`U.S. Patent No. 9,633,373
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
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`APPLE INC.,
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`Petitioner,
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`v.
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`FIRSTFACE CO., LTD.,
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`Patent Owner.
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`________________
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`Case IPR2019-00613
`U.S. Patent No. 9,633,373
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`________________
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`PATENT OWNER’S PRELIMINARY RESPONSE TO PETITION
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`TABLE OF CONTENTS
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`INTRODUCTION ............................................................................................... 1
`I.
`II. THE ’373 PATENT AND THE CHALLENGED CLAIMS .............................. 2
`A. Problem Presented ............................................................................................ 2
`III. Claim Construction ........................................................................................... 6
`IV. SUMMARY OF THE REFERENCES ............................................................ 6
`A. Griffin ............................................................................................................... 6
`B. Goertz ............................................................................................................... 7
`C. Davis ................................................................................................................. 8
`D. iOS .................................................................................................................... 9
`V. APPLICABLE LEGAL STANDARDS ............................................................ 10
`A. Standard for Institution ................................................................................... 10
`B. Obviousness .................................................................................................... 10
`VI. THE PETITION DOES NOT DEMONSTRATE THAT THE
`CHALLENGED CLAIMS ARE UNPATENTABLE UNDER GROUND 1. ........ 12
`A. Griffin Does Not Disclose Turning on the Display (Displaying a Lock Screen)
`and Performing a First Function in Response to a One-Time Pressing of the
`Activation Button. ................................................................................................. 13
`B. The Deficiencies of Griffin Are Not Resolved by Davis. .............................. 15
`C. A POSITA Would Not Combine Griffin With Davis to Arrive at the Claimed
`Invention. .............................................................................................................. 18
`VII. THE PETITION DOES NOT DEMONSTRATE THAT THE
`CHALLENGED CLAIMS ARE UNPATENTABLE UNDER GROUND 2. ........ 19
`A. Goertz Does Not Disclose an Activation Button Configured for Pressing to
`Turn On the Touch Screen Display. ..................................................................... 20
`B. Goertz Does Not Disclose Turning On the Display and Performing a First
`Function in Response to a One-Time Pressing of the Activation Button. ........... 22
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`C. The Deficiencies of Goertz Are Not Resolved by Davis. .............................. 24
`VIII. CONCLUSION .............................................................................................. 24
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`TABLE OF AUTHORITIES
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`Cases:
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`Bausch & Lomb v. Barnes-Hind/Hydrocurve,
`796 F.2d 443 (Fed. Cir. 1986) ........................................................................... 17
`
`
`CFMT, Inc. v. YieldUp Int’l Corp.,
`349 F.3d 1333 (Fed. Cir. 2003) ......................................................................... 11
`
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`Garmin Int’l, Inc. v. Patent of Cuozzo Speed Techs. LLC,
`Case No. IPR2012-00001, Paper 15 (PTAB Jan. 9, 2013) ................................ 11
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`In re Gordon,
`733 F.2d 900, 221 USPQ 1125 (Fed. Cir. 1984) ......................................... 12, 19
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`In re Rijckaert,
`9 F.3d 1531 (Fed. Cir. 1993) ............................................................................. 11
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`In re Royka,
`490 F.2d 981 (C.C.P.A. 1974) ........................................................................... 11
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`KSR Int’l. Co. v. Teleflex Inc.,
`550 U.S. 398 (2007) ........................................................................................... 11
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`Unigene Labs., Inc. v. Apotex, Inc.,
`655 F.3d 1352 (Fed. Cir. 2011) ......................................................................... 11
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`Rules and Statutes:
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`35 U.S.C. § 103 ................................................................................................. 10, 11
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`35 U.S.C. § 103(a) .................................................................................................. 11
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`35 U.S.C. § 282(b) .................................................................................................... 6
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`35 U.S.C. § 314(a) .................................................................................................. 10
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`37 C.F.R § 42.100(b) ................................................................................................ 6
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`37 C.F.R. § 42.107 .................................................................................................... 1
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`37 C.F.R. § 42.108(c) .............................................................................................. 10
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`Other Authorities:
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`M.P.E.P § 2143.01(V) ....................................................................................... 12, 19
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`Office Patent Trial Practice Guide, 77 Fed. Reg. 48,756, 48,756 (Aug. 14, 2012) 10
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`Pursuant to 37 C.F.R. § 42.107, Patent Owner Firstface Co., Ltd. (“Firstface”
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`or “Patent Owner”) submits this Preliminary Response to the Petition of Apple Inc.
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`( “Apple” or “Petitioner”) seeking inter partes review of claims 1-2, 4-6, and 11-14
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`of U.S. Patent No. 9,633,373 (Ex. 1001, the “’373 patent”).
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`I.
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` INTRODUCTION
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` The ’373 patent claims an elegant solution to the problem of incorporating
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`new functionalities, such as fingerprint authentication, into mobile devices while
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`maintaining simplicity. According to the challenged claims, a single, one-time
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`pressing of an activation button when a device display is off causes the device to
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`both turn on the display (actively displaying the lock screen) and perform a first
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`function (such as fingerprint authentication). And when the activation button is
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`pressed for longer than a threshold time period, the device performs a second
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`function, such as a hands-free function. The claimed inventions thus increase the
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`usefulness of a device without complicating the user interface because the new
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`functionalities do not require additional buttons or other hardware, nor do they
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`require the user to perform additional steps to access additional device
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`functionalities. A single press of the activation button will both turn on the display
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`(as the user would expect) and perform the additional function(s) while a lock
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`screen is displayed.
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`No prior art reference cited by Petitioner discloses activating a device display
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`(displaying the lock screen) and performing a first function, each in response to a
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`one-time pressing of the activation button. The primary references, Griffin and
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`Goertz, disclose, instead, multi-step processes requiring multiple user inputs. And
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`Davis, the secondary reference that Petitioner combines with Griffin or Goertz, does
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`not fill the void. It also discloses a multi-step process requiring multiple user inputs.
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`Thus, Petitioner’s proposed combinations do not disclose the claimed invention.
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`Because the prior art does not disclose all limitations of the challenged claims,
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`Petitioner has failed to show a reasonable likelihood that any challenged claim is
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`obvious.
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`II. THE ’373 PATENT AND THE CHALLENGED CLAIMS
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`A.
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`Problem Presented
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`The ’373 patent explains that, as mobile communications devices have
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`proliferated, their capabilities have expanded from simple communication to
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`include innumerable other features and functions. See, e.g., Ex. 1001 (’373 patent),
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`1:26-33. Indeed, while early mobile communications devices were largely used
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`only as telephones, they now have cameras, web browsers, games, word-processing
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`and messaging applications, e-mail software, and numerous other applications and
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`features. As developers added functionality to these devices, they also added
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`complexity. For example, historically, newly-added functions required that a device
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`display be turned on before functions could be accessed or executed, requiring a
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`user to perform multiple initiating steps. Id., 1:34-39. Moreover, many functions
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`required new buttons, convoluting and congesting the user interface. Id.
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`The inventors of the asserted patent, including Firstface’s co-CEO, Jae Lark
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`Jung, developed innovative solutions for improving the user experience with these
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`increasingly complex devices. The inventors recognized that users habitually turn
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`on the display of their devices while on the move. Id., 1:45-49. Accordingly, the
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`inventors developed technologies involving use of an activation button to perform
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`predetermined functions at the same time as turning on the display. Id., 1:52-56.
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`The activation button can be used, for instance, to turn on the display and perform a
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`user identification process, such as fingerprint, facial, or iris recognition. Id., 8:3-
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`20. To further enhance user experience, the inventors also recognized that the user
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`would prefer that the display turn on while authentication is being performed. See
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`Ex. 1001, claim 1. This configuration gives the user assurance that the terminal is
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`operating normally and, as such, successfully received the user’s identifying
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`biometrics (despite authentication being in process). In addition, the function(s)
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`performed may differ based on how the user presses the activation button. For
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`example, a single press of the button can turn on the display and initiate one
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`function, while a double or long press can turn on the display and initiate yet
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`another function. Id., 4:51-5:13.
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`The claims of the ’373 patent are directed to using the activation button to
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`turn on a touch screen display and to initiate additional functions (such as
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`fingerprint authentication) in response to a one-time pressing of the activation
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`button. See, e.g., id., claim 1. Claim 1 (as corrected in the certificates of correction)
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`is representative:
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`1. A mobile communication terminal comprising:
`a touch screen display;
`a camera;
`a power button configured to turn on and off the terminal by pressing;
`and
`an activation button separate from the power button and located
`outside the touch screen display, the activation button
`configured for pressing to turn on the touch screen display and
`to initiate one or more additional functions of the terminal,
`wherein the terminal has a first function and a second function to
`perform in response to user input via the activation button and is
`configured to provide user settings for configuring at least one
`of the first and second functions such that at least one of the first
`and second functions is set to be performed in addition to
`turning on the touch screen display upon pressing of the
`activation button while the touch screen display is turned off,
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`wherein the first and second functions are different from each
`other and selected from the group consisting of fingerprint
`authentication, activating the camera, playing music and a
`hands-free function,
`wherein upon one-time pressing of the activation button while the
`touch screen display is turned off, the terminal is configured to
`turn on the touch screen display and further perform at least one
`of the first and second functions in addition to turning on the
`touch screen display such that:
`a lock screen is displayed on the touch screen display upon turning on
`the touch screen display in response to the one-time pressing of
`the activation button while the touch screen display is turned off,
`in response to the one-time pressing of the activation button, the first
`function is performed in addition to turning on the touch screen
`display for displaying the lock screen thereon, and
`the second function is performed when the one-time pressing is for a
`long time, longer than a reference time period,
`wherein at least one of the first and second functions is performed
`subsequent to turning on the touch screen display and displaying
`the lock screen in response to the one-time pressing of the
`activation button,
`wherein the touch screen display displays the lock screen when at least
`one of the first and second functions is being performed.
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` Independent claim 11 is substantively similar.
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`III. Claim Construction
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`Claim terms subject to inter partes review are to be “construed using the
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`same claim construction standard that would be used to construe the claim in a civil
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`action under 35 U.S.C. 282(b), including construing the claim in accordance with
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`the ordinary and customary meaning of such claim as understood by one of ordinary
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`skill in the art and the prosecution history pertaining to the patent.” 37 C.F.R. §
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`42.100(b). Petitioner has not argued for any claim elements to be construed and, for
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`the purposes of this preliminary response, Patent Owner does not seek the
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`construction of any term.
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`IV. SUMMARY OF THE REFERENCES
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`A. Griffin
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`Griffin (Ex. 1027) is a United States Patent Application dated May 31, 2012,
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`with a filing date of November 29, 2010. It was considered by the examiner during
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`prosecution and is listed as a reference cited in the ’373 patent. Griffin is titled
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`“Multiple Input Device Lock and Unlock” and generally describes unlocking a
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`device, which can refer either to waking the device or moving the device from a
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`secure mode to an unsecure mode, via two different inputs from the user. Ex. 1027
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`at [0024]-[0025]. For example, Griffin discloses that a user may unlock a device by
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`pressing a button and then swiping in a specific way across the screen. See Ex.
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`1027, Figs. 5A-5C. Griffin makes clear that a single input, such as a button press, is
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`not enough to unlock a device: “[I]t can be seen that the foregoing methods and
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`devices are configured to permit the device 100 to transition from a locked to an
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`unlocked state not simply on the basis of a single type of input, such as a keypress
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`or a single touch-screen gesture, but on the basis of a two-input or multiple-input
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`action that must be detected across a plurality of user input interfaces provided on
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`the device 100.” Ex. 1027 at [0116].
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`B. Goertz
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`Goertz (Ex. 1013) is a U.S. Patent Application Publication dated January 21,
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`2010, bearing a filing date of June 17, 2009. Goertz is titled “User Interface for
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`Mobile Computer Unit,” and its Abstract explains that the invention relates to
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`providing a touch screen interface that presents keys in a way that facilitates entry
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`of Chinese characters using stroke and Pinyin input. Ex. 1013 at Abstract.
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`Figures 12-15 show various “Key lock” functions of the phone. Figure 12
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`depicts, for instance, the device with a lock gadget and explains that by pressing the
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`lock gadget, the phone is then locked. The specification explains that when the
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`phone is locked, activation of the phone is restricted in some manner, “e.g., when
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`the phone is locked, touching the screen in a way that would activate a gadget when
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`the phone is unlocked, does not activate the gadget when the phone is locked.” Ex.
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`1013 at [0060]. Goertz explains that unlocking the phone is achieved by activating a
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`home key. Id. Goertz further explains that in a “Key lock high security mode,” as
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`depicted in Figure 15, a keypad is displayed and a user is prompted to enter a
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`security code after the home key is activated (such as by touching the home key).
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`Once the proper code is entered, the phone is unlocked. And Goertz also discloses
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`that “[o]ptionally, additional security is implemented by use of fingerprint
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`identification, wherein the phone cannot be unlocked unless a fingerprint is
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`authenticated.” Id. at [0061]. Notably, Goertz does not disclose that the
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`authentication process is any different when fingerprint recognition is used instead
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`of a security code. In other words, Goertz is limited to a multi-step process,
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`requiring multiple user inputs to unlock the device. Goertz never presents an
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`embodiment in which a one-time pressing of a button will both unlock a device and
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`perform an authentication function.
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`C. Davis
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`Davis (Ex. 1015) is the secondary reference that Petitioner includes in
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`separate combinations with Griffin and Goertz. Davis is a U.S. Patent Application
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`Publication dated June 3, 2010, with a filing date of December 1, 2008. It is titled
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`“System and Method of Providing Biometric Quick Launch” and relates to easing
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`the burden of multi-factor authentication by causing a device to both unlock and
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`launch a specific application once the biometric portion of the multi-step
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`authentication procedure is complete. Ex. 1015 at Abstract, Figure 5, [0077]. In its
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`background, Davis criticizes the use of single-factor, password-based authentication
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`to secure a device, and notes that two-factor or three-factor authentication using a
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`smart card and/or biometric information is more secure. Ex. 1015 at [0002]-[0004].
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`Davis recognizes that three-factor authentication, in particular, can be cumbersome.
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`It thus proposes that “a user may associate a specific application with a stored
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`fingerprint template such that the specific application may be launched, if not
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`already executing, on the mobile device 102 responsive to provision of [a]
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`fingerprint to the fingerprint sensor 325.” Ex. 1015 at [0054]. Notably, nothing in
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`Davis discusses the use of a button to turn on a display screen, let alone use that
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`button to turn on the display screen and perform another function, like fingerprint
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`authentication.
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`D.
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`iOS
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`iOS (Ex. 1007) is a User Guide for the iPhone OS 3.1 software that, like
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`Davis, Petitioner includes in the combinations with Griffin and Goertz. Petitioner
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`refers to the manual for the presence of an iPhone home button that is separate from
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`a power button and that has certain software settings functions. According to
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`Petitioner, the home button depicted in the manual is used to turn on the device
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`display, and, according to Petitioner, iOS 3.1 was the operating system deployed in
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`iPhones as of September 9, 2009. For the purposes of this Response, Patent Owner
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`does not contest either point as immaterial to the denial of institution; though
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`whether the manual actually supports the proposition that the home button activates
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`the display is, at best, unclear.
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`V. APPLICABLE LEGAL STANDARDS
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`A.
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`Standard for Institution
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`The Board may only grant a petition for inter partes review where “the
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`information presented in the petition . . . shows that there is a reasonable likelihood
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`that the petitioner would prevail with respect to at least 1 of the claims challenged
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`in the petition.” 35 U.S.C. § 314(a); 37 C.F.R. § 42.108(c). Petitioner bears the
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`burden of showing that this statutory threshold has been met. See Office Patent
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`Trial Practice Guide, 77 Fed. Reg. 48,756, 48,756 (Aug. 14, 2012) (“The
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`Board . . . may institute a trial where the petitioner establishes that the standards for
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`instituting the requested trial are met . . . .”).
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`B. Obviousness
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`Section 103 of the Patent Act provides that “[a] patent may not be
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`obtained . . . if the differences between the subject matter sought to be patented and
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`the prior art are such that the subject matter as a whole would have been obvious at
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`the time the invention was made to a person having ordinary skill in the art to which
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`said subject matter pertains.” 35 U.S.C. § 103(a). If a single element of the claim is
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`absent from the prior art, the claims cannot be considered obvious. See CFMT, Inc.
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`v. YieldUp Int’l Corp., 349 F.3d 1333, 1342 (Fed. Cir. 2003) (“[O]bviousness
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`requires a suggestion of all limitations in a claim.”) (citing In re Royka, 490 F.2d
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`981, 985 (C.C.P.A. 1974)); In re Rijckaert, 9 F.3d 1531, 1534 (Fed. Cir. 1993)
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`(reversing obviousness rejection where prior art did not teach or suggest all claim
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`limitations); Garmin Int’l, Inc. v. Patent of Cuozzo Speed Techs. LLC, Case No.
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`IPR2012-00001, Paper 15 at 15 (PTAB Jan. 9, 2013) (refusing to institute an inter
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`partes review under 35 U.S.C. § 103 where prior art did not disclose all claim
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`limitations).
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`Further, “[o]bviousness requires more than a mere showing that the prior art
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`includes separate references covering each separate limitation in a claim under
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`examination.” Unigene Labs., Inc. v. Apotex, Inc., 655 F.3d 1352, 1360 (Fed. Cir.
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`2011) (citing KSR Int’l. Co. v. Teleflex Inc., 550 U.S. 398, 418 (2007)). “Rather,
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`obviousness requires the additional showing that a person of ordinary skill at the
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`time of the invention would have selected and combined those prior art elements in
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`the normal course of research and development to yield the claimed invention.” Id.
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`In other words, if a proposed modification or enhancement of a first prior art
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`reference through the combination of a second prior art reference would result in
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`the first reference being rendered unsuitable for its intended purpose, then there is
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`no suggestion or motivation to make the proposed modification or enhancement. In
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`re Gordon, 733 F.2d 900, 221 USPQ 1125 (Fed. Cir. 1984); see also M.P.E.P §
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`2143.01(V).
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`As explained below, Petitioner has not established a reasonable likelihood
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`that any challenged claims are unpatentable as obvious.
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`VI. THE PETITION DOES NOT DEMONSTRATE THAT THE
`CHALLENGED CLAIMS ARE UNPATENTABLE UNDER GROUND 1.
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`The Petition fails to demonstrate a reasonable likelihood that any challenged
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`claim is unpatentable under Ground 1. Ground 1 is a three-reference obviousness
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`combination comprised of Griffin, Davis, and iOS. The suggested combination does
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`not disclose turning on the touch screen display (displaying a lock screen) and
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`further performing a first function in response to a one-time pressing of the
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`activation button—an element common to all challenged claims. See claim elements
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`labeled [1j] (“in response to the one-time pressing of the activation button, the first
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`function is performed in addition to turning on the touch screen display for
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`displaying the lock screen thereon”) and [11g] (“in response to the one-time
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`pressing of the activation button, the first function is performed in addition to
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`changing to the active state for displaying the lock screen”). This ends the inquiry.
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`Nevertheless, the included references are not properly combined in the first place,
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`and thus cannot invalidate the challenged claims.
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`A. Griffin Does Not Disclose Turning on the Display (Displaying a
`Lock Screen) and Performing a First Function in Response to a One-
`Time Pressing of the Activation Button.
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`Petitioner asserts that Griffin discloses an activation button that turns on the
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`display and performs a first function because it discloses that, upon receiving a first
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`user input (a press of a button), a second user input interface is activated (which
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`accepts a swipe of a finger or other user input). Pet. at 34. In other words, in a
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`sleight of hand, Petitioner is saying that a press of a button turns on the display
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`(though it remains dark) such that the display can accept a second user input (the
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`turning on of the display for this purpose being the first function of the challenged
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`claims). Thus Petitioner essentially argues that turning on the display IS the first
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`function. This cannot be the case. Turning on the display and performing a first
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`function are two different things altogether. The challenged claims make this clear.
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`Indeed, the challenged claims require more than the activation of the display
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`to accept user input—they require display of a lock screen AND that the first
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`function (performed in response to a one-time pressing of the activation button) be
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`one of “fingerprint authentication, activating the camera, playing music and a
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`hands-free function.” Griffin neither discloses turning on the display to display a
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`lock screen nor the performance of any separate (enumerated) function in response
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`to a single press of an activation button.
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`Even if Griffin can be said to disclose a sufficient first function, however, it
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`discloses only a multi-step process requiring multiple user inputs to activate the
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`display (thus displaying a lock screen) and perform any device function; not the
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`one-step process of the challenged claims. Griffin’s multi-step process is
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`diagrammed in Figure 10 (reproduced and annotated below):
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`
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`The device begins in locked state 1000, in which “only minimal user input
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`interfaces may be activated to receive a user input.” Ex. 1027 at [0117]. In response
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`to a first unlock input, such as a key press, the device moves to an input enabled
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`state 1010. “While in the input enabled state 1010, the device activates a further
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`input interface, and awaits further input.” Id. (emphasis added). It is only after the
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`device receives a second unlock input while in the input enabled state does the
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`device move to unlocked state 1020. Thus, the only function performed by Griffin
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`in response to the activation button is entering a state in which it will be able to
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`receive further user input—which is no function at all.
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`B.
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`The Deficiencies of Griffin Are Not Resolved by Davis.
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`Davis does not cure Griffin’s deficiencies. Like Griffin, Davis does not
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`disclose a one-time pressing of the activation button that both turns on the display
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`and performs a first function. Davis instead discloses a multi-stage authentication
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`system requiring multiple user inputs.
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`Petitioner’s argument focuses on Figure 4 (reproduced and annotated below):
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`As Petitioner recognizes, Figure 4 discloses “a combination of procedures to unlock
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`a device.” Pet. at 16. Specifically, the device initially receives an unlock command
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`when the user makes a selection from a dialog displayed on a mobile device
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`(highlighted in blue). Ex. 1015 at [0048]. In response, the device “arranges for the
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`presentation of a unlock dialog (step 404) to prompt the user to enter authentication
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`factors, such as a device and/or a smart card password.” Id. The password entry
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`steps are highlighted in red and purple in the annotated Figure 4. The system then
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`continues to verify the information. If a match is found, as shown highlighted in
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`yellow, the system “presents a dialog on the display to prompt the user to provide a
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`fingerprint candidate.” Id. at [0049]. “Responsive to being prompted (step 416) to
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`provide a fingerprint, it is expected that the user will provide a fingerprint to the
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`fingerprint sensor . . . .” Id. at [0051].
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`In essence, there are multiple steps involved in the authentication process of
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`Davis. Various dialogs are presented, and, in no way, is a device awakened and a
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`user authenticated in response to a one-time pressing of an activation button. Thus,
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`Davis lacks this crucial element of the challenged claims.
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`Petitioner presents a heavily-modified version of Figure 4 in its Petition
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`(reproduced below), in which all methods of authentication are omitted, except for
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`fingerprint authentication:
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`This is inappropriate. “It is impermissible within the framework of section 103 to
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`pick and choose from any one reference only so much of it as will support a given
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`position to the exclusion of other parts necessary to the full appreciation of what
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`such reference fairly suggests.” Bausch & Lomb v. Barnes-Hind/Hydrocurve, 796
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`F.2d 443, 448 (Fed. Cir. 1986). Nevertheless, Petitioner argues that “a single
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`biometric input mechanism may have been used to unlock a device and launch an
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`application” and that this alteration is appropriate because Davis discloses that
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`“many embodiments will only require a subset of the authentication factors
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`discussed in this application.” Pet. at 18 (emphasis added). But even Petitioner’s
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`modified Figure 4 requires multiple steps. First, the unlock command is received at
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`step 402 (in blue). Then, a fingerprint dialog is presented to the user (shown in
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`yellow), and the user provides a fingerprint in response. Ex. 1015 at [0052]. Thus,
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`even in the scenario presented by Petitioner, the reference requires more than a one-
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`time pressing to unlock the device—it requires multiple user inputs. Given that
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`neither Griffin nor Davis can satisfy this limitation (and Petitioner does not assert
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`that iOS satisfies this claim limitation1), the combination cannot satisfy the claim.
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`C. A POSITA Would Not Combine Griffin With Davis to Arrive at
`the Claimed Invention.
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`Finally, even if Petitioner could show that a Griffin / Davis combination2
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`yields the claimed invention, Petitioner has failed to demonstrate that Griffin and
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`Davis are properly combined. Indeed, a POSITA would not combine Griffin with
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`Davis in the proposed manner because they each teach away from the simplicity
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`achieved by the challenged claims.
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`1 Petitioner argues that iOS satisfies the limitation of performing a “second
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`function” based upon a long press of the activation button. Patent Owner does not
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`address the sufficiency of iOS’s disclosure in this response, but only notes that
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`Petitioner has not pointed to iOS for satisfaction of the “first function” claim
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`element.
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`2 Recall that Ground 1 is a three-reference combination that includes iOS. As
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`discussed in Section IV.D., above, Petitioner relies on iOS for the presence of other
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`elements, including a “second function.” Thus, its inclusion in the combination as a
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`secondary reference is immaterial to this Preliminary Response.
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`Griffin and Davis each recognize that unlocking a device should be a
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`complex process. Griffin teaches that a complex wake-up or unlock action may be
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`desirable to prevent accidental waking or unlocking of a device and, thus, requires
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`two separate user inputs. Similarly, Davis teaches that a multi-step authentication
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`process is desirable so that security is maximized. It explicitly criticizes single-
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`factor, password-based authentication while arguing in favor of two- or three-factor
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`authentication. Ex. 1015 at [0002]-[0004]. Thus, combining Griffin and Davis in an
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`effort to invalidate the challenged claims is counterintuitive. A proposed
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`combination cannot make a prior art invention unsatisfactory for its intended
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`purpose. In re Gordon, 733 F.2d 900, 221 USPQ 1125 (Fed. Cir. 1984); see also
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`M.P.E.P § 2143.01(V). A POSITA would not combine Griffin and Davis because
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`doing so runs contrary to the express security consciousness of those disclosures.
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`VII. THE PETITION DOES NOT DEMONSTRATE THAT THE
`CHALLENGED CLAIMS ARE UNPATENTABLE UNDER GROUND 2.
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`The Petition fails to demonstrate a reasonable likelihood that any challenged
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`claim is unpatentable under Ground 2. Ground 2 is a three-reference obviousness
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`combination comprised of Goertz, Davis, and iOS.