FACEBOOK, INC., INSTAGRAM, LLC, and
`WHATSAPP INC.
`
`v.
`
`BLACKBERRY LIMITED
`
`Case Nos. IPR2019-00516 & IPR2019-00528
`
`Patent No. 8,279,173
`
`Patent Owner’s Demonstratives
`
`Hearing: May 5, 2020
`
`1
`
`Facebook v. BlackBerry
`IPR2019-00516 & -00528
`Ex. 2015
`
`
`WHATSAPP INC.
`
`v.
`
`BLACKBERRY LIMITED
`
`Case Nos. IPR2019-00516 & IPR2019-00528
`
`Patent No. 8,279,173
`
`Patent Owner’s Demonstratives
`
`Hearing: May 5, 2020
`
`1
`
`Facebook v. BlackBerry
`IPR2019-00516 & -00528
`Ex. 2015
`
`
`
`Overview of the ’173 Patent
`
`Ex. 1001 (‘173 Patent) at Fig. 4B, 9:14-20
`See also IPR2019-00516, Paper No. 14 at 8
`
`2
`
`
`
`Overview of the ’173 Patent
`
`Ex. 1001 (‘173 Patent) at Fig. 1
`(annotated), 5:39-47, 5:56-61
`See also IPR2019-00516,
`Paper No. 14 at 7
`
`3
`
`
`
`Overview of Petitioners’ Grounds
`
`Ground
`
`IPR2019-00516, Ground 1
`(dropped)
`
`IPR2019-00516, Grounds 2-3
`
`IPR2019-00516, Grounds 4-5
`
`References
`
`Zuckerberg
`
`Zuckerberg in view of
`Rothmuller and MacLaurin
`
`Zuckerberg in view of Plotkin
`and MacLaurin
`
`IPR2019-00516, Grounds 6-7
`
`Rothmuller in view of Matthews
`
`IPR2019-00528, Grounds 1-2
`
`MacLaurin
`
`IPR2019-00528, Grounds 3-4
`
`MacLaurin in view of Rothmuller
`
`IPR2019-00528, Grounds 5-6
`
`MacLaurin in view of Plotkin
`
`IPR2019-00516, Paper No. 2 at 4-5
`IPR2019-00528, Paper No. 2 at 4-5
`
`4
`
`
`
`All Prior Art Lacks an Indicator of a Tag Source
`
`Ex. 1001 (‘173 Patent) at 9:14-20
`See also IPR2019-00516, Paper No. 14 at 33-53, 75
`See also IPR2019-00528, Paper No. 16 at 32-52
`
`5
`
`
`
`Petitioners Cannot Prevail Without Prior Art
`
`“The patentability of claims 3 and 9 with the limitation
`‘a plurality of prongs that provide a detachable
`mechanical and electrical connection’ presents more
`than a peripheral issue. . . . [A]n assessment of basic
`knowledge and common sense as a replacement for
`documentary evidence for core factual findings
`lacks substantial evidence support.”
`
`K/S Himpp v. Hear-Wear Techs., LLC, 751 F.3d 1362, 1365-66 (Fed. Cir. 2014).
`
`See also IPR2019-00516, Paper No. 29 at 2-3; IPR2019-00528, Paper No. 29 at 13
`
`6
`
`
`
`
`
`Claim Construction
`Claim Construction
`
`7
`
`
`
`Claim Construction
`
`• Term: “tag source”
`
`BlackBerry’s Proposed
`Construction
`
`Petitioners’ Proposed
`Construction
`
`separately searchable
`collection of tags
`•
`”
`
`collection of tags
`
`or
`
`recognizable collection of tags
`
`Compare IPR2019-00516, Paper No. 14 (Patent Ow ner Response) at 20 with IPR2019-00516, Paper No. 22 (Petitioners’ Reply) at 1, 9
`
`8
`
`
`
`BlackBerry’s Construction
`
`Ex. 1001 (‘173 Patent) at 9:14-20
`See also IPR2019-00516, Paper No. 14 at 22-23
`
`9
`
`
`
`BlackBerry’s Construction
`
`Ex. 1001 (‘173 Patent) at Fig. 1
`(annotated), 5:39-47, 5:56-61
`See also IPR2019-00516,
`Paper No. 14 at 24-25
`
`10
`
`
`
`BlackBerry’s Construction
`
`Ex. 1001 (‘173 Patent) at 5:39-47
`See also IPR2019-00516, Paper No. 14 at 23-24
`
`11
`
`
`
`BlackBerry’s Construction
`
`Ex. 2012 (Expert Depo. Tr.) at 55:13-21
`See also IPR2019-00516, Paper No. 14 at 23-24
`
`12
`
`
`
`Petitioners’ Constructions
`
`Ex. 2005 (Exhibit from Expert Depo)
`
`Ex. 2012 (Expert Depo. Tr.) at 88:16-25
`
`See also IPR2019-00516, Paper No. 14 at 26-28
`
`13
`
`
`
`Petitioners’ Constructions
`
`IPR2019-00516, Paper No. 22 (Petitioners’ Reply) at 14
`
`See also IPR2019-00516, Paper No. 14 at 38-39
`
`14
`
`
`
`Petitioners’ Constructions
`
`Ex. 2006 (Petitioners’ MSJ Opposition) at 13
`
`See also IPR2019-00516, Paper No. 29 at 10-11
`
`15
`
`
`
`Petitioners’ Constructions
`
`Ex. 1001 (‘173 Patent) at 9:14-20
`
`See also IPR2019-00516, Paper No. 29 at 9-10
`
`16
`
`
`
`Petitioners’ Constructions
`
`IPR2019-00528, Paper No. 23 (Petitioners’ Reply) at 19
`
`See also IPR2019-00528, Paper No. 29 at 9-10
`
`17
`
`
`
`Petitioners’ Constructions
`
`IPR2019-00516, Paper No. 22 (Petitioners’ Reply) at 15
`
`See also IPR2019-00516, Paper No. 29 at 9-10
`
`18
`
`
`
`
`
`Prior Art
`Prior Art
`
`19
`
`
`
`Rothmuller Lacks an Indicator of a Tag Source
`
`Ex. 1004 (Rothmuller) at Fig. 1; see also IPR2019-00516, paper No. 14 at 45-50
`
`20
`
`
`
`Rothmuller Lacks an Indicator of a Tag Source
`
`IPR2019-00516, Paper No. 22 (Petitioners’ Reply) at 22
`
`See also IPR2019-00516, Paper No. 29 at 5
`
`21
`
`
`
`Plotkin Lacks an Indicator of a Tag Source
`
`Ex. 1008 (Plotkin) at 328
`
`See also IPR2019-00516, paper No. 14 at 50-53
`
`22
`
`
`
`Plotkin Lacks an Indicator of a Tag Source
`
`IPR2019-00516, Paper No. 22 (Petitioners’ Reply) at 15
`
`IPR2019-00528, Paper No. 23 (Petitioners’ Reply) at 21
`
`See also IPR2019-00516, Paper No. 29 at 2; IPR2019-00528, Paper No. 29 at 12
`
`23
`
`
`
`Zuckerberg Lacks an Indicator of a Tag Source
`
`Ex. 1003 (Zuckerberg) at Fig. 5; see also IPR2019-00516, Paper No. 14 at 33-42
`
`24
`
`
`
`Zuckerberg Lacks an Indicator of a Tag Source
`
`Ex. 1003 (Zuckerberg) at 8:49:58
`
`See also IPR2019-00516, Paper No. 14 at 37-39
`
`25
`
`
`
`Zuckerberg Lacks an Indicator of a Tag Source
`
`IPR2019-00516, Paper No. 22 (Petitioners’ Reply) at 15
`
`See also IPR2019-00516, Paper No. 29 at 5-6
`
`26
`
`
`
`Zuckerberg Lacks an Indicator of a Tag Source
`
`IPR2019-00516, Paper No. 22 (Petitioners’ Reply) at 12
`
`27
`
`
`
`Zuckerberg Lacks an Indicator of a Tag Source
`
`IPR2019-00516, Paper No. 22 (Petitioners’ Reply) at 11 n.3
`
`IPR2019-00516, Ex. 1023 (Reply Decl.) ¶ 31
`
`See also IPR2019-00516, Paper No. 29 at 1-2
`
`28
`
`
`
`MacLaurin Lacks an Indicator of a Tag Source
`
`Ex. 1006 (MacLaurin) at Fig. 8; see also IPR2019-00528, Paper No. 16 at 31-35
`
`29
`
`
`
`MacLaurin Lacks an Indicator of a Tag Source
`
`Ex. 1006 (MacLaurin) at Fig. 8; see also IPR2019-00528, Paper No. 16 at 31-35
`
`30
`
`
`
`MacLaurin Lacks an Indicator of a Tag Source
`
`Ex. 1006 (MacLaurin) at 8:20-23
`
`See also IPR2019-00528, Paper No. 16 at 35-38
`
`31
`
`
`
`MacLaurin Lacks an Indicator of a Tag Source
`
`IPR2019-00528, Paper No. 23 (Petitioners’ Reply) at 15
`
`See also IPR2019-00528, Paper No. 29 at 3-6
`
`32
`
`
`
`MacLaurin Lacks an Indicator of a Tag Source
`
`IPR2019-00528, Paper No. 23 (Petitioners’ Reply) at 19
`
`See also IPR2019-00528, Paper No. 29 at 6
`
`33
`
`
`
`BlackBerry’s Substitute Claims
`
`IPR2019-00516, Paper No. 15 (PO’s Conditional Motion to Amend) at Appendix A
`
`34
`
`
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