Paper No. 25
`Trials@uspto.gov
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`571-272-7822
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT AND TRIAL APPEAL BOARD
`______________
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`APPLE, INC.,
`Petitioner,
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`v.
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`UUSI, LLC d/b/a NARTRON,
`Patent Owner.
`_____________
`
`IPR2019-00358 and IPR2019-00359
`Patent 5,796,183
`_____________
`
`Record of Oral Hearing
`Held Virtually: Thursday, May 7, 2020
`_____________
`
`
`Before BRYAN F. MOORE, MINN CHUNG, and
`NORMAN H. BEAMER, Administrative Patent Judges.
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`Trials@uspto.gov
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`571-272-7822
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT AND TRIAL APPEAL BOARD
`______________
`
`APPLE, INC.,
`Petitioner,
`
`v.
`
`UUSI, LLC d/b/a NARTRON,
`Patent Owner.
`_____________
`
`IPR2019-00358 and IPR2019-00359
`Patent 5,796,183
`_____________
`
`Record of Oral Hearing
`Held Virtually: Thursday, May 7, 2020
`_____________
`
`
`Before BRYAN F. MOORE, MINN CHUNG, and
`NORMAN H. BEAMER, Administrative Patent Judges.
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`IPR2019-00358 and IPR2019-00359
`Patent 5,796,183
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`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`W. KARL RENNER, ESQUIRE
`JEREMY MONALDO, ESQUIRE
`RYAN CHOWDHURY, ESQUIRE
`FISH & RICHARDSON PC
`1000 Maine Avenue, SW
`Washington, DC 20024
`
`
`
`DANIEL D. SMITH, ESQUIRE
`FISH & RICHARDSON PC
`1717 Main Street
`Dallas, TX 75201
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`LAWRENCE M. HADLEY, ESQUIRE
`GLASER WEIL, LLP
`10250 Constellation Boulevard
`Suite 1900
`Los Angeles, CA 90067
`
`STEVE UNDERWOOD, ESQUIRE
`JOSEPH A. RHOA, ESQUIRE
`JONATHAN A. ROBERTS, ESQUIRE
`NIXON & VANDERHYE, PC
`901 North Glebe Road
`Suite 1100
`Arlington, VA 22203
`
`
`
`The above-entitled matter came on for hearing on Thursday, May 7,
`2020, commencing at 12:01 p.m. EST, by video/by telephone.
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`IPR2019-00358 and IPR2019-00359
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`P R O C E E D I N G S
` JUDGE CHUNG: Good morning. This is a
`trial hearing in cases IPR2019-00358 and 00359,
`Apple, Inc. versus UUSI, LLC.
` I am Judge Chung, and with me on the video
`are Judges Beamer and Moore.
` So, starting with petitioner, will counsel
`for each party please introduce yourselves.
` MR. RENNER: Yes, your Honor. This is
`Karl Renner. I'm joined by Jeremy Monaldo, Dan
`Smith, and Ryan Chowdhury, and also on the phone
`is Aaron Fromme from Apple.
` JUDGE CHUNG: Wonderful. Good morning or
`good afternoon.
` Who do we have online for patent owner?
` MR. HADLEY: Good morning, your Honor.
`This is Lawrence Hadley for the respondent patent
`owner. I will be the only one appearing on the
`video and making the argument this morning, but
`with us on the phone are Counsel Steve Underwood,
`Joseph Rhoa, and Jonathan Roberts.
` JUDGE CHUNG: Wonderful. Welcome,
`everyone. Again, good morning or good afternoon.
` As you are all aware, this oral argument
`is being conducted by video today. As outlined in
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`the trial hearing order in these cases, each party
`will have 60 minutes of total argument time.
`Petitioner will argue first and may reserve up to
`half of their time for rebuttal. And patent owner
`will then respond and may also reserve time for
`their own rebuttal or sur-rebuttal.
` Just remind you that this hearing is open
`to the public, and a full transcript of today's
`proceeding will be part of the record.
` A few reminders before we begin. First is
`that because this is a video hearing with everyone
`having live microphones, I ask the parties and
`counsel to please mute yourselves except when it's
`your turn to speak.
` And next, about the slides, we received
`your presentation slides and have copies of them
`available to us during the hearing, but because --
`again, because this is a video hearing where
`there's no slide projected on the projector,
`during your presentation, please make sure to
`refer to slides by slide number to help us follow
`your presentation.
` And the last thing is -- is to please do
`not interrupt the other side's presentation to
`raise objections. Rather, raise the issues during
`your own presentation. This is probably less of
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`an issue on a video hearing than a live hearing
`but, still, I thought it would be a good thing to
`remind people not to interrupt each other.
` So, are there any questions from the
`parties, from counsel, before we begin?
` If not --
` MR. RENNER: No question.
` JUDGE CHUNG: Sure.
` MR. RENNER: Oh, no, I was indicating no
`questions.
` JUDGE CHUNG: No questions. Yeah.
` I think the audio is -- can be a little
`delayed, and I will keep that in mind.
` So, if no questions, counsel for
`petitioner, you may proceed.
` How much time would you like to reserve
`for rebuttal?
` MR. RENNER: Thank you, your Honor. We'll
`reserve 25 minutes.
` JUDGE CHUNG: 25 minutes. All right. You
`may proceed.
` MR. RENNER: Thank you.
` Your Honors, slide 1, if we could, in our
`presentation materials, just to get us started,
`the '183 patent, it relates, as you're all aware,
`to the press and touch technology and the
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`technology that's really been used for some time
`really dating back into the seventies.
` If we turn to slide 3, just to reorient us
`a little more, six different grounds were advanced
`in the petition -- two petitions, 358 and 359, to
`address the various claims that are at issue here.
` Today our intention is to focus on
`primarily the independent claims. And for
`convenient reference, note that we'll -- we'll
`refer to the 358 proceeding, unless we indicate
`otherwise.
` It might also be helpful for you to have
`available the federal circuit appendix version
`that was cited in briefing. We'll make some
`reference into that, as well. It's an important
`issue as it relates to the claim construction.
` Slide 4, speaking of which, in slide 4 we
`just summarized the three items that we knew we
`wanted to discuss with you in the direct
`presentation. Obviously, we're open to any
`questions you may have. Our point is to make sure
`we're addressing your questions.
` But given our druthers, we've addressed
`these three issues, the first being claim
`construction; the next two being different
`combinations, one with the Chiu and Schwarzbach
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`combination and its relationship to Claim 37, and
`the other being the addition to Meadows -- of
`Meadows to that combination.
` Slide 5 gets us sort of into the three
`issues, and it's the issue of claim construction
`that is framed here in slide 5. With respect to
`that issue, the claim term in question,
`"selectively providing signal output frequencies,"
`appears in each of the contested independent
`claims in question.
` We, in slide 6, reproduced just for
`convenient reference representative claim 94 as it
`relates to this. And in claim 6, what we have
`shown here is the -- in highlighting the construed
`language. We're reminded that the relevant
`language fits within the claim calling for a
`microcontroller that selectively provides, and it
`provides a frequency -- signal output frequencies
`to an array of input touch terminals of a keypad.
` Notably, this language was promoted within
`the petition for construction, you may recall, and
`that it also was addressed in the POPR that was
`put in by the patent owner where they offered an
`alternative construction, and it was addressed in
`the institution decision with roughly ten pages of
`analysis that included reference to the federal
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`circuit opinion which has come out six weeks prior
`to the institution sitting.
` In the analysis that was provided, that
`ten-pages analysis, several points were
`particularly noteworthy. First, in explaining
`plain meaning, the basis in plain meaning for the
`language that is here, it was remarked that the
`claims, they recite "selectively providing
`reference -- frequencies," "selectively providing"
`being the keyword, so the "selectively" word
`modifies the word "providing," and that the claims
`do not recite the said -- accurately -- they don't
`recite providing selected frequencies. It's not
`about the selection of frequencies is the -- what
`we take away.
` Your Honors, we maintain that position and
`we'll talk more about it, but, additionally, other
`noteworthy points were made there. With reference
`made to claims 96 and 97, for instance, and the
`need for consistency among the claims, where claim
`96, from it we know that the independent claims
`have -- have to accommodate a single frequency
`that's applied to an array or array rows of the
`touch pad.
` We know that was stated in the passive
`voice but, nevertheless, the requirement there was
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`for a single frequency to be applied and the
`frequencies.
` Claim 97 is called and said for a
`plurality of Hertz values to be applied. So, when
`it's talking about the two claims in combination
`being both dependent on 94, we know that the
`language in 94 and in the other independent claims
`that mimic that language need to accompany both
`the provision of the single frequency, if you
`will, hertz and also multiple different
`frequencies at hertz.
` Final note on that is the last part of
`claim 97, it states in language, it's quite
`interesting, I'm just going to read out loud what
`that is just, again, to refresh recollection, it
`says, "selected from a plurality of hertz values,"
`when talking about this signal output frequency.
` So, in that claim, there's a call for the
`signal output frequency to be selected from a
`plurality of hertz values. That language makes
`very clear that when this patent owner wanted to
`call for a selection of frequency values from a
`plurality of potential frequency values, it knew
`how to say that, and the words it used were not
`the words "selectively provided" or "providing" or
`any modification of "providing" with the word
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`"selectively."
` With that, slide 7, please, if we could,
`slide 7 shows the results of the analysis that the
`board has undergone and that's advantageous, and
`in the uppermost -- left uppermost box, it says
`that the claims language in question, it does not
`require the microcontroller to select signal
`output frequencies from multiple available
`frequencies.
` So, again, the reason, because, after all,
`the independent claim doesn't speak of
`"selectively" in terms of the context of selecting
`the frequencies.
` And then it says affirmatively in the
`lower box, highlighted, that the microcontroller
`does -- is involved in selecting a row or a
`portion of the array of the touch pad. So, that
`is what the claim does, in fact, call for.
` Now, this is all not newsworthy to you.
`This is really straightaway and consistent with
`the institution decision, the briefing has
`maintained itself there, in our view. And Nartron
`really says little about most of the analysis that
`is here. Instead, Nartron, it seeks to change
`that analysis. It seeks to look past that
`analysis by, instead, focusing on the federal
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`circuit appeal that had come in.
` And with that, I'd go to slide 10 to focus
`our attention on what that appeal does and what
`that appeal doesn't actually say and how it
`affects things.
` The Samsung appeal, Samsung versus Nartron
`rule, the subject of this appeal, it involved
`reasonable expectation of success and motivation
`to combine. The issue there implicating
`reasonable expectation of success, we know from
`Illumina that that means that the challenger must
`show a reasonable expectation of achieving what is
`claimed in the patent in suit, and the federal
`circuit reminded that in its opinion.
` Now, Samsung, looking upon that, they
`complained that the board has unduly limited the
`claim scope, and they asked the federal circuit to
`take a look at that because, with the narrow claim
`scope that was in front or on the table,
`reasonable expectation of success was harder to
`achieve.
` The federal circuit acknowledged an
`implicit claim construction by the board, and it
`evaluated that construction to determine whether
`the board was justified in resolving that there
`did not exist a reasonable expectation of success.
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` Now, that implicit -- yes?
` JUDGE BEAMER: I know that the federal
`circuit talked about an implicit claim
`construction, but I was unable to find anything in
`the record of the other case where there was any
`such implicit claim construction.
` What was the basis -- do you have an
`understanding of where they -- how they came to
`that characterization of the opinion they were
`reviewing?
` MR. RENNER: It's a good question. The
`answer is no, actually. We -- we looked at that,
`and we were trying to dig in and discern that
`ourselves and, ultimately, it was difficult to
`find that.
` So, knowing that in this case what we have
`is the construction that we believe is supported
`by the plain meaning, by comparison, by even the
`specification if taken alone and, again, the
`institution decision did a fine job of setting all
`that forward in this case, and that the federal
`circuit was -- their opinion was only being relied
`upon by Nartron to offset all of that analysis, we
`spent our time really analyzing as if the federal
`circuit was correct in this analysis that there
`was an implicit construction, but I agree with you
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`it was challenging to resolve that.
` Did I address your question, your Honor?
` JUDGE BEAMER: Yes. Please proceed.
` MR. RENNER: Thank you. So, with that in
`mind, the construction that was in question,
`according to the federal circuit, was that the
`board had concluded the claims require that the
`microcontroller provides different frequencies to
`different rows of the touch pad. That's what the
`federal circuit had indicated was the result of
`the analysis down different frequencies to
`different rows of touch pad.
` This construction the board concluded, it
`has undermined the combination of Gerpheide,
`that's our associate, with Ingraham and Caldwell.
`They said that it would not be possible for a
`sequence to occur through each touch pad to
`differentiate between neighboring touch pads and,
`therefore, there is no reasonable expectation of
`success.
` You notice in that analysis that what
`they're talking about is the progression of
`selection of touch pad, either array rows or touch
`pads themselves. They're not talking about
`differentiation or the selection of frequency.
` In framing the appeal, actually, the
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`parties, they never asked the federal circuit to
`address selection of frequencies. And the federal
`circuit opinion didn't devote any words to analyze
`the selection of frequencies. Rather, the
`disputes for the federal circuit was centered on
`whether the frequencies must be provided to
`different touch pads rows or whether, instead, it
`was sufficient for them to simply be provided to
`the touch pat itself, that is all of its rows.
`And its conclusion was that any implicit claim
`construction must have been erroneous.
` Again, importantly, there was no briefing
`on whether the frequencies are selected from
`multiple possible frequencies or otherwise. And
`that stands to reason because if we look at that
`Gerpheide reference, it -- it sends multiple
`frequencies out, and then it selects the frequency
`from the lowest interference version that has been
`sent out. And the parties weren't disputing that.
`So, there was no question about the existence in
`the prior art in question of multiple frequencies.
` Now, all of that is just contextual,
`hoping to give a better understanding of, when we
`do see what's in the opinion, what -- what is
`really to be taken away from it.
` In short, it includes language that you've
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`seen that's quoted by Nartron. Nartron is not
`inaccurately quoting, but their quotes distort,
`through omission of the context and the competing
`quotes that exist in the opinion, the meaning of
`what they have quoted.
` Now, if we look at the appendix version of
`the opinion, pages 11 and 12, we're going to see
`the beneficial context that we're referring to and
`quotes that are contrary to those that are being
`relied upon.
` The last sentence in page 11, if you have
`that in front of you, is where this begins. And
`in that sentence, there is certain givens. It
`says, "Given the dependent claim recites sending
`the same frequency to all the rows of the device."
`Federal circuit says, "We interpret the
`necessarily broader independent claims," their 40,
`same as our claim 37 or 40 -- or 94 in this
`language, "as covering such a situation," that is,
`the claim needs to be broad enough to allow the
`same frequency to be sent to all the rows.
` Now, through a claim differentiation, the
`board is -- the court is noting here that the
`independent claim can't be read summarily as
`foreclosed from providing the same frequency to all
`the rows in the device.
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` That sentence concludes with a
`parenthetical, and that parenthetical says, "Even
`though -- even though, yes, that is the claim may
`also cover the situation, where different
`frequencies are provided." So, they're not trying
`to narrow the claim; they're just trying to
`explain the claim is broad enough, needs to be
`broad enough, in fact, to have its frequency or
`frequencies delivered to all of the rows of the
`device, and that is contrasted with what the board
`thought to have done in resolving no reasonable
`expectation of success.
` The next sentence, which straddles pages
`11 and 12, really drive this point home. There,
`the federal circuit clarified that the claims, and
`I'll quote, "are not limited to situations which
`different frequencies are provided to different
`rows." Again, it's trying to get away from the
`notion that specific rows being the recipient of
`the frequencies is not a requirement of these
`dependent claims, and ends with first paragraph --
`ends that paragraph with the first sentence that
`is on page 12 in full, where they conclude by
`agreeing with Samsung in principle, where, as
`Samsung had alleged, the claim only requires
`frequencies to be provided to the entire touch
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`pad.
` And, so, through this analysis, they're
`resolving that it's the touch pad that is the --
`the recipient, that which -- to which the
`provision is made, not necessarily the rows of the
`array on the touch pad.
` As a general ambiguity to this part of the
`writing, the next paragraph, paragraph 12, and
`this is where -- where Nartron cites from, there
`is a little more ambiguity, and we think we can
`make sense of it, inconsistent with this writing.
` The last sentence of the paragraph, the
`first paragraph here on this page, it says the
`question -- and it's defining how you resolve when
`they send back this decision to the -- to the
`board, how do you resolve reasonable expectation
`of success in light of the claim construction, the
`work that was just done.
` They say the question is whether
`reasonable expectation of success in modifying the
`combination of Ingraham and Caldwell, a
`combination, to provide frequencies to the touch
`panel in light of Gerpheide.
` What is it doing there? In light of
`Illumina, it's articulating that the construction
`that it's resolved relative to reasonable
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`expectation of request is the words "to provide
`frequencies to the touch pad," and that is
`perfectly consistent with the paragraph prior.
` Remember, the paragraph prior talks about
`it not being the array rows that were the
`recipient but the touch pad itself. And here
`they're inserting that phraseology, that
`construction, if you will, into their articulation
`of what you need to do in order to resolve
`reasonable expectation of success.
` So, I'm going to focus on those words "to
`provide frequencies to the touch pad."
` Now, they end that sentence with the
`parenthetical, which is an i.e., and that sentence
`ends after they say -- they reference the
`teachings of Gerpheide. In doing so, what they're
`doing is they're setting up, if I'm going to apply
`that construction in the context of reasonable
`expectation of success, and I'm going to do that
`in a world we're talking about Gerpheide plus
`Ingraham and Caldwell, how do I do that, and it
`adds the following parenthetical. It says,
`"wherein there -- there was a reasonable
`expectation of success that the combination could
`have been modified to provide a frequency selected
`from multiple frequencies to the entire touch
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`pad."
` What they're doing there, it's maintaining
`the specific words that it had earlier used. The
`words "to provide" are maintained. The reference
`to the entire touch pad, that's maintained, as
`well. The only thing that's changed is the word
`"frequencies" is replaced, because of Gerpheide's
`reference, with the words "a frequency selected
`from multiple possible frequencies."
` And why is that? That's because
`Gerpheide, remember, is sending out multiple
`frequencies, and then it's selecting one of those
`frequencies.
` So, when I'm going to evaluate whether the
`combination of Gerpheide plus these other two
`references as has a reasonable expectation of
`success, I've got to look at the claim language,
`but in the context of that combination, I'm going
`to look at what does Gerpheide bring to the table
`in terms of its selection among the frequencies
`that it sent out.
` It's not construing newly. In fact, the
`sentence itself, the primary part of the sentence
`is where it tells us what's attached to. This is
`just a parenthetical so that you can understand
`how to apply that (inaudible) and apply the claim
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`language that it construes there, what book it is
`analyzing.
` And with that, we would submit to you that
`the claim construction is resolved by the federal
`circuit as it relates to reasonable expectation of
`success has no bearing on whether or not the claim
`requires limitations on selecting or somehow
`otherwise choosing frequencies. That's not --
`that's not the form of the focus of their opinion.
`And any citation to the opinion for that purpose
`we believe to be misguided.
` We go back to the analysis that was done
`in a very thorough manner, and that was done with
`the plain meaning in mind and then, in the
`alternative, even if there was an ambiguity, with
`the specification in mind, and that was resolved,
`we believe, in favor of petitioner.
` Without questions, I would -- I would go
`to my colleagues Jeremy Monaldo for issue two.
`But are there any questions on that? Very
`important point.
` JUDGE BEAMER: Well, if you look at, for
`example, claim -- claim 86, and I believe there's
`other similar claims, where it says, "wherein each
`signal output frequency is selected from a
`plurality of hertz values," how -- how do you --
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`what is your current position in light of the
`federal circuit opinion as to how that is
`interpreted?
` Does that mean that a system must be able
`to, on the fly, during the operation, select from
`a plurality of values?
` Does it mean simply that, at the design
`stage, when you are designing an embodiment of
`this invention, you select a particular value from
`some menu of values or what?
` MR. RENNER: Great question. I appreciate
`it. The -- a few things. That claim is similar
`to claim 97 referenced earlier in the 94 claim
`set. You're correct. You're instructed towards
`claim set. And this is one that has that similar
`language.
` It's, first of all, important to note that
`this claim modifies the independent claim which
`calls for the microprocessor to do the work. It's
`the worker here. And in this claim, you can see
`reference at the end of the claim a reference to
`"selected from," "is selected from." So, it's
`talking in active. Now it's talking about how you
`select here.
` And we think -- our -- our view of the
`world is this requires that it can't be done at
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`the design phase. It's got to be done in order to
`meet this claim and 97, importantly, along with
`this. Has to be done at the, you know, processing
`phase, if you will, by the microprocessor.
` What's being selected and how you score
`that, this is one of two alternatives. The claim
`right before it in the other set tells us that the
`frequencies might be the same. Yeah, claim 85
`here is similar to 96 in the other set where
`there's the same frequency option, as well.
` And, so, it could be, and in the
`independent claims go -- it can be and needed to
`be that the microprocessor can operate with just
`one frequency being used across multiple rows or
`it could be different frequencies used across
`multiple rows, and here we don't think this claim
`would modify that part of the analysis.
` JUDGE BEAMER: So, is there any support in
`the spec for that version of claim 86?
` MR. RENNER: So, for the version of 86
`which is that the -- that the -- that there's a
`selection of the frequencies, no. We think the
`microprocessor does not -- it does not actually
`select the frequencies. We think that it's never
`been disclosed as having done so, and we think
`there's a 112 deficiency here that your board --
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`your Honors have noted.
` That's the problem with the analysis when
`you go down the path that Nartron would like you
`to go down. They want the independent claim to be
`read in the way that we're talking about on 97 or
`also in this claim of 86, 87.
` JUDGE BEAMER: Okay. Thank you.
` MR. RENNER: Sure. And I'll reemphasize
`that one last point, that here with the words --
`the words where "selected" comes in, this would
`be, if anything, where the patent owner, later
`offering these claims in reissue, where they tried
`to express their intent for a selection of -- of
`frequencies. You see a very different use of the
`word "selected," which comes alongside the word
`"providing" when they're talking about a different
`kind of selection, which is what's in their
`independent claims.
` Jeremy, I think I'll ask you to move on.
`Thank you.
` Thank you, your Honor.
` MR. MONALDO: Thank you, Karl, and thank
`you to your Honors for taking the time today to
`discuss these IPRs. And I'll start my part of the
`presentation on slide 20 to discuss the second
`issue identified in our demonstratives application
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`of Chiu and Schwarzbach to claim 37.
` Moving to slide 21, you can see the unique
`feature of claim 37, the requirement that an
`oscillator voltage is greater than a supply
`voltage.
` Now, in institution decision, your Honors
`criticized the petition's reference to
`Schwarzbach's transmitter modulator 110 for this
`feature.
` In looking at -- back at Schwarzbach, we
`recognize that this criticism was fair, and I'm
`not going to spend time today trying to argue that
`Schwarzbach's transmitter modulator meets this
`claim feature. What I am going to do is explain
`how the analysis in the institution decision
`focussed too greatly on Schwarzbach alone and did
`not address the combination arguments, the
`combination of Chiu and Schwarzbach, for this
`feature.
` And for that background, I'll start with a
`discussion of simple combination of Chiu and
`Schwarzbach, and then I'll follow with the
`discussion of where that combination is presented
`in the petition for this claim feature.
` Moving to slide 22, you can see Chiu and
`Schwarzbach describe the same microprocessor. In
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`the upper text box, you see Chiu's disclosure, TMS
`1670. In the lower text box, you see
`Schwarzbach's disclosure, the same, TMS 1670, the
`same microprocessor. This is not in dispute.
` Moving to slide 23, you can see the
`disclosure of the voltage level in each of Chiu
`and Schwarzbach. In upper text box, you see
`Chiu's disclosure of 30 scan pulses. But what
`Chiu lacks is a disclosure of a supply voltage.
`That's where Schwarzbach comes in. And you can
`see in the lower text box disclosure of VDD supply
`voltage of 16 volts.
` Very simple, Chiu is missing disclosure of
`supply voltage, and Schwarzbach provides the
`missing detail. And with that detail added, you
`can clearly see an oscillator voltage, the
`30 volts described in Chiu, that is greater than a
`supply voltage, 16 volts described in Schwarzbach.
` Now let's turn to discussion of where this
`argument is made in the petition. And I'm moving
`to slide 24. You can see content from page 18 of
`the petition discussing the combination of Chiu
`and Schwarzbach. This is the initial and primary
`discussion of the combination and sets the table
`for all of the analysis that follows.
` As you can see on slide 24, the petition
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`argues that Schwarzbach is combined with Chiu but
`said the microprocessor 90 of Chiu is provided
`with a supply voltage of 16 volts as taught by
`Schwarzbach, Simply taking the supply voltage of
`Schwarzbach and applying it to Chiu.
` The petition then concludes that this
`results in a 30-volt signal that is greater than
`the 16-volt supply voltage from outset, 30 volts
`and 16 volts.
` Now moving to slide 25, you can see a
`paragraph from page 30 of the petition discussing
`claim 37. In this paragraph, you see the
`conclusion, "Chiu would be operated at the supply
`voltage of the i
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