UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`PANASONIC CORPORATION AND PANASONIC CORPORATION
`OF NORTH AMERICA
`Petitioners,
`
`v.
`
`CELLSPIN SOFT, INC.
`Patent Owner.
`
`CASE: IPR2019-001311
`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 29.
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`PANASONIC CORPORATION AND PANASONIC CORPORATION
`OF NORTH AMERICA
`Petitioners,
`
`v.
`
`CELLSPIN SOFT, INC.
`Patent Owner.
`
`CASE: IPR2019-001311
`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 29.
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`Pursuant to 37 C.F.R. § 42.70(b) and the Trial Hearing Order dated December 23, 2019
`
`IPR2019-00131
`U.S. Pat. No. 9,258,698
`
`(Paper 43), 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 21, 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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`IPR2019-00131
`U.S. Pat. No. 9,258,698
`
`CERTIFICATE OF SERVICE
`
`the herein
`that a copy of
`The undersigned hereby certifies
`DEMONSTRATIVE EXHIBITS is being served in its entirety on January 21,
`2020, upon the following parties via electronic service:
`
`David T. Xue
`Karineh Khachatourian
`Rimon Law
`2479 East Bayshore Road, Suite 210
`Palo Alto, CA 94303
`david.xue@rimonlaw.com
`karinehk@rimonlaw.com
`
`Jennifer C. Bailey
`Adam P. Seitz
`Erise IP, P.A.
`7015 College Boulevard, Suite 700
`Overland Park, KS 66211
`jennifer.bailey@eriseip.com
`adam.seitz@eriseip.com
`PTAB@eriseip.com
`
`Attorneys for Petitioners GoPro, Inc. Garmin International, Inc., and Garmin
`USA, Inc.
`
`T. Vann Pearce, Jr.
`Orrick, Herrington & Sutcliffe, LLP
`1152 15th Street, N.W.
`Washington, D.C. 20005-1706
`vpearce@orrick.com
`
`David R. Medina
`Orrick, Herrington & Sutcliffe, LLP
`1000 Marsh Road
`Menlo Park, CA 94025
`dmedina@orrick.com
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`Attorneys for Petitioners Panasonic Corporation of North America and
`Panasonic Corporation
`
`/s/ John J. Edmonds
`John J. Edmonds
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`2
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`PANASONIC CORPORATION OF NORTH AMERICA, ET AL.
`Petitioners
`
`v.
`
`CELLSPIN SOFT, INC.
`Patent Owner
`
`______________________
`
`Patent No. 9,258,698
`Inter Partes Review No. 2019‐00131
`
`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
`• Strawn’s Conception of Paired Wireless Connection
`• Mashita, Hirashi & Onichi Mentions Bluetooth But Do Not Disclose its Optional Pairing
`• Mashita Uses a PIN for “Authentication” Not Pairing
`• Mashita’s “terminate link(s)” are contrary to a paired connection
`• BRI of Cryptographic Authentication
`• Mashita does NOT disclose “Cryptographic Authentication”
`• Pairing without Authentication
`• Limitation G is not met by Mashita & the Combination of Mashita’s camera with Hirashi will NOT work
`• Mashita Does Not Disclose HTTP Image Transfer from the Phone
`• Mashita Teaches Away from HTTP Image Transfer from the Phone
`• Mashita FTP to HTTP is not a simple substitution
`• BRI of GUI and Onishi’s cellular phone 150 does not have a GUI
`• Client Application ‐ Claims 5 and 8
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`2
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`
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`Introduction Summary
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`Ex. 2009, ¶ 7
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`
`
`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
`
`
`
`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, ¶46
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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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`
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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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`Ex. 1003/6:23-39
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Ex. 2006, p. 80
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`8
`
`
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`BRI of Paired Wireless Connection –
`Bluetooth “Association” Models provide for optional encrypted data exchange and for
`optional pairing
`
`ZIGBEE
`
`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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`Strawn’s Conception of Paired Wireless Connection
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`Ex. 2030, p. 15
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`10
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`
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`Mashita Mentions Bluetooth But Does Not Disclose its Optional Pairing
`Panasonic/Strawn’s Petition Theory of Paired for Mashita:
`
`Ex. 1001 (Strawn Declaration), ¶¶75-76, 80
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`11
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`
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`Onishi Mentions Bluetooth But Does Not Disclose its Optional Pairing
`Panasonic/Strawn’s Theory of Paired for Onishi:
`
`Ex. 1001, ¶¶77, 80
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`12
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`
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`Hiraishi Mentions Bluetooth But Does Not Disclose its Optional Pairing
`Panasonic/Strawn’s Theory of Paired for Hiraishi
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`Ex. 1001, ¶¶78, 80
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`13
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`Mashita Uses a PIN for “Authentication” Not Pairing
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`Ex. 1006 (Mashita), ¶¶51, 94
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`14
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`Mashita’s “terminate link(s)” are contrary to a paired connection
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`Ex 1006, Fig 7
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`Ex 1006, Fig. 6
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`15
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`
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`Mashita’s “terminate link(s)” are contrary to a paired connection
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`Ex. 2018, page 160-161
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`Ex. 2018, page 174-175
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`16
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`
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`BRI of Cryptographic Authentication
`Ex. 2009, ¶¶52-53.
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`…
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`Ex. 2009, ¶¶ 49-50
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`…
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`17
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`
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`Mashita does NOT disclose “Cryptographic Authentication”
`Cryptographic Authentication ≠ Secrecy
`Panasonic/Strawn’s Petition Theory for Cryptographic Authentication = Secrecy
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`Ex. 2001 (Strawn Declaration), ¶¶83‐85
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`18
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`
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`Mashita does NOT disclose “Cryptographic Authentication”
`Mashita’s PIN is Not a Passkey
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`Ex. 2006, pp. 134-135
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`19
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`
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`Mashita does NOT disclose “Cryptographic Authentication”
`Mashita states that only the physical device addresses are stored
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`Physical Device Address
`IS NOT
`Cryptographic
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`Ex. 1006, ¶¶30 & 94
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`20
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`
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`Pairing without Authentication
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`Ex. 2006, pp. 865-867
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`Pairing
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`Authentication
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`• Authentication is optional for Pairing
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`Ex. 2006, p. 696
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`21
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`
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`Limitation G, is not met by Mashita and the Combination of Mashita’s camera
`with Hirashi will NOT work:
`G : “receiving a data transfer request initiated by a mobile software application on the cellular phone, over
`the established short‐range paired wireless connection”
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`Ex. 1006, Fig. 7
`
`In Mashita’s Fig. 7, there is NO waiting state for the camera, to wait for the request from the mobile device. Combination of
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`Mashita camera with Hirashi will NOT work.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`22
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`Ex. 2018, p. 161
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`
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`Mashita Does Not Disclose HTTP Image Transfer from the Phone
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`Ex. 1001 (Strawn Decl.), ¶¶37
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`Ex. 1006, ¶82
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`Ex. 1006, ¶89
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`23
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`
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`Mashita Teaches Away from HTTP Image Transfer from the Phone
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`24
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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. 2021, Fig. 3.
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`Ex. 2009, ¶¶65-66
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`25
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`
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`Onishi’s cellular phone 150 does not have a GUI
`Mode selection button 55 is used to toggle modes and the button group 59 is just a keyboard
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`Ex. 1008, ¶40
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`26
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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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`27
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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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`28
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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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`29
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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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`30
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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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`31
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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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`32
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`Claim 8 for Reference
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`Ex. 1003, Claim 8
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`33
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`
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