIBITS is being served in its entirety on January 22,
`2020, upon the following parties via electronic service:
`
`jarednewton@quinnemaneul.com
`Jennifer.Bailey@eriseip.com
`Adam.Seitz@eriseip.com
`PTAB@eriseip.com
`karinehk@rimonlaw.com
`
`/s/ John J. Edmonds
`John J. Edmonds
`
`2
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`
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`CANON U.S.A., INC.
`Petitioner
`
`v.
`
`CELLSPIN SOFT, INC.
`Patent Owner
`___________________
`
`Patent No. 9,258,698
`Inter Partes Review No. 2019‐00127
`
`PATENT OWNER CELLSPIN’S DEMONSTRATIVE SLIDES
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`
`
`Agenda
`• Introduction Summary
`• Bluetooth Pairing, Authentication and Encryption are Distinct Issues and Each is Optional
`• Bluetooth Pairing is Optionally Practiced and Optionally Supported
`• BRI of Paired Wireless Connection
`• Canon’s CONSTRUCTIONS for Paired Wireless Connection
`• BRI of Cryptographic Authentication
`• Canon/Madisetti’s Petition Theory of Obviousness for Cryptographic Authentication
`• None of Exhibits 1017, 1019 or 1020 disclose camera cryptographically authenticating
`• NO Rational/Motivation To Combine “Cryptographic Authentication” with “Takashi”
`• BRI of “Along With”
`• In Takahashi User_ID is not sent “Along With” the File.
`• BRI of GUI and GUI not present in Hiroshi, Takashi, and Ando
`• No Rationale/Motivation to combine Nozaki with Hiroishi for ‐ Delete GUI
`• Client Application ‐ Claims 5 and 8
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`2
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`Introduction Summary
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`Ex. 2009, ¶ 7
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`3
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`
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`Bluetooth Pairing, Authentication and Encryption are Distinct Issues and
`Each is Optional
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`Ex. 2006, pp. 19, 861
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`4
`
`
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`Bluetooth Pairing is Optionally Practiced and Optionally
`Supported
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`Ex. 2018, p. 1269
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`Ex. 2018, p. 1269
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`Ex. 2023, p. 16.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`5
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`
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`BRI of Paired Wireless Connection
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`Ex. 2009, ¶47
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`6
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`
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`BRI of Paired Wireless Connection –
`concept of “mutual agreement” to communicate
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`Ex. 1003, 3:60-4:25.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`7
`
`
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`BRI of Paired Wireless Connection –
`Bluetooth “Association” Models provide for optional encrypted data exchange and for
`optional pairing
`
`Ex. 1003/6:23-39
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Ex. 2006, p. ___
`
`8
`
`
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`BRI of Paired Wireless Connection –
`Bluetooth “Association” Models provide for optional encrypted data exchange and for
`optional pairing
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`ZIGBEE
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`The channel, PAN identifier, and network address
`of the local node and the target node are stored
`persistently in the pairing table.
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`Ex. 2003 (“Zigbee”), p. 6.
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`Ex. 2018, pp. 80, 135
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`9
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`
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`Canon’s CONSTRUCTIONS for Paired Wireless Connection
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`Ex. 1043, ¶¶97
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`Ex. 1003, ¶¶98, 228
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`Canon/Madisetti’s Petition Theory of Paired = Allows two-way communication
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`Canon/Madisetti’s Reply Theory of Paired = Association that allows two-way
`communication
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`10
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`
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`Hiroishi & Hollstrom Mentions Bluetooth but Do Not Disclose its
`Optional Pairing or any Other “Association” for Pairing
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`Ex. 1005 (Hirioshi), ¶66-67
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`Ex. 1013 (Hollstrom)/6:58-63
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`11
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`
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`Cryptographic Authentication ‐ BRI of Cryptographic Authentication
`Ex. 2009, ¶¶52-53.
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`Ex. 2009, ¶50
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`12
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`
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`Canon/Madisetti’s Petition Theory of Obviousness for Cryptographic
`Authentication is that “Cryptographic Authentication” was “Routine” in 2007
`and that a POSITA would desire “security”
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`Ex. 1003, ¶¶99-100, 229-230.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`13
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`
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`None of Exhibits 1017, 1019 or 1020 disclose or even discuss a camera
`cryptographically authenticating a cellular phone
`IT was NOT Routine in 2007 for a camera to Cryptographically Authenticate
`a mobile device
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`14
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`RATIONALE/MOTIVATION TO COMBINE “Cryptographic Authentication” with
`“Takashi” is ABSENT
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`Ex. 1008 (Takashi), ¶35
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`15
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`
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`BRI of “Along With”
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`Ex. 2009, p. 26
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`Ex. 2022, p. 1
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`16
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`
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`In Takahashi the User_ID is not sent “ALONG WITH” the File.
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`Ex. 1008 (Takashi), ¶¶32, 56, 66
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`17
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`
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`BRI of GUI
`wherein the graphical user interface (GUI) is … to delete the created new media file
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`Ex. 2009, ¶¶64-65
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`18
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`Ex. 2021, Fig. 3.
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`
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`GUI Used to Delete from Camera is Absent in Hiroshi, Takashi, and Ando
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`Ex. 1008 (Takahashi), Abstract
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`Ex. 1005 (Hiroishi), Fig. 7
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Ex. 1015 (Ando), 43 and Fig. 2
`19
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`
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`No Rationale/ Motivation to combine Nozaki with Hiroishi for “graphical user
`interface (GUI) … to delete the created new media file”
`Hiroishi automatically deletes the image from the camera after it is sent to the
`phone
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`Hiroishi - Ex. 1005, 106.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`20
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`
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`Client Application ‐ Claim 5
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`Ex. 1003, Claim 5
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`21
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`
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`Client Application ‐ Claim 8
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`Ex. 1003, Claim 8
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`22
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`
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`Client Application
`Claims 5 and 8
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`PANASONIC
`EX. 1003, Page 4
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`23
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`
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`Client Application ‐ Claims 5 and 8
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`24
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`
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`Claim 1 for Reference
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`Ex. 1003, Claim 1
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`25
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`
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`Claim 5 for Reference
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`Ex. 1003, Claim 5
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`26
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`
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`Claim 8 for Reference
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`Ex. 1003, Claim 8
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`27
`
`
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