Canon U.S.A., Inc. et al. v. Cellspin Soft, Inc.,
`IPR2019-00127
`Presentation of Petitioner Canon U.S.A., Inc.
`January 28, 2020
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`1
`
`
`IPR2019-00127
`Presentation of Petitioner Canon U.S.A., Inc.
`January 28, 2020
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`1
`
`
`
`Roadmap
`
`Overview of the Petition and Instituted Grounds
`
`Topic
`
`The Challenged Patent
`
`The State of the Art
`
`Claim Construction
`
`The Prior Art at Issue
`
`Obviousness of the Challenged Claims
`
`Motions to Strike
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`Page No.
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`3-4
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`5-12
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`13-17
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`18-49
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`50-55
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`56-108
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`109-116
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`2
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`
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`Overview of the Petition and
`Instituted Grounds
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`3
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`
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`Overview of the Petition and Instituted Grounds
`
`• Canon’s Petition was filed on October 30, 2018 and challenged claims 1-22 of the ‘698 Patent.
`
`• The Petition relied on the expert declaration of Dr. Vijay Madisetti, Ph.D. (Ex. 1003).
`
`• The Board instituted inter partes review on all proposed grounds.
`
`Ground
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`References
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`1
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`2
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`3
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`4
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`5
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`6
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`Hiroishi and Takahashi
`
`Hiroishi, Takahashi, and Ando
`
`Hiroishi, Takahashi, and Nozaki
`
`Hiroishi, Takahashi, Nozaki, and Ando
`
`Hollstrom and Takahashi
`
`Hollstrom, Takahashi, and Ando
`
`Basis
`
`§ 103
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`§ 103
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`§ 103
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`§ 103
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`§ 103
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`§ 103
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`Claims
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`1-20
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`21-22
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`1-22
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`21-22
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`1, 3-5, 7,8, 10-13, 15-20
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`2, 6, 9, 14, 21, 22
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`4
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`
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`The Challenged Patent
`U.S. Patent No. 9,258,698
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`5
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`
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`The ‘698 Patent: Overview
`
`Automatic Multimedia Upload for Publishing Data and Multimedia
`Content
`
`•
`
`Issued: February 9, 2016
`
`• Filed: November 5, 2014
`
`• Priority Claim: Provisional Application No. 61/017,202, filed
`December 28, 2007
`
`• Named Inventors: Gurvinder Singh, Marcos Klein, Vince Laviano
`
`• Assignee: Cellspin Soft, Inc.
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`Ex. 1001 at 1
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`6
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`
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`The ‘698 Patent: Background
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`7
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`Ex. 1001 at 1:50-55
`Pet. at 6
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`
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`The ‘698 Patent: Alleged Invention
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`8
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`Ex. 1001 at 1:56-62
`Pet. at 6
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`
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`The ‘698 Patent: Alleged Invention
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`9
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`Ex. 1001 at 2:5-11
`Pet. at 6
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`
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`The ‘698 Patent: Alleged Invention
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`10
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`Ex. 1001 at 9:42-51
`Pet. at 6
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`
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`The ‘698 Patent: Alleged Invention
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`11
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`Ex. 1001 at 8:48-55
`Pet. at 6
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`
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`The ‘698 Patent: Independent Claim 1
`
`[a] A machine-implemented method of media transfer, comprising:
`
`[b] for a digital camera device having a short-range wireless capability to connect with a cellular phone, wherein the cellular phone has access to the internet,
`performing in the digital camera device:
`
`[c] establishing a short-range paired wireless connection between the digital camera device and the cellular phone, wherein establishing the short-range
`paired wireless connection comprises, the digital camera device cryptographically authenticating identity of the cellular phone;
`
`[d] acquiring new-media, wherein the new-media is acquired after establishing the short-range paired wireless connection between the digital camera device and
`the cellular phone;
`
`[e] creating a new-media file using the acquired new-media;
`
`[f] storing the created new-media file in a first non-volatile memory of the digital camera device;
`
`[g] receiving a data transfer request initiated by a mobile software application on the cellular phone, over the established short-range paired wireless
`connection, wherein the data transfer request is for the new-media file, and wherein the new-media file was created in the digital camera device before receiving
`the data transfer request; and
`
`[h] transferring the new-media file to the cellular phone, over the established short-range paired wireless connection, wherein the cellular phone is configured
`to receive the new-media file, wherein the cellular phone is configured to store the received new-media file in a non-volatile memory device of the cellular phone,
`
`[i] wherein the cellular phone is configured to use HTTP to upload the received new-media file along with user information to a user media publishing
`website, and wherein the cellular phone is configured to provide a graphical user interface (GUI) in the cellular phone,
`
`[j] wherein the graphical user interface (GUI) is for the received new-media file and to delete the created new media file.
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`12
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`Ex. 1001 at Claim 1
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`
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`The State of the Art
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`13
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`
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`The State of the Art
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`The Bluetooth Basic Imaging Profile (Ex. 2023)
`
`• Released: July 30, 2003
`
`• Contributors: Canon, Casio, Fujifilm, HP, Microsoft, Toshiba
`
`• Abstract: This profile defines the requirements necessary for
`BluetoothTM devices to support the Basic Imaging Profile usage
`models. The requirements are expressed by defining the features,
`functions, and underlying profiles which are required for
`interoperability among Bluetooth devices in the Basic Imaging
`Profiles usage models.
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`Ex. 2023 at 1
`Reply at 11
`
`14
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`
`
`The State of the Art
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`15
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`Ex. 2023 at 13-14
`Reply at 11
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`
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`The State of the Art
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`16
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`Ex. 2023 at 13-14
`Reply at 11
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`
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`The State of the Art
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`17
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`Ex. 2023 at 16
`Reply at 11
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`
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`Claim Construction
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`18
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`
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`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`19
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`Ex. 1001 at claim 1
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`
`
`Claim Construction: “paired wireless connection”
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`Petitioner’s Position
`
`Patent Owner’s Position
`
`Plain and ordinary meaning.
`
`To a POSITA, in the context of the ‘698 patent
`and in other contexts as well, the BRI of a “paired
`connection” is a “bidirectional communications
`link between devices which provides encrypted
`data exchange between the devices, and the
`communication link can be disconnected and
`reconnected without having to repeat pairing or
`authentication.”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`Pet. at 17-18
`POR at 16
`Reply at 6-7
`
`20
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`
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`Claim Construction: “paired wireless connection”
`
`Petitioner’s Position
`
`Patent Owner’s Position
`
`Plain and ordinary meaning.
`
`To a POSITA, in the context of the ‘698 patent
`and in other contexts as well, the BRI of a “paired
`connection” is a “bidirectional communications
`link between devices which provides encrypted
`data exchange between the devices, and the
`communication link can be disconnected and
`reconnected without having to repeat pairing or
`authentication.”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`Pet. at 17-18
`POR at 16
`Reply at 6-7
`
`21
`
`
`
`Claim Construction: “paired wireless connection”
`
`Petitioner’s Position
`
`Patent Owner’s Position
`
`Plain and ordinary meaning.
`
`To a POSITA, in the context of the ‘698 patent
`and in other contexts as well, the BRI of a “paired
`connection” is a “bidirectional communications
`link between devices which provides encrypted
`data exchange between the devices, and the
`communication link can be disconnected and
`reconnected without having to repeat pairing or
`authentication.”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`Pet. at 17-18
`POR at 16
`Reply at 6-7
`
`22
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`
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`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`23
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`POR at 15-16
`Reply at 3-7
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`
`
`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`24
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`POR at 15-16
`Reply at 3-7
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`
`
`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`25
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`POR at 15-16
`Reply at 3-7
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`
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`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`26
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`Ex. 1001 at 9:42-51, Claim 19
`Reply at 3-7
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`
`
`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`27
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`Ex. 1001 at 3:63-67
`Reply at 3-7
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`
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`Claim Construction: “paired wireless connection”
`
`“[W]e conclude that the district court erroneously construed ‘perforated’ using
`extrinsic evidence that contradicts the intrinsic evidence of record.”
`
`Advanced Fiber Techs. Trust v. J&L Fiber Services, Inc., 674 F.3d 1365, 1374-75 (Fed. Cir. 2012)
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`Pet. at 17-18
`POR at 16
`Reply at 3-7
`
`28
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`
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`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`Ex. 1039 at 21
`Reply at 3-7
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`29
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`
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`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`Ex. 1036
`Reply at 3-7
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`30
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`
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`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`Ex. 1043 ¶ 5
`Reply at 3-7
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`31
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`
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`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`32
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`Ex. 1040 at 45:6-19
`Reply at 3-7
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`
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`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`33
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`Ex. 1040 at 19:5-11
`Reply at 3-7
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`
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`Claim Construction: “paired wireless connection”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`34
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`Ex. 1040 at 19:12-15
`Reply at 3-7
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`
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`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`35
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`Ex. 1040 at 19:16-20:3
`Reply at 3-7
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`
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`Claim Construction: “paired wireless connection”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`36
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`Ex. 1040 at 19:16-20:3
`Reply at 3-7
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`
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`Claim Construction: “paired wireless connection”
`
`“[C]ourts can neither broaden nor narrow claims to give the patentee something
`different than what he has set forth.”
`
`Texas Instruments Inc. v. U.S. Int’l Trade Comm’n, 988 F.2d 1165, 1171 (Fed. Cir. 1993)
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`Pet. at 17-18
`POR at 16
`Reply at 6-7
`
`37
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`
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`Claim Construction: “cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`38
`
`Ex. 1001 at claim 1
`
`
`
`Claim Construction: “cryptographically authenticating”
`
`Petitioner’s Position
`
`Consistent with the Board’s Institution Decision,
`“cryptographically authenticating” encompasses
`“authenticating the identity of the cellular phone
`using some form of security or encryption,
`including by use of a shared passkey on the
`digital camera device and the cellular phone.”
`
`Patent Owner’s Position
`“The BRI of “cryptographically authenticated” is
`verified as a legitimate transmission, user, or
`system including by use of encryption and
`decryption involving an algorithm.”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`POR at 21
`Reply at 7
`
`39
`
`
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`Claim Construction: “cryptographically authenticating”
`
`Petitioner’s Position
`
`Consistent with the Board’s Institution Decision,
`“cryptographically authenticating” encompasses
`“authenticating the identity of the cellular phone
`using some form of security or encryption,
`including by use of a shared passkey on the
`digital camera device and the cellular phone.”
`
`Patent Owner’s Position
`“The BRI of “cryptographically authenticated” is
`verified as a legitimate transmission, user, or
`system including by use of encryption and
`decryption involving an algorithm.”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`POR at 21
`Reply at 7
`
`40
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`
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`Claim Construction: “cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`41
`
`Ex. 1001 at 4:65-67
`Reply at 7
`
`
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`Claim Construction: “graphical user interface”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`42
`
`Ex. 1001 at claim 1
`
`
`
`Claim Construction: “graphical user interface”
`
`Petitioner’s Position
`
`Plain and ordinary meaning.
`
`Patent Owner’s Position
`“the BRI of a graphical user interface (i.e., “GUI”)
`is “an interface through which a user interacts
`with electronic devices such as computers, hand-
`held devices and other appliances. This interface
`uses icons, menus and other visual indicator
`(graphics) representations to display information
`and related user controls, unlike text-based
`interfaces, where data and commands are in
`text. GUI representations are manipulated by a
`pointing device such as a mouse, trackball,
`stylus, or a finger on a touch screen.”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`POR at 21
`Reply at 8
`
`43
`
`
`
`Claim Construction: “graphical user interface”
`
`Petitioner’s Position
`
`Plain and ordinary meaning.
`
`Patent Owner’s Position
`The BRI of a graphical user interface (i.e., “GUI”)
`is “an interface through which a user interacts
`with electronic devices such as computers, hand-
`held devices and other appliances. This interface
`uses icons, menus and other visual indicator
`(graphics) representations to display information
`and related user controls, unlike text-based
`interfaces, where data and commands are in
`text. GUI representations are manipulated by a
`pointing device such as a mouse, trackball,
`stylus, or a finger on a touch screen.”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`POR at 21
`Reply at 8
`
`44
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`
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`Claim Construction: “graphical user interface”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`45
`
`Ex. 1001 at 6:25-30
`Fig. 2
`
`
`
`Claim Construction: “graphical user interface”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`46
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`Ex. 1040 at 105:2-8
`Reply at 3-7
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`
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`Claim Construction: “along with”
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`47
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`Ex. 1001 at claim 1
`
`
`
`Claim Construction: “along with”
`
`Petitioner’s Position
`
`Patent Owner’s Position
`
`Plain and ordinary meaning.
`
`The BRI of a “along with” is “in addition to
`(something or someone).”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`48
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`POR at 22-23
`Reply at 8-9
`
`
`
`Claim Construction: “along with”
`
`“[C]ourts can neither broaden nor narrow claims to give the patentee something
`different than what he has set forth.”
`
`Texas Instruments Inc. v. U.S. Int’l Trade Comm’n, 988 F.2d 1165, 1171 (Fed. Cir. 1993)
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`49
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`POR at 22-23
`Reply at 8-9
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`
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`Asserted Prior Art
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`50
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`
`
`JP Patent Publication No. 2003-60953 to Hiroishi
`
`Photographing System, Photographing Method, Camera, Recording
`Medium, and Program
`
`• Published: February 28, 2003
`
`• Filed: August 15, 2001
`
`• Named Inventor: Toshiyuki Hiroishi
`
`• Assignee: Fuji Photo Film Co., Ltd.
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`Ex. 1005
`
`51
`
`
`
`U.S. Patent No. 6,763,247 to Hollstrom
`
`Portable Telecommunication Apparatus for Controlling an Electronic
`Utility Device
`
`•
`
`Issued: July 13, 2004
`
`• Filed: November 17, 2000
`
`• Named Inventors: Magnus Hollstrom, Robert Hed, Patrik Olsson,
`Anders Edlund, Björn Ekelund, Nils Rydbeck
`
`• Assignee: Telefonaktiebolaget LM Ericsson
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`Ex. 1013
`
`52
`
`
`
`JP Patent Publication No. 2005-303511 to Takahashi
`
`Image Storage System, Mobile Terminal, Image Storage Device, Image
`Storage Method, Image Transmission Program, and Image Storage
`Program
`
`• Published: October 27, 2005
`
`• Filed: April 8, 2004
`
`• Named Inventors: Takahashi Susumu, Toshikazu Ito
`
`• Assignee: Logic, K.K.
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`Ex. 1008
`
`53
`
`
`
`JP Patent Publication No. 2003-46841 to Ando
`
`Simple Digital Camera and Image Ordering Method Using Such
`
`• Published: February 14, 2003
`
`• Filed: July 30, 2001
`
`• Named Inventor: Shigeru Ando
`
`• Assignee: Fuji Photo Film Co. Ltd.
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`Ex. 1015
`
`54
`
`
`
`JP Patent Publication No. 2004-96166 to Nozaki
`
`Electronic Camera and Electronic Camera System
`
`• Published: March 25, 2004
`
`• Filed: August 29, 2002
`
`• Named Inventor: Hirotake Nozaki
`
`• Assignee: Nikon Corporation
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`Ex. 1011
`
`55
`
`
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`Obviousness of the Challenged Claims
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`56
`
`
`
`“establishing a short-range paired wireless connection between
`the digital camera device and the cellular phone, wherein
`establishing the short-range paired wireless connection
`comprises, the digital camera device cryptographically
`authenticating identity of the cellular phone”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`57
`
`
`
`JP Patent Publication No. 2003-60953 to Hiroishi
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`Ex. 1005 at (0066)
`Pet. at 23-24
`Ex. 1003 ¶ 96
`
`58
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`
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`JP Patent Publication No. 2003-60953 to Hiroishi
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`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`59
`
`Ex. 1005 at (0072); Fig 5
`Pet. at 23-24
`Ex. 1043 at 15:21-16:9
`
`
`
`JP Patent Publication No. 2003-60953 to Hiroishi
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`60
`
`Ex. 1005 at [0091]-[0092]; Figs. 5-6
`Pet. at 23-24
`Ex. 1043 at 15:21-16:9
`
`
`
`JP Patent Publication No. 2003-60953 to Hiroishi
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`61
`
`Ex. 1005 at Fig. 1
`Pet. at 23-24
`Ex. 1003 ¶ 96
`
`
`
`JP Patent Publication No. 2003-60953 to Hiroishi
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`62
`
`Ex. 1042 at 14:20-15:6; 15:21-16:9
`Pet. at 23-24
`Reply at 9
`
`
`
`JP Patent Publication No. 2003-60953 to Hiroishi
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`63
`
`Ex. 1042 at 13:12-19
`Pet. at 23-24
`Reply at 9
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`Ex. 1043 ¶ 11
`Reply at 9
`
`64
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`
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`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`65
`
`Ex. 1040 at 12:1-14
`Reply at 9
`
`
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`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`66
`
`Ex. 1040 at 12:15-23
`Reply at 9
`
`
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`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
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`67
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`Ex. 1040 at 12:15-23
`Reply at 9
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`68
`
`Ex. 2023 at 16
`Reply at 11
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`69
`
`Ex. 1043 at ¶ 11
`Reply at 10
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`Ex. 1017 at 6
`Pet. at 24
`
`70
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`71
`
`Ex. 1019 at [0055]
`Pet. at 24
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`72
`
`Ex. 1020 at [0019]
`Pet. at 24
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`73
`
`Ex. 1018 at 148
`Pet. at 24-25
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`74
`
`Ex. 2018 at 1273
`Reply at 15
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`75
`
`Ex. 1040 at 57:12-22
`Reply at 15
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`Ex. 1039 at 18
`Ex. 1040 at 66:8-19
`Reply at 15-16
`
`76
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`77
`
`Ex. 1040 at 66:8-19
`Reply at 16
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`78
`
`Ex. 1040 at 66:20-67:10
`Reply at 16
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`79
`
`Ex. 1036 at 9
`Reply at 16
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`80
`
`Ex. 1040 at 64:24-65:14
`Reply at 16
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`81
`
`Ex. 1039 at 16
`Reply at 17
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`82
`
`Ex. 1042 at 31:1-32:9
`Reply at 17
`
`
`
`“Establishing a paired wireless connection … cryptographically authenticating”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`83
`
`Ex. 1040 at 25:6-12
`Reply at 17
`
`
`
`“wherein the cellular phone is configured to use HTTP to
`upload the received new-media file along with user
`information to a user media publishing website”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`84
`
`
`
`JP Patent Publication No. 2005-303511 to Takahashi
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`85
`
`Ex. 1008 at (0062), Abstract, (0052), (0037), (0063)
`Pet. at 32
`
`
`
`JP Patent Publication No. 2005-303511 to Takahashi
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`86
`
`Ex. 1008 at (0062), Abstract, (0052), (0037), (0063)
`Pet. at 32
`
`
`
`“wherein the cellular phone is configured to use HTTP …”
`
`Ex. 1005 (Hiroishi) at (0044)
`Pet. at 53
`
`Ex. 1013 (Hollstrom) at 6:18-24
`Pet. at 78
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`87
`
`
`
`“wherein the cellular phone is configured to use HTTP …”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`88
`
`Ex. 1003 ¶ 206
`
`
`
`“wherein the cellular phone is configured to use HTTP …”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`89
`
`Ex. 1023 at 1:44-47
`Pet. at 52
`
`
`
`“wherein the cellular phone is configured to use HTTP …”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`90
`
`Ex. 1028 at 1:17-21
`Pet. at 52
`
`
`
`“wherein the cellular phone is configured to use HTTP …”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`91
`
`Ex. 1008 at Abstract
`Pet. at 53
`
`
`
`“Graphical User Interface”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`92
`
`
`
`“Graphical User Interface”
`
`Ex. 1005 (Hiroishi) at Fig. 7(D); Pet. at 33; Reply at 21-23
`
`Ex. 1015 (Hollstrom) at Fig. 2; Reply at 21-23
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`93
`
`
`
`“wherein the graphical user interface (GUI) is for the
`received new-media file and to delete the created new
`media file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`94
`
`
`
`“wherein the graphical user interface (GUI) is for the received new-media file
`and to delete the created new media file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`95
`
`Ex. 1015 at [0043]
`Pet. at 54
`
`
`
`“wherein the graphical user interface (GUI) is for the received new-media file
`and to delete the created new media file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`96
`
`Ex. 1015 (Ando) at Abstract
`Pet. at 55
`
`
`
`“wherein the graphical user interface (GUI) is for the received new-media file
`and to delete the created new media file”
`
`Ex. 1005 (Hiroishi) at (0017)
`Pet. at 33, 55
`
`Ex. 1013 (Hollstrom) at 6:29-39
`Pet. at 62, 80
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`97
`
`
`
`“wherein the graphical user interface (GUI) is for the received new-media file
`and to delete the created new media file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`98
`
`Ex. 1003 ¶ 211
`
`
`
`“wherein the graphical user interface (GUI) is for the received new-media file
`and to delete the created new media file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`99
`
`Ex. 1003 ¶ 212
`
`
`
`“…to delete the created associated file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`100
`
`Ex. 1011 at Abstract
`Pet. at 56
`
`
`
`“…to delete the created associated file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`101
`
`Ex. 1011 at [0013]
`Pet. at 56
`
`
`
`“…to delete the created associated file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`102
`
`Ex. 1011 at [0028], [0031]
`Pet. at 57
`
`
`
`“…to delete the created associated file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`103
`
`Ex. 1011 at [0031]
`Pet. at 57
`
`
`
`“…to delete the created associated file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`104
`
`Ex. 1011 at Abstract
`Pet. at 57
`
`
`
`“…to delete the created associated file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`105
`
`Ex. 1005 (Hiroishi) at (0017)
`Pet. at 33, 58
`
`
`
`“…to delete the created associated file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`Ex. 1003 ¶ 219
`
`106
`
`
`
`“…to delete the created associated file”
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`107
`
`Ex. 1015 at [0043]
`Pet. at 59
`
`
`
`“…to delete the created associated file”
`
`Ex. 1005 (Hiroishi) at (0017)
`Pet. at 33, 59
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`108
`
`Ex. 1011 at [0031]
`Pet. at 57, 59
`
`
`
`Canon’s Motion to Strike
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`109
`
`
`
`Canon’s Motion to Strike
`
`
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCEPETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`110
`
`Paper No. 29 at 1 (Patent Owner’s Sur-Reply) at v
`
`
`
`Canon’s Motion to Strike
`
`
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCEPETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`111
`
`Trial Practice Guide at 73-74
`
`
`
`Canon’s Motion to Strike
`
`• Highly prejudicial to Canon:
`
`• No opportunity to depose Cellspin’s expert witness on his new opinions
`
`• No opportunity to address Cellspin’s new evidence in briefing
`
`• No due process:
`
`• Canon’s only opportunity to address the new factual assertions is at the hearing
`
`• No justification for late submission of evidence:
`
`• New evidence designed to correct deficiencies in the constructions presented in Cellspin’s POR
`
`• Permitting Cellspin’s conduct would encourage patent owners to file unauthorized sur-reply evidence
`
`• Remedy – Board has struck new sur-reply evidence in similar circumstances
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`112
`
`Canon’s Motion to Strike at 6-14
`
`
`
`Cellspin’s Motion to Strike
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`113
`
`
`
`Cellspin’s Motion to Strike
`
`
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCEPETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`114
`
`Trial Practice Guide at 81
`
`
`
`Cellspin’s Motion to Strike
`
`Canon Inc. v. Intellectual Ventures II LLC, IPR 2014-00631, Paper 50 at 51
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`115
`
`
`
`Cellspin’s Motion to Strike
`
`Canon Inc. v. Intellectual Ventures II LLC, IPR 2014-00631, Paper 50 at 51
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS – NOT EVIDENCE
`
`116
`
`
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