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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`SNAP INC.,
`Petitioner
`
`v.
`
`BLACKBERRY LIMITED
`Patent Owner
`
`____________________
`
`Patent No. 8,825,084
`____________________
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`DECLARATION OF DR. SAMRAT BHATTACHARJEE
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`Snap Inc. Ex. 1002 Page 0001
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,825,084
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`TABLE OF CONTENTS
`TABLE OF CONTENTS ........................................................................................... i
`I.
`INTRODUCTION .......................................................................................... 1
`II.
`QUALIFICATIONS ....................................................................................... 1
`III.
`SUMMARY OF OPINIONS .......................................................................... 5
`IV. LEVEL OF ORDINARY SKILL IN THE ART ............................................ 6
`V.
`BACKGROUND OF THE RELEVANT FIELD .......................................... 7
`VI. OVERVIEW OF THE ’084 PATENT ........................................................... 8
`VII. CLAIM CONSTRUCTION ......................................................................... 10
`A.
`“determine at least one action spot within a predetermined
`distance from the current location of the first mobile device.” .......... 10
`VIII. OVERVIEW OF THE PRIOR ART ............................................................ 12
`A. Winkler ............................................................................................... 12
`B.
`Altman................................................................................................. 15
`C.
`Lemmela ............................................................................................. 17
`D.
`Crowley .............................................................................................. 19
`IX. THE PRIOR ART TEACHES OR SUGGESTS ALL THE
`FEATURES OF CLAIMS 1-2, 5-6, 9-10, 12-13, and 15 OF THE ’084
`PATENT ....................................................................................................... 20
`A. Ground 1: Winkler and Altman Teach or Suggest the Features
`of Claims 1-2, 5-6, 9-10, 12-13, and 15 of the ’084 Patent ............... 20
`1.
`Claim 1 ..................................................................................... 20
`2.
`Claim 2 ..................................................................................... 43
`3.
`Claim 5 ..................................................................................... 44
`4.
`Claim 6 ..................................................................................... 44
`5.
`Claim 9 ..................................................................................... 46
`6.
`Claim 10 ................................................................................... 53
`7.
`Claim 12 ................................................................................... 54
`i
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`U.S. Patent No. 8,326,327
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`B.
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`8.
`Claim 13 ................................................................................... 56
`Claim 15 ................................................................................... 57
`9.
`Ground 2: Lemmela and Crowley Teach or Suggest the Features
`of Claims 1-2 and 5-6 of the ’084 Patent ........................................... 58
`1.
`Claim 1 ..................................................................................... 58
`2.
`Claim 2 ..................................................................................... 70
`3.
`Claim 5 ..................................................................................... 71
`4.
`Claim 6 ..................................................................................... 72
`Ground 3: Lemmela and Crowley and Winkler Teach or Suggest
`the Features of Claims 9-10, 12-13, and 15 of the ’084 Patent ......... 73
`1.
`Claim 9 ..................................................................................... 74
`2.
`Claim 10 ................................................................................... 79
`3.
`Claim 12 ................................................................................... 80
`4.
`Claim 13 ................................................................................... 81
`5.
`Claim 15 ................................................................................... 82
`CONCLUSION ............................................................................................. 84
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`C.
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`ii
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`X.
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,825,084
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`I, Dr. Samrat Bhattacharjee, declare as follows:
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`I.
`
`INTRODUCTION
`1.
`I have been retained by Snap Inc. (“Petitioner”) as an independent
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`expert consultant in this proceeding before the United States Patent and Trademark
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`Office (“PTO”) regarding U.S. Patent No. 8,825,084 (“the ’084 patent”) (Ex.
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`1001). I have been asked to consider, among other things, whether certain
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`references teach or suggest the features recited in claims 1-2, 5-6, 9-10, 12-13, and
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`15 (“the challenged claims”) of the ’084 patent. My opinions are set forth below.
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`2.
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`I am being compensated at my normal rate of $600 per hour for the
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`time I spend on this matter. No part of my compensation is dependent on the
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`outcome of this proceeding or any other proceeding involving the ’084 patent. I
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`have no other interest in this proceeding.
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`II. QUALIFICATIONS
`3. My qualifications for forming the opinions in this report are
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`summarized here and explained in more detail in my curriculum vitae, which I
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`understand is provided as Exhibit 1003.
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`4.
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`I earned a Ph.D. in Computer Science from Georgia Institute of
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`Technology in 1999. Before that, I earned Bachelor of Science degrees in
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`Mathematics and Computer Science from Georgia College and State University in
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`1
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`U.S. Patent No. 8,825,084
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`1994. I was a Teaching Assistant at the Georgia Institute of Technology from
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`1994 to 1995 and an Instructor in 1998.
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`5.
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`From 1999 through 2005, I was an Assistant Professor at the
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`University of Maryland, College Park, in the Department of Computer Science,
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`and then an Associate Professor with tenure from 2005 through 2009. In 2006, I
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`was a Visiting Professor at Max Planck Institüt für Software Systems in
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`Saarbrücken, Germany. In 2007, I was a Visiting Researcher at AT&T Labs in
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`Florham Park, New Jersey.
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`6.
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`Since 2009, I have been a tenured Professor at the University of
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`Maryland. My teaching and research have focused on systems, security, and
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`computer networking, including mobile systems and all aspects of the technologies
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`pertaining to the ’084 patent.
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`7.
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`I have served as a reviewed for ACM/IEEE Transactions on
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`Networking, IEEE Journal on Selected Areas in Communications, Computer
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`Communications Journal (Special Issue on Network Security), ACM Transactions
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`on Computer
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`Systems,
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`Performance Evaluation
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`Journal, Computer
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`Communications Review, European Transactions on Telecommunications, IEEE
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`Transactions on Parallel and Distributed Systems, and ACM Transactions on
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`Internet Technology.
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`2
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,825,084
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`I am the author of numerous publications in the field of computer
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`8.
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`networking. Including journal articles, book chapters, publications in proceedings,
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`technical reports, and invited papers.
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`9.
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`I have been active in a number of professional organizations and
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`conferences. I have served with the National Science Foundation (NSF) Workshop
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`on Network Testbeds, the NSF Networking Research Panel, the Department of
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`Education High Performance Networking Panel, and as an Evaluator for the Intel
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`Science Talent Search.
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`10.
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`I have received several honors and awards. These include: the Alfred
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`P. Sloan Jr. Fellowship; the Best Paper Award, 14th Annual IEEE International
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`Conference on High Performance Computing (HiPC) (with Vijay Gopalakrishnan,
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`Ruggero Morselli, Peter Keleher, and Aravind Srinivasan); the Best Paper Award,
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`7th IEEE/ACM Conference on Grid Computing (with Jiksoo Kim, Byomsuk Nam,
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`Peter Keleher, Michael Marsh, and Alan Sussman); and the NSF CAREER Award.
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`I also received Teaching Excellence Awards in 2004, 2008, and 2012.
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`11.
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`In 2017, along with colleagues from Cornell University and the Max
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`Planck Society in Germany, I started an annual school for introducing
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`undergraduate students from across the world to research. This school is partially
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`supported by the NSF and had student participants from 29 countries.
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`I am the co-director of a new joint Ph.D program in computer science
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`12.
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`between the University of Maryland and the Max Planck Society in Germany.
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`13.
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`I am the co-inventor of four patents: U.S. Patent No. 7,181,623
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`(entitled “Scalable Wide-Area Upload System and Method”); U.S. Patent No.
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`7,940,850 (entitled “Method for Encoding Frame Data”); U.S. Patent No.
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`8,397,284 (entitled “Detection of Distributed Denial of Service Attacks in
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`Autonomous System Domains”); and U.S. Patent No. 8,554,941 (entitled “Systems
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`and Methods for Distributing Video on Demand”).
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`14.
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`I have been involved in other non-University Panels and Positions. I
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`was Co-Chair of the Internet Research Task Force (IRTF) Peer-to-Peer Research
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`Group from 2003-2009. I was Co-Program Committee Chair for NetEcon 2009
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`Workshop and was Committee Member for INFOCOM in 2008-2009 and for
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`Sigmetrics in 2007-2009.
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`15.
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`I have served as an advisor to several Ph.D., Master’s, and
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`Undergraduate’s degree candidates. I am currently an advisor to two Ph.D.
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`candidates.
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`16. As shown in Exhibit 1003, I have published extensively in the field of
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`computer networking, wireless systems, mobile systems, operating systems, and
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`U.S. Patent No. 8,825,084
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`computer security. A more complete list of my publications, authorships, and
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`editorial positions can be found in Exhibit 1003.
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`III. SUMMARY OF OPINIONS1
`17. All of the opinions contained in this Declaration are based on the
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`documents I reviewed and my professional judgment, as well as my education,
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`experience, and knowledge regarding commuter networking.
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`18.
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`In forming my opinions expressed in this Declaration, I reviewed the
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`’084 patent (Ex. 1001); U.S. Patent No. 8,750,906 to Winkler et al. (“Winkler”)
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`(Ex. 1004); U.S. Patent Application Publication 2008/0250337 A1 to Lemmela et
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`al. (“Lemmela”) (Ex. 1005); U.S. Patent Application Publication 2007/0281716 A1
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`to Altman et al. (“Altman”) (Ex. 1006); the prosecution file history for the ’084
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`patent (Ex. 1007); and U.S. Patent No. 7,593,740 to Crowley et al. (“Crowley”)
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`(Ex. 1008). My opinions are additionally guided by my appreciation of how a
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`person of ordinary skill in the art would have understood the claims of the ’084
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`1 My citations to non-patent publications are to the original page numbers of the
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`publication, and my citations to U.S. Patents are to the column:line number or
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`paragraph number of the patents or published patent applications, as applicable.
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`U.S. Patent No. 8,825,084
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`patent at the time of the alleged invention, which, for purposes of this petition, I
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`assume is August 27, 2010.
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`19. Based on my experience and expertise, it is my opinion that certain
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`references teach or suggest all the features recited in claims 1-2, 5-6, 9-10, 12-13,
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`and 15 of the ’084 patent.
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`IV. LEVEL OF ORDINARY SKILL IN THE ART
`20. At the time of the alleged invention, in August 2010, a person of
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`ordinary skill in the art would have had at least a B.S. degree in computer science,
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`electrical engineering, or equivalent thereof, and at least two years of experience in
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`the relevant field, e.g., computer networking. More education can substitute for
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`practical experience and vice versa. I apply this understanding in my analysis
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`herein.
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`21.
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`In determining the level of ordinary skill, I have been asked to
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`consider, for example, the types of problems encountered in the art, prior solutions
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`to those problems, the rapidity with which innovations are made, the sophistication
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`of the technology, and the educational level of active workers in the field.
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`22. My analysis of the ’084 patent and my opinions in this declaration are
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`from the perspective of one of ordinary skill in the art, as I have defined it above,
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`U.S. Patent No. 8,825,084
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`during the relevant time frame stated above. During this time frame, I possessed at
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`least the qualifications of a person of ordinary skill in the art, as defined above.
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`V. BACKGROUND OF THE RELEVANT FIELD
`23. The ’084 patent generally relates to mobile devices, and in particular
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`determining what the patentee refers to as “action spots” based on the locations and
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`activities of mobile devices.
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`24. At the time the patent was filed, the basic technology for determining
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`the location of a mobile device was well known.
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`25. Logging the actions undertaken by the mobile device, perhaps at the
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`behest of its user, was also well known. Such actions included, for instance,
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`sending emails, text messages, making a photograph or video.
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`26. Sending information from a mobile device to a server connected to a
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`network was also well known. Such information could include the device's
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`location, or a log of the device's activity. Similarly, receiving information at a
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`mobile device from a server was also commonly known.
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`27. Applications that displayed a map, directions, or bearing were also
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`well known, and denoting points of interests on a display of a mobile device by
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`overlaying information on a map was common.
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`U.S. Patent No. 8,825,084
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`VI. OVERVIEW OF THE ’084 PATENT
`28. The ’084 patent, titled “System and Method for Determining Action
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`Spot Locations Relative to the Location of a Mobile Device” is generally directed
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`to determining and displaying the location of mobile device activity on a map.
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`(Ex. 1001, Abstract.) The ’084 patent recognizes that previously existing mobile
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`devices could retrieve maps and directions for locations relative to a mobile device.
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`(Id., 1:36-39.) The ’084 patent also recognizes that prior device users could
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`determine “events and happenings” occurring proximate to a mobile device’s
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`location and manually compare the location of such events to the mobile device’s
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`location, which could be “tedious.” (Id., 3:11-23.)
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`29. The ’084 patent explains that an “action spot” refers to a location or
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`an event where at least one other mobile device engages in activity. (Id., 3:3-5.)
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`This “activity” may include a “documenting action” (such as text messaging,
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`emailing, blogging, posting a message on a social networking internet site), a
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`“recording action,” (such as video recording, audio recording, or photographing) or
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`“any other action where the mobile device is being used to observe and make note
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`of a location or an event currently occurring at the location of the mobile device.”
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`(Id., 2:61-3:3.)
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`U.S. Patent No. 8,825,084
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`30. The ’084 patent also teaches that action spots may be determined
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`within a “predetermined distance” from a mobile device and may correspond to
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`device activity occurring within a “predetermined period of time.” (Id., 3:34-35,
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`40-42.) This predetermined distance and predetermined period of time can be set
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`manually by the user, or can be predefined by the software application developer,
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`the server provider, the manufacturer of the mobile device, or the communication
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`network service provider. (Id., 8:24-32, 37-44.) This predetermined distance can
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`be any specific distance from the current location of the mobile device; this
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`predetermined period of time can be any specific time period that is measured from
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`the time the mobile device arrived at the current location. (Id., 8:32-37, 44-48.)
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`31. The ’084 patent teaches that action spots may be displayed with an
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`indication of activity level occurring at each spot. (Id., Abstract.) Graphical items
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`associated with action spots may employ colors, shapes, or sizes, to display the
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`relative level of activity occurring at the spot. (Id., 10:9-14.) For example, “the
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`graphical item associated with the action spot 410 can have a green color to
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`indicate that the most activity is occurring at that action spot 410. The graphical
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`item associated with the action spot 406 can be orange to indicate that the action
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`spot 406 has the second most activity.” (Id., 10:14-19.)
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`U.S. Patent No. 8,825,084
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`VII. CLAIM CONSTRUCTION
`32.
`I understand that a claim subject to inter partes review is construed in
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`accordance with the ordinary and customary meaning, as understood by one of
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`ordinary skill in the art and the prosecution history pertaining to the patent. I have
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`followed these principles in forming my opinions in this declaration.
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`A.
`“determine at least one action spot within a predetermined
`distance from the current location of the first mobile device.”
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`33. All challenged claims recite “determine at least one action spot within
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`a predetermined distance from the current location of the first mobile device.”
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`9Ex. 1001, 19:30-21:7.)
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`34.
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`I understand that Petitioner has offered that this phrase should mean
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`“determine each action spot within a specific distance from the current location of
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`the first mobile device, the specific distance being set prior to the determining
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`step.” I have used this construction unless otherwise noted.
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`35.
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`I agree that this construction is consistent with the ’084 patent’s
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`claims and specification. For example, ’084 patent describes the predetermined
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`distance as specific distances: “[t]he predetermined distance can be within five
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`blocks, ten blocks, ten yards, one hundred yard, one hundred feet, thirty feet, ten
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`meters, fifteen meters, five miles, ten miles, twelve miles, twenty miles, or any
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`other distance from the current location 302 of the mobile device 100.” (Id., 8:32-
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`37.) Beyond a fixed specific distance, the ’084 patent does not provide guidance
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`as to the meaning of “predetermined distance.” In particular, the specification does
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`not contemplate that a “predetermined distance” could be a range, or the output of
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`a computer algorithm.
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`36. Also, a person of ordinary skill in the art would understand that the
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`“predetermined distance” must be set prior to the determination of action spots.
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`The determination of action spots is limited to action spots “within a
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`predetermined distance from the current location of the mobile device.” (Id.,
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`19:29-21:67.) Therefore, the “distance” must be determined before action spots
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`are determined.
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`37. A person of ordinary skill would also understand that each action spot
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`within a specific distance from the current location of the first mobile device must
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`be determined. This limitation recites “at least one action spot,” but the
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`specification does not explain how a system would treat action spots within the
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`“predetermined distance from the mobile device” differently so that some action
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`spots within that distance would be “determined” and others would not. Without
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`interpreting this limitation as applying to each action spot, the ’084 patent thus
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`fails to inform a person of ordinary skill in the art about the claim’s scope.
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`U.S. Patent No. 8,825,084
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`VIII. OVERVIEW OF THE PRIOR ART
`A. Winkler
`38.
` Winkler generally relates to a system for determining and displaying
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`dynamic elements on a mobile device’s map application. (Ex. 1004, Abstract.)
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`Winkler labels these elements as “map elements,” which may correspond to
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`locations where mobile devices have performed actions at various locations. (Id.,
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`1:8-12; 2:14-26; 10:40-52; 12:5-10.)
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`39.
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`“Map elements” may be dynamically modified based on “events”
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`occurring at a user’s mobile device or at other locations associated with map
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`elements. (Id., 10:1-7.) “Events” can reflect movement of mobile devices near a
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`“map element” or activity on a mobile device, such as posting comments,
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`associated with a “map element.” (Id., 10:40-47). When the occurrence of an
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`event is detected, the associated “map element” may change color, blink, or issue
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`an audible signal, and an updated “map element” will be displayed. (Id., 10:54-64;
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`11:6-26.) For example, Figures 6A-6C display mobile device screens with a “map
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`element” dynamically changing based on the occurrence of an “event”:
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`(Id., FIG. 6.)
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`40. Winkler also teaches use of “map elements” to display additional
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`information on a map. (Id., 11:66-12:2.) For example, Winkler teaches “heat
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`map[s],” which display zones with varying concentrations of user activity:
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`(Id., FIG. 7A; 12:4-10.) The highlighted areas 710, 720, 730 represent different
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`zones. (Id., 12:4-10, 12:45-46.) The zones are colored based on the amount of
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`activity in each region. (Id., 12:45-51.) Activity in a zone may equate to, for
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`example, the number of “map elements,” mobile device users, or comments posted
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`about locations within that region. (Id., 12:5-10.) The Winkler system can also
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`filter information shown on a map based on user feedback and/or input. (Id.,
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`12:25-26.) Although different examples of the Winkler system are described,
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`Winkler emphasizes that all examples are part of the same system. (See, e.g., id.
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`14:17-41 (“The elements and acts of the various examples described [] can be
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`combined to provide further implementations of the system.”))
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,825,084
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`B.
`Altman
`41. Altman generally relates to a system for location-based mobile
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`communications. (Ex. 1006, ¶ 2, 5-6.) Altman discusses how existing methods of
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`mobile communication are not optimized based on the relative locations of
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`communicating users. (Id., ¶ 4.) Specifically, these systems are not optimized for
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`facilitating communication when users are within certain proximity of a particular
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`location or to one another. (Id.) Altman thus teaches a mobile communication
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`system that initiates communication among users based the users’ current device
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`location. (Id., Abstract.)
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`42. Altman teaches a “location-based social network manager process”
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`and a “mobile communication device that incorporates a real-time map.” (Id., ¶
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`29.) In general, the process first determines the current location of a mobile
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`device. (Id., ¶ 7.) It then displays a map representation of an area, for example,
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`the area surrounding the mobile device. (Id.) The process then superimposes on
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`the map the locations of other user devices. (Id.) Messaging using the
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`communications capability of a mobile device can then incorporate this location
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`information. (Id.) This allows users’ interactions to be based on their relative
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`location to each other. (Id.)
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`U.S. Patent No. 8,825,084
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`43. Altman teaches one embodiment in which the location-based social
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`network manager includes a point of interest (POI) feature. (Id., ¶ 54.) This
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`feature allows device users to program and share points of interest with one
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`another. (Id.) It also allows the system to use a users’ location to determine which
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`POI might be of interest to her. (Id.) Altman teaches that the POI feature can also
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`include an auto messaging mechanism which sends an alert to a user based on the
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`POI of another user. (Id., ¶ 59.) For example, one user can tag a location as a POI,
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`and then be alerted when her friend gets within a specific distance of this POI:
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`(Id., FIG. 9; ¶ 59.) In Figure 9, the system alerts the user when her friend Cindy is
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`within 0.5 miles from her. (Id.) This specific distance may be set by the user in
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`advance. (Id., ¶ 60.)
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,825,084
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`C.
`Lemmela
`44. Lemmela generally relates to determining and displaying information
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`regarding location-based electronic postings. (Ex. 1005, ¶ 1.) Lemmela teaches
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`determining “interesting locations” by utilizing other device users’ location-based
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`electronic postings. (Id., ¶¶ 7, 9.) “Interesting locations” are determined by
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`analyzing other users’ location-based postings and identifying information which is
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`common in postings within a geographic area. (Id.) For example, if various
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`neighboring postings contain the same salient word(s), those words are determined
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`to be common to postings in the area, and therefore are likely to be reliable and
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`useful. (Id.) The taught system then groups postings which exist within a
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`particular geographic area and contain the same salient words. (Id., ¶¶ 7, 9, 11.) A
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`mobile device may display graphics representing information based on such
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`groupings:
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`U.S. Patent No. 8,825,084
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`(Id., FIG. 1; ¶ 26.) In Figure 1, a “display 20 shows a map of an area of interest.”
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`(Id.) To illustrate “an overall picture of the activities, services, sights and
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`atmosphere” of the area, the information regarding the most salient words used in
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`public postings can be presented to the user. (Id.) This information “may [be] in
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`the form of a cloud 24 or 26.” (Id., ¶ 27.) In this illustration, “cloud 24 indicates
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`an area with several shopping opportunities,” as determined by postings within the
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`bordered area. (Id., ¶¶ 26, 27.) Similarly, “cloud 26 indicat[es] an area [where
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`location postings mention] one or more cafes.” (Id.)
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`45. Lemmela teaches signifying the relative amount of device activity at
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`each grouped posting location. (See ¶¶ 12, 28.) For example, “the display of
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`U.S. Patent No. 8,825,084
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`information may take the form of a heat map, in which certain areas are colored
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`based on the information being presented.” (Id., ¶¶ 12, 28.) Different colors may
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`be used based on the density of location postings in the area. (Id.) Size variations
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`may also be used to show the popularity of a certain word within an area’s
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`location-based electronic postings. (Id., ¶ 29.) Although different examples of the
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`Lemmela system are described, Lemmela emphasizes that all examples are part of
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`the same system. (See, e.g., id., ¶ 46 (“For example, each of the elements of the
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`aforementioned embodiments may be utilized alone or in combination or
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`subcombination with elements of the other embodiments.”))
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`D. Crowley
`46. Crowley generally relates to “location-based social software for
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`mobile devices.” (Ex. 1008, 2:19-21.) Crowley teaches a system and method for
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`location-based communication between mobile device users. (See id., 2:32-38.) In
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`one aspect, Crowley teaches a system which determines the location of multiple
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`user devices, receives a message from a first user, and sends this message to other
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`users based on the proximity of the first user to the other users. (Id., 2:32-38.) To
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`determine whether users are sufficiently “proximate” to each other, a distance
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`parameter is set. (Id., 12:53-64.) This distance may be a “predetermined distance
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`(e.g., ten blocks) or may vary based on location (e.g., closer for areas, like a
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`U.S. Patent No. 8,825,084
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`downtown, where people can expect to walk from venue to venue).” (Id., 12:60-
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`64.)
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`IX. THE PRIOR ART TEACHES OR SUGGESTS ALL THE
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`FEATURES OF CLAIMS 1-2, 5-6, 9-10, 12-13, AND 15 OF THE ’084
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`PATENT
`A. Ground 1: Winkler and Altman Teach or Suggest the Features of
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`Claims 1-2, 5-6, 9-10, 12-13, and 15 of the ’084 Patent
`47.
`In my opinion, the combination of Winkler and Altman teaches or
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`suggests all of the features of claims 1-2, 5-6, 9-10, 12-13, and 15 of the ’084
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`Patent. Below, I address each of these claims and their respective limitations.
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`1.
`Claim 1
`48. As described below, the combination of Winkler and Altman teaches
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`or suggests the features of claim 1:
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`Claim Language
`[1a] A server
`configured to:
`
`Winkler and Altman
`For purposes of this analysis, I assume the preamble is
`limiting.
`
`Winkler teaches a system that includes a server. (Ex.
`1004, 2:1-3 (“The system includes two or more mobile
`devices and a server . . . “); 4:41-42 (“The network 220
`may include or communicate with one or more servers
`252 . . .”); 4:49-50 (“components that enable
`communication of information between the servers 252
`and mobile devices”); 5:61 (“the system may include a
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`20
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`Claim Language
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,825,084
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`Winkler and Altman
`content server”); 6:24-25 (“a server 252 within the
`network”); 6:61 (“The system, at server(s) 252 . . .”);
`7:8-9 (“a server 252 within the network 220 . . .”);
`10:35-36 (“the system receives instructions from the
`server 252”); 10:47-48 (“the server 252 monitors
`locations of mobile devices within the network”); 15:14
`(“a server accessible via a telecommunications
`network”).
`
`Winkler teaches a server configured to perform certain
`tasks. Winkler teaches a server which “may store
`location information for the mobile devices, information
`about locations on a map, and so on.” (Id., 2:3-5.)
`Winkler teaches servers which “may display and/or
`present information to users of the mobile devices
`described herein, such as information stored in the
`database 254.” (Id., 4:43-45.) Winkler teaches servers
`which “also include or comprise one or more location
`determination components or devices that detect the
`location of mobile devices within the network.” (Id.,
`4:48-60.) Winkler teaches “content servers” which
`include “a mapping component configured to provide
`instructions to mobile devices that present maps and
`map elements, a location determination component
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`Snap Inc. Ex. 1002 Page 0024
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`Claim Language
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`[1b] receive data
`indicative of a current
`location of a first
`mobile device;
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`Declaration of Dr. Samrat Bhattacharjee
`U.S. Patent No. 8,825,084
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`Winkler and Altman
`configured to identify a location of mobile devices
`within a network, a communication component
`configured to receive and send information to the
`mobile devices, and an event detection component
`configured to detect an occurrence of an event
`associated with the mobile devices.” (Id., 5:61-6:2.)
`Winkler teaches a server configured to receive data
`indicative of a current location of a first mobile device.
`
`Winkler teaches a system which “receives input from
`the user, transmits data to the server 252 identifying a
`location on the map that received the input, information
`identifying the mobile device and, optionally, the
`location of the mobile device.” (Id., 10:20-24.) Winkler
`teaches tha