UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`Google LLC
`
`Petitioner
`
`v.
`
`Cywee Group Ltd.
`
`(record) Patent Owner
`
`Patent No. 8,552,978
`
`DECLARATION OF PROF. MAJID SARRAFZADEH
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` LG 1002
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`TABLE OF CONTENTS
`ENGAGEMENT AND COMPENSATION ................................................. 4 
`I. 
`QUALIFICATIONS ..................................................................................... 4 
`II. 
`SUMMARY OF OPINIONS ........................................................................ 6 
`III. 
`IV.  MATERIALS REVIEWED .......................................................................... 6 
`V. 
`UNDERSTANDING OF THE RELEVANT LAW ..................................... 6 
`A.  Anticipation ................................................................................................. 6 
`B.  Obviousness ................................................................................................. 7 
`VI. 
`LEVEL OF ORDINARY SKILL IN THE ART ........................................ 10 
`VII. 
`RELEVANT TIMEFRAME FOR DETERMINING OBVIOUSNESS .... 10 
`VIII.  TECHNICAL INTRODUCTION ............................................................... 11 
`IX. 
`CLAIM INTERPRETATION ..................................................................... 16 
`A.  Claim 10—“spatial reference frame” and “spatial reference frame
`associated with the 3D pointing device” ................................................... 17 
`B.  Claim 10—“rotation output” ..................................................................... 22 
`THE PRIOR ART (ZHANG, BACHMANN, AND LIBERTY) ............... 23 
`1. 
`Overview of Zhang ................................................................... 23 
`2. 
`Overview of Bachmann ............................................................ 29 
`3. 
`Overview of Liberty .................................................................. 36 
`CLAIMS 10 AND 12 WOULD HAVE BEEN OBVIOUS OVER ZHANG
`AND BACHMANN .................................................................................... 43 
`Summary of Opinion ................................................................................. 43 
`A. 
`B.  Overview of the obviousness determination ............................................. 43 
`1. 
`Combining Zhang and Bachmann ............................................ 44 
`2. 
`Rationale for combining Zhang and Bachmann ....................... 45 
`3. 
`Ability to Implement and Reasonable Expectation of Success 51 
`C.  How the Combination Meets the Elements of the Claims ........................ 53 
`1. 
`Claim 10 .................................................................................... 53 
`
`XI. 
`
`X. 
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`XII. 
`
`2. 
`Claim 12 .................................................................................... 73 
`CLAIMS 10 AND 12 WOULD HAVE BEEN OBVIOUS OVER
`LIBERTY AND BACHMANN .................................................................. 73 
`Summary of Opinion ................................................................................. 73 
`A. 
`B.  Overview of the Obviousness Determination ............................................ 74 
`1. 
`Combining Liberty and Bachmann ........................................... 74 
`2. 
`Rationale for the Combination .................................................. 75 
`3. 
`Ability to Implement and Reasonable Expectation of Success 79 
`C.  How the Combination Meets the Elements of the Claims ........................ 80 
`1. 
`Claim 10 .................................................................................... 80 
`2. 
`Claim 12 .................................................................................... 85 
`XIII.  OATH .......................................................................................................... 86 
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`
`I.
`
`ENGAGEMENT AND COMPENSATION
` My name is Majid Sarrafzadeh. I have been retained by Google LLC
`
`for the purpose of providing my opinion with respect to the unpatentability of U.S.
`
`Pat. No. 8,552,978 (“the ’978 patent”). I am being compensated for my time in
`
`preparing this declaration at the rate of $650/hr, and my compensation is not
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`dependent upon my opinions or the outcome of the proceedings.
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`II. QUALIFICATIONS
`
`I currently hold the title of Distinguished Professor and Director of
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`Embedded and Reconfigurable Computing (ER) Laboratory in the Computer
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`Science Department at the University of California, Los Angeles (UCLA). I also
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`have a courtesy appointment in the Department of Electrical Engineering at UCLA.
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`I am the Co-Director of the Center for SMART Health, Co-Director for the BRITE
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`Center on Minority Health Disparities, and a Co-Founder of the UCLA Wireless
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`Health Institute.
`
`
`
`I believe that I qualify as an expert in the field of sensors and sensor
`
`data processing, and as at least a person of ordinary skill in the art. My current
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`Curriculum Vitae is attached to the end of this declaration, and summarizes my
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`qualifications.
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`
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`I received my Bachelor’s Degree from the University of Illinois at
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`Urbana-Champaign in Electrical and Computer Engineering in 1982, a Master of
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`Science Degree in Electrical and Computer Engineering University of Illinois in
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`1984, and a Ph.D. in Electrical and Computer Engineering University of Illinois in
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`1987.
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`
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`From 1987 to 1991, I was an Assistant Professor in the Department of
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`Electrical and Computer Engineering at Northwestern University. From 1991-1997,
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`I held the title of Associate Professor, also in the Department of Electrical and
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`Computer Engineering at Northwestern University. From 1997-2000, I held the title
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`of Full Professor in that department.
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`
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`I am an author or co-author on more than 500 publications in electrical
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`engineering and computer sciences. Many of my publications relate to the use of
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`sensors and sensor networks to track human body movement and health indicators.
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`
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`I have used various sensors including motion sensors in my research. I
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`have designed and built hardware and software systems for motion tracking, gait
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`analysis, 3D rehab systems, and gaming just to name a few. I have performed data
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`capture, data processing and analytics with these mobile systems. I have utilized the
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`design in remote monitoring systems. In many of my projects I have developed
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`algorithms relating to sensor fusion. For example, I have used motion sensor fusion
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`to cancel motion noise
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`in other signals, such as when working with
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`photoplethysmography (PPG). I have used pressure sensors, accelerator and
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`gyroscope fusion to construct motion data.
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`III. SUMMARY OF OPINIONS
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`In my opinion, claims 10 and 12 are obvious over the Zhang publication
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`and Bachmann patent.
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`
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`In my opinion, claims 10 and 12 are also obvious over the Liberty
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`patent and Bachmann patent.
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`IV. MATERIALS REVIEWED
`
`In forming my opinions, I have relied of my knowledge of the field and
`
`my experience, and have specifically reviewed the following exhibits:
`
`
`
`Exhibit No.
`1001
`1004
`1005
`1006
`1009
`
`Description
`U.S. Pat. No. 8,552,978 (“the ’978 patent”)
`U.S. Pat. No. 7,089,148 (“Bachmann”)
`U.S. Pat. App. Pub. 2004/0095317 (“Zhang”)
`U.S. Pat. No. 7,158,118 (“Liberty”)
`File History of U.S. Pat. App. 13/176,771
`
`
`V. UNDERSTANDING OF THE RELEVANT LAW
`
`I have the following understanding of the applicable law:
`
`A. Anticipation
`
`I understand that a claim in an issued patent can be unpatentable if it is
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`anticipated. In this case, “anticipation” means that there is a single prior art reference
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`that discloses every element of the claim, arranged in the way required by the claim.
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`
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`I understand that an anticipating prior art reference must disclose each
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`of the claim elements expressly or inherently. I understand that “inherent”
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`disclosure means that the claim element, although not expressly described by the
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`prior art reference, must necessarily be present based on the disclosure. I understand
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`that a mere probability that the element is present is not sufficient to qualify as
`
`“inherent disclosure”.
`
`B. Obviousness
`
`I understand that a claim in an issued patent can be unpatentable if it is
`
`obvious. Unlike anticipation, obviousness does not require that every element of the
`
`claim be in a single prior art reference. Instead, it is possible for claim elements to
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`be described in different prior art references, so long as there is motivation or
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`sufficient reasoning to combine the references.
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`
`
`I understand that a claim is unpatentable for obviousness if the
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`differences between the claimed subject matter and the prior art are such that the
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`subject matter as a whole would have been obvious at the time the alleged invention
`
`was made to a person having ordinary skill in the art to which said subject matter
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`pertains.
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`
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`I understand, therefore, that when evaluating obviousness, one must
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`consider obviousness of the claim “as a whole”. This consideration must be from
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`the perspective of the person of ordinary skill in the relevant art, and that such
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`perspective must be considered as of the “time the invention was made”.
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` The level of ordinary skill in the art is discussed in ¶24 below.
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` The relevant time frame for obviousness, the “time the invention was
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`made”, is discussed in ¶25, below.
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`
`
`I understand that in considering the obviousness of a claim, one must
`
`consider four things. These include the scope and content of the prior art, the level
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`of ordinary skill in the art at the relevant time, the differences between the prior art
`
`and the claim, and any “secondary considerations”.
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`
`
`I understand that “secondary considerations” include real-world
`
`evidence that can tend to make a conclusion of obviousness either more probable or
`
`less probable. For example, the commercial success of a product embodying a claim
`
`of the patent could provide evidence tending to show that the claimed invention is
`
`not obvious. In order to understand the strength of the evidence, one would want to
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`know whether the commercial success is traceable to a certain aspect of the claim
`
`not disclosed in a single prior art reference (i.e., whether there is a causal “nexus” to
`
`the claim language). One would also want to know how the market reacted to
`
`disclosure of the invention, and whether commercial success might be traceable to
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`things other than innovation, for example the market power of the seller, an
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`advertising campaign, or the existence of a complex system having many features
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`beyond the claims that might be desirable to a consumer. One would also want to
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`know how the product compared to similar products not embodying the claim. I
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`understand that commercial success evidence should be reasonably commensurate
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`with the scope of the claim, but that it is not necessary for a commercial product to
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`embody the full scope of the claim.
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` Other kinds of secondary considerations are possible. For example,
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`evidence that the relevant field had a long-established, unsolved problem or need
`
`that was later provided by the claimed invention could be indicative of non-
`
`obviousness. Evidence that others had tried, but failed to make an aspect of the
`
`claim might indicate that the art lacked the requisite skill to do so. Evidence of
`
`copying of the patent owner’s products before the patent was published might also
`
`indicate that its approach to solving a particular problem was not obvious. Evidence
`
`that the art recognized the value of products embodying a claim, for example, by
`
`praising the named inventors’ work, might tend to show that the claim was non-
`
`obvious.
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`
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`I further understand that prior art references can be combined where
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`there is an express or implied rationale to do so. Such a rationale might include an
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`expected advantage to be obtained, or might be implied under the circumstances. For
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`example, a claim is likely obvious if design needs or market pressures existing in the
`
`prior art make it natural for one or more known components to be combined, where
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`each component continues to function in the expected manner when combined (i.e.,
`
`when there are no unpredictable results). A claim is also likely unpatentable where
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`it is the combination of a known base system with a known technique that can be
`
`applied to the base system without an unpredictable result. In these cases, the
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`combination must be within the capabilities of a person of ordinary skill in the art.
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`
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`I understand that when considering obviousness, one must not refer to
`
`teachings in the specification of the patent itself. One can, however, refer to portions
`
`of the specification admitted to being prior art, including the “BACKGROUND”
`
`section. Furthermore, a lack of discussion in the patent specification concerning
`
`how to implement a disclosed technique can support an inference that the ability to
`
`implement the technique was within the ordinary skill in the prior art.
`
`VI. LEVEL OF ORDINARY SKILL IN THE ART
`
`In my opinion, the relevant art was that of sensors and sensor data
`
`processing. In the relevant timeframe, a person of ordinary skill in the art had at
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`least a Bachelor’s Degree in Computer Science, Electrical Engineering, Mechanical
`
`Engineering, or Physics, or equivalent work experience, along with knowledge of
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`sensors (such as accelerometers, gyroscopes and magnetometers), and mobile
`
`computing technologies. I believe I would meet this definition, and would have met
`
`this definition in the relevant timeframe.
`
`VII. RELEVANT TIMEFRAME FOR DETERMINING OBVIOUSNESS
`
`I understand that obviousness must be evaluated “at the time of the
`
`invention”. From the cover page of the ’978 patent, I can see that the first provisional
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`application for a patent was filed in the United States on January 6, 2010. For the
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`purpose of this declaration, I will analyze obviousness in the time frame immediately
`
`prior to this date, although my testimony is applicable to a longer period of time (at
`
`least a year) before January 6, 2010. My testimony is directed to this timeframe,
`
`even if I do not always use a past tense.
`
`VIII. TECHNICAL INTRODUCTION
` The ’978 patent discusses 3D pointing devices. (Ex. 1001, Title). Such
`
`devices are for “detecting motions of the device and translating the detected motions
`
`to a cursor display such as a cursor pointing on the screen…of a 2D display
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`device….” (Ex. 1001, 1:31-33). As one example of such a device, a computer
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`mouse could be adapted to detect movements and rotations in three dimensions. This
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`would allow such movements to be translated into commands for a computer, for
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`example. (Ex. 1001, 1:52-61). FIG. 1 of the ’978 patent shows an example pointing
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`device 110 and an associated display 120:
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` The ’978 patent uses sensors within pointing devices to track
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`movements and rotations. In the patent, three kinds of sensors are discussed:
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`rotation sensors (for detecting the angular velocity of rotation), accelerometers (for
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`detecting axial accelerations), and magnetometers (for detecting the local magnetic
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`field). (Ex. 1001, FIG. 4). Such sensors can be mounted in 3D pointing device, and
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`their outputs provide information on the movements and rotations of the device.
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` The ’978 patent discusses using the output of the sensors to calculate
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`the orientation of a 3D pointing device. (Ex. 1001, 4:15-57). Here, the word
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`“orientation” describes how the device is rotated in space with respect to the axes of
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`a given coordinate system, and is synonymous with the terms “attitude” and “tilt”.
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`(Ex. 1001, 1:62-64). FIG. 2 of the ’978 patent shows the same 3D pointing device
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`110 in a different “orientation”, having been rotated about the x-axis by 90 degrees:
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`(Ex. 1001, 2:11-14).
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`“Orientation” can be represented in a number of different ways. One
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`way is to use a set of angles, known as “Euler angles”. The Euler angles, called
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`“yaw”, “pitch” and “roll,” represent rotation around three orthogonal axes. If the
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`object whose orientation is being described is an airplane, the “yaw” could be
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`thought of as the horizontal (compass) direction of the airplane, while the “pitch” is
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`the inclination of the nose of the airplane, and the “roll” is the angle of wings. The
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`Euler angles do not need to be defined relative to the axes that most naturally fit
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`airplane flight, however, but can be with respect to any coordinate system with three
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`orthogonal axes.
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` Orientation can also be represented by a quaternion. A quaternion is a
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`four-valued vector (q0 q1 q2 q3) that can be thought of as a generalization of a
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`complex number. Quaternions were first described in the 19th Century. The
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`elements of a quaternion are usually thought of as having one real value (q0) and
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`three values (q1 q2 q3) parallel with three different imaginary axes, labeled i, j and
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`k. For this reason, quaternions can also be represented with vector addition in the
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`form q = a + bi + cj +dk, where i2=j2=k2=ijk=-1, and where the following relations
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`hold: ij=k, ji=-k, jk=i, kj=-i, ki=j, ik=-j.
`
`
`
` Quaternions have special mathematical properties that allow them to
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`describe rotations efficiently. For any rotation of angle Θ around a given axis
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`defined by a vector (x,y,z), a quaternion q representing the rotation can be defined
`
`such that q = cos(Θ/2) + sin(Θ/2)(xi +yj +zk). Furthermore, multiplying two
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`quaternions together using the distributive law and the relationships defined in 30,
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`above results in an application of rotations described by both quaternions.
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`Furthermore, and most usefully, any ordinary vector v=(v1 v2 v3) can be defined as
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`a quaternion with real component =0, e.g. v’=(0 v1 v2 v3). Then, any rotation
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`defined by a quaternion q can be applied to v’ to get a rotated quaternion r, by using
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`q and its conjugate (q-1), in the following way r=qv’q-1. In this equation, the
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`application of the quaternion q is by quaternion multiplication using the distributive
`
`law and the relationships defined in 30. The conjugate of q, labeled q-1, is simply q
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`with the imaginary components negated.
`
` The relationships described in ¶¶30-31 were well known in the relevant
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`timeframe, and are described in the prior art I reviewed. (e.g. Ex. 1004, 8:63-67)(Ex.
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`1006, 16:65-18:28). It was also well known that the Euler angles, described above
`
`in ¶29 could be equivalently represented by a quaternion. For example, the Liberty
`
`reference (Ex. 1006), states:
`
`“Q is the normalized rotation quaternion that represents the
`rotation from the body frame to the user frame. Since the
`rotation quaternion to rotate from the user frame to the body
`frame is Q, we could replace Q with R* where R is the
`rotation from the user frame to the body frame. Note that Q
`can be represented in a number of equivalent forms
`including Euler angles and the direction cosine matrix
`(DCM), and the above equations may vary slightly in their
`equivalent forms based upon different representations of Q.”
`(Ex. 1006, 17:36-44).
`
` The ’978 patent discusses prior art 3D pointing devices having sensors
`
`(such as the Liberty patent, described below), but criticizes the prior art devices as
`
`as allegedly unable to calculate orientation accurately. (Ex. 1001, 2:41-3:52). The
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`purpose that the ’978 describes is to use additional sensors and to compensate the
`
`output of the sensors to improve the accuracy of the orientation calculation. (Ex.
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`1001, 1:22-27).
`
` To “compensate” the output of the sensors, the ’978 patent discloses a
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`mathematical method using quaternions. (Ex. 1001, 16:5 et seq.). Figure 7 of the
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`’978 patent (right) shows an aspect of this method. The system obtains measured
`
`angular velocities at step 715 (Ex. 1001,
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`16:27-30). The system also obtains
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`measured axial accelerations in step 725
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`(Ex. 1001, 16:60-64).
`
` Using
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`the
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`measured angular velocities, the system
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`calculates predicted axial accelerations.
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`(Ex. 1001, 17:2-9). By comparing the
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`actual and predicted accelerations (step
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`735), the method purports to improve
`
`the estimate of orientation (called here
`
`the “updated state (3rd quaternion)” in
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`box 735). (Ex. 1001, 18:25-55).
`
`IX. CLAIM INTERPRETATION
`
`I understand that it is sometimes necessary or useful for claim terms in
`
`a patent to be further explained or interpreted (“construed”). In the present
`
`proceeding, I understand generally that claims terms are construed according to their
`
`broadest reasonable interpretation in light of the specification, looking at the
`
`ordinary meaning to a person of ordinary skill in the art in the relevant timeframe
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`and considering the specification of the patent and the file history of the patent.
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`
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`I have reviewed the claim interpretations in the corresponding petition
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`for inter partes review, and I am of the opinion that they would have been reasonable
`
`to a person of ordinary skill in the art in the relevant timeframe in the context of the
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`’978 patent. These interpretations are set forth in the following paragraphs, and my
`
`testimony applies these interpretations:
`
`A. Claim 10—“spatial reference frame” and “spatial reference frame
`associated with the 3D pointing device”
` The terms “spatial reference frame” and “spatial reference frame
`
`associated with the 3D pointing device” each mean “a reference frame associated
`
`with the 3D pointing device, which always has its origin at the same point in the
`
`device and in which the axes are always fixed with respect to the device.”
`
` My interpretation of these terms is based on the claims and specification
`
`of the ’978 patent. Claim 10 refers to several frames of reference, including (1) “a
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`spatial reference frame associated with the 3D pointing device,” (2) “the spatial
`
`reference frame,” (3) a “global reference frame associated with Earth,” and (4) “a
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`fixed reference frame associated with a display device.” Neither claim 10 nor
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`dependent claims 11–18 defines “a spatial reference frame associated with the 3D
`
`pointing device” or “the spatial reference frame.” But claims 10–18 use these terms
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`interchangeably, which leads me to conclude that they mean the same thing. The
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`specification of the ’978 patent supports this conclusion as explained below.
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` The specification of the ’978 patent uses the terms “spatial reference
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`frame” and “spatial reference frame associated with [a] 3D pointing device” to refer
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`to the frames of reference of pointing devices like those shown in FIGS. 3, 5, 6, 9,
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`and 13–15 of the ’978 patent. The ’978 patent does not define these terms in great
`
`detail, but it does liken the spatial reference frame to the reference frame associated
`
`with the 3D pointing device shown in FIGS. 1 and 2. For example, when describing
`
`the electronic device 300 shown in FIG. 3, the ’978 patent states:
`
`“The electronic device 300 is subject to movements and
`rotations in dynamic environments in a spatial reference
`frame such as a 3D reference frame. The spatial reference
`frame is analogous to the reference frame XPYPZP also
`shown in FIG. 1 and FIG. 2.”
`
`(Ex. 1001, 9:16-20)(Emphasis added). Similarly, when discussing the flowchart
`
`shown in FIG. 13, the ’978 patent refers to “the three coordinate axes of a spatial
`
`reference frame associated with the 3D pointing device itself (such as the
`
`reference frame XPYPZP shown in FIG. 1 and FIG. 2).” (Ex. 1001, 30:60-
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`30:63)(Emphasis added). I take these references to mean that the reference frame
`
`XPYPZP shown in FIGS. 1 and 2 is an example of a spatial reference frame
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`(associated with the 3D pointing device).
`
` The reference frame XPYPZP shown in FIGS. 1 and 2 (reproduced
`
`below) is called the “spatial pointer reference frame.” (Ex. 1001, 1:38–1:42). The
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`’978 patent states that the spatial pointer reference frame is “associated with the
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`pointing device 110 [and] is defined by the coordinate axes XP, YP and ZP as shown
`
`in FIG. 1.” (Ex. 1001, 1:43-1:45). Because the pointing device 110 can be “a 3D
`
`pointing device” (Ex. 1001, 1:30), I interpret the spatial pointer reference frame to
`
`be “a reference frame associated with the 3D pointing device” per the first part of
`
`my interpretation of “spatial reference frame.” This interpretation is consistent with
`
`the descriptions of spatial reference frames elsewhere in the specification of the ’978
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`patent.
`
` Next, I consider the second part of my interpretation, i.e., that the spatial
`
`reference frame “always has its origin at the same point in the device and in which
`
`the axes are always fixed with respect to the device.” This is based on FIGS. 1 and
`
`2 of the ’978 patent. These figures are reproduced below and show that the XP, YP
`
`and ZP coordinate axes intersect at a point within the electronic device 110. See, for
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`example, FIG. 1 of the ’978 patent:
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` FIG. 2 (reproduced below) also shows that the intersection of the XP,
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`YP, and ZP coordinate axes is within the electronic device 110:
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` The intersection point of a set of coordinate axes is commonly called
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`the “origin” of the reference frame, hence my interpretation that the spatial reference
`
`frame (associated with the 3D pointing device) has an origin in the device.
`
` Not only is the origin in the device, it is always at the same point in the
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`device, even if the device is rotated or translated. This is because the XP, YP, and ZP
`
`coordinate axes are always fixed with respect to the device. In other words, the
`
`coordinate frame does not move relative to the device, even if the device itself moves
`
`with respect to the display or the Earth.
`
` FIG. 2 of the ’978 patent shows that the XP, YP, and ZP coordinates do
`
`not move with respect to the device when the device is rotated. More specifically,
`
`rotating the device counterclockwise by 90 degrees with respect to the screen 120
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`(i.e., around the XP axis) causes the XP, YP, and ZP coordinate axes to rotate
`
`counterclockwise by 90 degrees. This means that the XP, YP, and ZP coordinate axes
`
`do not rotate with respect to the device. Similarly, it is my opinion that the XP, YP,
`
`and ZP coordinate axes do not translate with respect to the device. In other words,
`
`the XP, YP, and ZP coordinate axes are always fixed with respect to the device, hence
`
`my interpretation that the spatial reference frame has axes that “are always fixed
`
`with respect to the device.”
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` By definition, the coordinate axes are also fixed with each other. This
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`means that their intersection point—the origin—is fixed with respect to the
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`coordinate axes. And because the coordinate axes are fixed with respect to the
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`device, the origin is also fixed with respect to the device. This means that the origin
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`is always in the same point in the device.
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` For these reasons, I interpret “spatial reference frame” and “spatial
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`reference frame associated with the 3D pointing device” to have the same meaning:
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`“a reference frame associated with the 3D pointing device, which always has its
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`origin at the same point in the device and in which the axes are always fixed with
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`respect to the device.”
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`B. Claim 10—“rotation output”
` Claim 10 uses the phrase “rotation output”. I interpret this “rotation
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`output” to be the “output of a rotation sensor” for the following reasons.
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` According to claim 10, the “rotation output” is “associated with a
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`rotation of the 3D pointing device.” Claim 10 also states that “the rotation output is
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`generated by a nine-axis motion sensor module”. Put differently, the nine-axis
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`motion sensor module produces the rotation output as the 3D pointing device rotates.
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` The specification of the ’978 patent makes clear that the rotation output
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`is the output of a rotation sensor that is part of the nine-axis sensor module. For
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`example, the Summary of the ’978 patent states:
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`“The rotation sensor generates a rotation output associated
`with a rotation of the 3D pointing device associated with three
`coordinate axes of a spatial reference frame associated with the
`3D pointing device.” (Ex. 1001, 7:61-64)(Emphasis added).
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` The Detailed Description of the ’978 patent goes into more detail about
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`the rotation output, rotation sensor, and nine-axis sensor module. It starts by
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`disclosing a “nine-axis motion sensor module 302 [that] includes the rotation sensor
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`342”. (Ex. 1001, 9:60-61). It also states:
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`“The rotation sensor 342 of the nine-motion sensor module 302
`detects and generates the first signal set including angular
`velocities ωx, ωy, ωz associated with the movements and
`rotations of the electronic device 300 about each of three
`orthogonal coordinate axes XPYPZP of the spatial reference
`frame”. (Ex. 1001, 10:1-6).
`
` This description is consistent with claim 10 and indicates that “rotation
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`output” should be interpreted as “output of a rotation sensor”.
`
`X. THE PRIOR ART (ZHANG, BACHMANN, AND LIBERTY)
`1. Overview of Zhang
` Zhang discloses a “handheld pointing device” for controlling a
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`“computer pointing control system”. (Ex. 1005, Abstract). Zhang’s FIG. 2
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`(reproduced below) shows an example of this computer pointing control system with
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`a handheld pointing device 100:
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` Zhang’s device 100 includes several sensors that detect the device’s
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`
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`orientation. Zhang explains:
`
`“A universal pointing control system for televisions and
`computer displays is disclosed. The system is comprised of a
`remote handheld device, a display control unit and a command
`delivery unit. The remote handheld device includes a set of
`orientation sensors that detect the device’s current
`orientation.” (Ex. 1005, ¶0008)(Emphasis added).
`
` The set of orientation sensors “detects the device’s current orientation
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`and generate[s] the pointing direction signal.” (Ex. 1005, ¶0021). This pointing
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`direction signal indicates which way the device 100 is pointing. (Ex. 1005, ¶0021).
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` Zhang discloses that these different orientation sensors include a two-
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`axis magnetic field sensor and a two-axis accelerometer. Zhang’s FIG. 3
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`(reproduced immediately below) shows an example two-axis magnetic field sensor
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`120 and an example accelerometer 130 on a circuit board 160 inside the device 100
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`along with a microcontroller 110:
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`
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`
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` FIG. 3 shows that the magnetic field sensor 120 and the accelerometer
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`
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`sensor 130 are mounted at right angles with respect to each other. (Ex. 1005, ¶0026).
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`This is so that one sensor (here, the magnetic field sensor 120) detects the device’s
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`yaw (azimuth) angle and the other sensor (here, the accelerometer sensor 130)
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`detects the device’s pitch (inclination) angle. (Ex. 1005, ¶0025).
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` Zhang’s FIG. 4a shows the magnetic field sensor 120, the yaw angle ϕ,
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`and the orientation of the Earth’s magnetic field 25. The magnetic field sensor 120
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`“detects the device’s orientation relative to the direction of the earth’s magnetic field
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`25.” (Ex. 1005, ¶0026). Similarly, Zhang’s FIG. 4b shows the accelerometer sensor
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`130 and the pitch angle ε. The accelerometer sensor 130 “sense[s] the device’s
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`heading change in the y-z plane.” (Ex. 1005, ¶0027). Zhang’s FIGS. 4a and 4b are
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`reproduced immediately below:
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`
`
` The microcontroller 110 determines the device’s orientation from the
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`signals generated by the magnetic field sensor 120 and the accelerometer sensor 130.
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`(Ex. 1005, ¶¶0025 and 0029). These signals are filtered, amplified, digitized, and
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`processed using the components shown in the system diagram in Zhang’s FIG. 5, an
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`annotated version of which is reproduced immediately below. (Ex. 1005, ¶0029).
`
`
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` The magnetic field sensor 120 and accelerometer sensor 130 appear in
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`the lower left of FIG. 5 (numerals 120 and 130 are shown by red-dashed boxes).
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`These sensors output signals to amplifiers 121, 123, 131, and 133, which amplify
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`the sensor outputs. (Ex. 1005, ¶0029). Low-pass filters 122, 124, 132, and 134
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`remove high-frequency components from the amplified signals, which are
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`multiplexed by a multiplexer 112 and digitized by an analog-to-digital converter
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`(ADC) 111 before being processed by the microcont