Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`Invalidity of U.S. Patent No. 10,212,586
`by
`U.S. Patent No. 6,871,063 to Schiffer (“Schiffer ’063”)
`
`
`The excerpts cited herein are exemplary. For any claim limitation, Defendant may rely on excerpts cited for any other limitation and/or
`additional excerpts not set forth fully herein to the extent necessary to provide a more comprehensive explanation for a reference’s
`disclosure of a limitation. Where an excerpt refers to or discusses a figure or figure items, that figure and any additional descriptions
`of that figure should be understood to be incorporated by reference as if set forth fully therein.
`
`Except where specifically noted otherwise, this chart applies the apparent constructions of claim terms as used by Plaintiff in its
`infringement contentions; such use, however, does not imply that Defendant adopts or agrees with Plaintiff’s constructions in any way.
`
`U.S. Patent No. 10,212,586 (“the ’586 Patent”) claims priority to Japanese Application No. 2012-117105, filed May 23, 2012. For
`purposes of these invalidity contentions, Defendant applies the May 23, 2012, priority date for the ’586 Patent. However, Defendant
`reserves the right to contest Plaintiff’s reliance on the May 23, 2012, priority date, should the priority date become an issue in this
`proceeding.
`
`Schiffer ’063 was filed on June 30, 2000 and issued on March 22, 2005. As such, Schiffer ’063 qualifies as prior art with regard to the
`‘586 patent under 35 U.S.C. § 102(a), 102(b), and 102(e). Alternatively, should the claims of the ‘586 patent be found to not be entitled
`to priority to the foreign filing date, Schiffer ’063 qualifies as prior art under §§ 102(a)(1) and 102(a)(2) (post-AIA). Using Plaintiff’s
`interpretation of the claims, Schiffer ’063 anticipates claims 1-2, 6-7, 9-10, 13-14, and 16-18 under 35 U.S.C. § 102(a), (b) and (e).
`
`Alternatively, Schiffer ’063 renders obvious claims 1-2, 6-7, 9-10, 13-14, and 16-18 under 35 U.S.C. § 103(a).
`
`Alternatively, Schiffer ’063 in view of U.S. Patent No. 7,941,534 to de la Huerga (“de la Huerga ’534”) renders obvious claims 1-2, 6-
`7, 9-10, 13-14, and 16-18 under 35 U.S.C. § 103(a). De la Huerga ’534 was filed on June 26, 2004 and was published on April 28,
`2005. As such, de la Huerga ’534 qualifies as prior art with regard to the ‘586 patent under 35 U.S.C. §§ 102(a), 102(b), and 102(e).
`
`Alternatively, Schiffer ’063 in view of U.S. Patent Application Publication No. 2006/0041746 to Kirkup, et al. (“Kirkup ’746”) renders
`obvious claims 1-2, 6-7, 9-10, 13-14, and 16-18 under 35 U.S.C. § 103(a). Kirkup ’746 was filed on August 17, 2004 and published on
`Feb 23, 2006. As such, Kirkup ’746 qualifies as prior art with regard to the ‘586 patent under 35 U.S.C. §§ 102(a), 102(b), and 102(e).
`
`
`
`
`1
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`IPR2020-00202
`Maxell Ex. 2013
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`Alternatively, Schiffer ’063 in view of U.S. Patent No. 8,149,089 to Lin (“Lin ’089”) renders obvious claims 1-2, 6-7, 9-10, 13-14, and
`16-18 under 35 U.S.C. § 103(a). Lin ’089 was filed on November 21, 2008 and issued on April 3, 2012. As such, Lin ’089 qualifies as
`prior art with regard to the ’586 Patent under 35 U.S.C. § 102(a) and 102(e).
`
`
`Schiffer ’063
`
`To the extent the preamble is limiting, Schiffer ’063 teaches “mobile phone 100” (mobile terminal):
`
`
`Mobile phone 100 of FIG. 1 may be any mobile phone capable of long-range communication.
`For example, for one embodiment, mobile phone 100 is a cellular phone, in which case long-
`range transceiver circuit 102 may communicate with a cell base.
`Schiffer ’063 at 2:30-34.
`
`Schiffer ’063’s mobile phone 100 is configured to be unlocked or locked (in which case the ability
`of the phone to send and receive calls is limited):
`
`
`In accordance with one embodiment of the present invention, before step 200 of FIG. 2 a user
`may authenticate him or herself to their mobile phone. Authentication of a user to the mobile
`phone may be accomplished by, for example, the user entering a password onto keypad 105
`of mobile phone 100 of FIG. 1. This password may then be compared to information stored
`in the protected memory region of SIM 101 to verify the password. If the password is verified,
`mobile phone 100 may then be unlocked. Unlocking the phone enables the phone to send and
`receive calls via long-range transceiver circuit 102, exchange information via short-range
`transceiver circuit 103, and allows the user to modify phone settings via keypad 105.
`Alternatively, authentication of the user by the mobile phone may include performing voice
`recognition of the user.
`Schiffer ’063 at 3:23-37.
`Schiffer ’063 teaches that mobile phone 100 includes “short-range transceiver circuit 103.” See
`FIG. 1, infra. This short-range transceiver circuit is characterized as establishing a short-range,
`wireless communication link:
`
`
`Consequently, a short-range, wireless communication link, 121, is established between
`computer system 110 and mobile phone 100, according to step 205. In accordance with one
`
`2
`
`U.S. Patent No. 10,212,586
`Claim 1
`[1(pre)]A mobile terminal
`configured to switch between
`an unlocked state and a locked
`state in which a predetermined
`operation is limited,
`comprising:
`
`[1(a)] a transceiver which
`performs short-range wireless
`communications;
`
`
`
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`IPR2020-00202
`Maxell Ex. 2013
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`embodiment of the present invention, this short-range, wireless communication link is a
`Bluetooth link, and the short-range, wireless communication range is the range of the
`Bluetooth wireless network.
`Schiffer ’063 at 3:42-49.
`
`[1(b)] a memory which
`previously stores information
`about an another mobile
`terminal; and
`
`
`
`
`
`
`Schiffer ’063 teaches that mobile phone 100 includes “SIM 101” (see FIG. 1, supra), which in turn
`includes a “protected memory region having data stored therein”:
`
`
`SIM 101 of FIG. 1 includes a protected memory region having data stored therein. A protected
`memory region is a memory region that is not generally modifiable by typical users. Thus,
`3
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`Maxell Ex. 2013
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`important information may be securely stored in the protected memory region of SIM 101 with
`a low risk of being compromised. The data stored in the protected memory region of SIM 101
`includes the subscriber identity number associated with the user of mobile phone 100.
`Schiffer ’063 at 2:38-45.
`
`Schiffer ’063 further discloses that this SIM may store data including an “access code” (or data
`used to generate the access code) for computer system 110:
`
`
`In response, the mobile phone transmits an access code back to the computer system via the
`link. This access code is generated using data stored in the SIM in the mobile phone. After the
`computer system verifies the access code, access to the computer system is granted in response
`to receiving the access code.
`Id. at 2:7-13.
`
`In some embodiments, the access code is an “alternate value” stored in the SIM and encrypted
`using the subscriber identity number:
`The access code transmitted from mobile phone 100 to computer system 110 via short-range,
`wireless communication link 121 of FIG. 1 is generated by mobile phone 100 using data stored
`in SIM 101. For one embodiment of the present invention, this data includes the subscriber
`identity number stored in the protected memory region of SIM 101. For added security, the
`access code may be encrypted by mobile phone 100 before being transmitted. The algorithm
`used to encrypt the access code may use data stored in SIM 101. For one embodiment, the
`access code is all or some portion of the subscriber identity number itself. For another
`embodiment, the access code may be an alternate value that may be encrypted using all or
`some portion of the subscriber identity number as an encryption key.
`Id. at 4:23-36. This “alternate value” (once decrypted) may be a “security code” previously stored
`in computer system 110 by the user:
`For one embodiment of the present invention, the access code may be decrypted by computer
`system 110 before being verified. Verification may include comparing the access code to a
`previously stored value to detect a match or other predetermined relationship. The previously
`stored value may be stored in a protected memory region of memory 113, such as the BIOS.
`This previously stored value may be entered by the user upon initially setting up an
`authentication system in accordance with the present invention. This previously stored value
`
`
`
`4
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`Defendant’s Invalidity Contentions
`Exhibit H1
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`
`
`
`5
`
`may include, for example, the subscriber identity number, or some portion thereof, or other
`security code.
`Thus, mobile phone 100 stores the “security code” in the memory of its SIM, and the security code
`is “information about” computer system 110 by virtue of having been stored as the access code for
`computer system 110 by the user.
`Finally, Schiffer ’063 discloses that computer systems (such as computer system 110) may be a
`“small handheld electronic device” or a “mobile” system:
`
`
`Computer systems, from small handheld electronic devices to medium-sized mobile and
`desktop systems to large servers and workstations, are becoming increasingly pervasive in our
`society. As such, people are becoming more reliant on computer systems to store and access
`information, much of which may be confidential. To maintain the confidentiality of this
`information, some computer systems may be voluntarily “locked” or “secured” by a user.
`When a computer system is locked, access to the computer system may be limited. This not
`only serves to maintain the confidentiality of information stored on the computer system but
`also deters theft of the computer system.
`Schiffer ’063 at 1:11-22.
`
`Alternatively, de la Huerga ’534 teaches this limitation. De la Huerga ’534 teaches that security
`device 10 stores information about other computer devices it can unlock:
`
`
`In some cases the electronic security device can include an address of one or more trusted
`computer systems or servers.
`de la Huerga ’534 at 15:3-4.
`
`These computer devices can include mobile devices (e.g., patient monitoring devices) to which the
`user may authenticate (“mobile terminals”):
`
`
`System 194 includes a plurality of personal computers or computer terminals comprising
`workstations 60 and 60’, which may be located in patient rooms, at nurse stations, in doctor
`offices and administrative offices, a plurality of network devices including databases 158 and
`162 and servers including an Admit, Discharge, and Transfer system or server 166, at least
`one laboratory system or server 170, various bedside treatment devices 116 and 116’ such as
`
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`ventilators and IV infusion pumps, patient monitoring devices 80 and 80’, a pharmacy system
`or server 186, a security verification system or server 168, a billing system or server 171, a
`patient historical records system or server 173 and a unit dose medication dispenser 150.”
`Id. at 20:1-15 (parentheticals omitted).
`
`De la Huerga ’534 further contemplates mobile terminals including patient bracelets (see FIG. 2)
`and locking pill containers (FIG. 5):
`
`
`The other devices include two smart devices including a patient monitor 80’ and a patient
`treatment device 116’, each equipped with a wireless transceiver input device 64 which is
`similar to transceiver 81’ on band 40 (see FIG. 2) and transceiver 81’ on container 200 (see
`FIG. 5)
`Id. at 24:1-5; see also FIGs 2, 5:
`
`
`Furthermore, de la Huerga ’534 disparages the prior art as not being suitable for portable devices:
`
`
`This [prior art] system is primarily directed to accessing desktop computer terminals on a
`sensitive computer network and is not easily adaptable, however, for restricting access to
`
`
`
`6
`
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`IPR2020-00202
`Maxell Ex. 2013
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`[1(c)] a controller which
`switches the mobile terminal
`between an unlocked state and
`a locked state based on an
`authentication input to the
`mobile terminal, wherein the
`locked state prevents
`unauthorized access to the
`mobile terminal;
`
`
`
`7
`
`laptops, portable instruments, medical equipment such as respirators, or electronically-
`controlled medication dispensers.
`Id. at 11:38-42.
`
`The motivation to modify Schiffer ’063 in this way would be to allow a user to unlock a variety of
`devices with their cell phone, each device with a different access code. Doing so would be the use
`of a known technique to improve similar devices (access devices) in the same way.
`Schiffer ’063 implicitly teaches that mobile phone 100 includes a microprocessor, controller, or
`other controller. For example, Schiffer ’063 teaches that a password entered by the user “is
`compared” to stored information :
`
`
`Authentication of a user to the mobile phone may be accomplished by, for example, the user
`entering a password onto keypad 105 of mobile phone 100 of FIG. 1. This password may then
`be compared to information stored in the protected memory region of SIM 101 to verify the
`password. If the password is verified, mobile phone 100 may then be unlocked.
`Schiffer ’063 at 3:25-31. The components or components that do this comparison are the claimed
`“controller.” This controller “unlock[s]” mobile phone 100 (switches it from a locked state to an
`unlocked state) based on the password (authentication input) entered into mobile phone 100 by the
`user.
`
`In the locked state, unauthorized access (including sending and receiving calls, exchanging
`information and modifying settings) is prevented:
`Unlocking the phone enables the phone to send and receive calls via long-range transceiver
`circuit 102, exchange information via short-range transceiver circuit 103, and allows the user
`to modify phone settings via keypad 105.
`Id. at 3:32-35.
`
`Alternatively, de la Huerga ’534 teaches that security device 10 includes a processor:
`
`
`Device 10 includes a processor 250 linked to memory 262, activation button 18, indicator 20
`(e.g. a LED or speaker), wireless communication transceiver 14, power source (e.g. a battery,
`photocell, or fuel cell or magnetic field induced power source), and an optional biometric
`indicia sensor 405 (e.g. a fingerprint sensor placed on the back of device 10).
`
`Apple v. Maxell
`IPR2020-00202
`Maxell Ex. 2013
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`de la Huerga ’534 at 65:53-59.
`
`De la Huerga ’534 teaches that processor 250 switches device 10 to an unlocked from a locked
`state (where the function of authenticating the user to other devices is disabled):
`
`
`In an initial or basic version, the user has an electronic security device and authenticates
`himself according to the standard computer security protocol, e.g. a user name and password,
`biometric indicia, or by using codes in the electronic device itself.
`Id. at 12:8-12
`
`This locking and unlocking of device 10 is distinct from unlocking and unlocking other devices:
`
`
`Where device authentication protocol information 1153 is used to authenticate a user to
`security device 10, system authentication protocol 1165 is used to authenticate security device
`(and therefore its user or owner) to computer system 194.
`Id. at 67:17-21.
`
`The motivation to modify Schiffer ’063 to incorporate de la Huerga ’534’s processor would be to
`provide a component to perform the various functions described by Schiffer ’063’s mobile device
`100. Substituting whatever performs the functions in Schiffer ’063 with de la Huerga ’534’s
`processor would be a simple substitution of one known element for another to obtain predictable
`results.
`
`Alternatively, Kirkup ’746 teaches that the microprocessor 338 of handheld device 120 performs
`all functions:
`
`
`Handheld electronic device 120 comprises a number of components, the controlling
`component being microprocessor 338. Microprocessor 338 controls the overall operation of
`the handheld electronic device 120. The hardware and software control functions described
`above in relation to FIGS. 1A to 1F and FIG. 2 are performed by microprocessor 338.
`Kirkup ’746 at ¶ [0085].
`
`These functions include locking (disabling the use of) and unlocking the device:
`
`
`
`8
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`The handheld electronic device 120 requires the user to authenticate himself/herself by
`providing a password or PIN code to unlock the user interface of the handheld electronic
`device 120 and enable use thereof.
`Kirkup ’746 at ¶ [0045]; see also FIG. 3:
`
`
`The motivation to modify Schiffer ’063 to incorporate Kirkup ’746’s microprocessor would be to
`provide a component to perform the various functions described by Schiffer ’063’s mobile device
`100. Substituting whatever performs the functions in Schiffer ’063 with Kirkup ’746’s
`microprocessor would be a simple substitution of one known element for another to obtain
`predictable results.
`Schiffer ’063 teaches that, when the conditions are met (as described below; see elements [1(e)],
`[1(f)], and [1(g)]), mobile phone 100 transmits the access code to computer system 110:
`
`
`9
`
`[1(d)] wherein, when
`conditions are met, the
`controller controls the mobile
`
`
`
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`IPR2020-00202
`Maxell Ex. 2013
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`terminal to transmit
`information to the another
`mobile terminal for switching
`a state of the another mobile
`terminal from a locked state to
`an unlocked state, wherein the
`conditions include:
`
`At step 210 of FIG. 2, an access code is transmitted from short-range transceiver circuit 103
`of mobile phone 100 to short-range transceiver circuit 111 of computer system 110 via link
`121 of FIG. 1.
`Schiffer ’063 at 4:10-13; see also FIG. 2:
`
`
`
`
`This access code causes computer system 110 to grant the user access (switch state from a locked
`state to an unlocked state):
`Once the access code has been verified by computer system 110 of FIG. 1, the computer
`system grants the user access to the system at step 215 of FIG. 2. If the access code is not
`
`10
`
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`verified, i.e. no access code is received or the wrong access code is received, access to the
`computer system remains limited.
`Id. at 4:53-58; see also FIG. 2 at step 215 supra.
`Schiffer ’063 teaches that, when the authentication process starts, the mobile phone 100 is in a
`locked state:
`
`
`In accordance with one embodiment of the present invention, before step 200 of FIG. 2 a user
`may authenticate him or herself to their mobile phone. Authentication of a user to the mobile
`phone may be accomplished by, for example, the user entering a password onto keypad 105
`of mobile phone 100 of FIG. 1. This password may then be compared to information stored
`in the protected memory region of SIM 101 to verify the password. If the password is verified,
`mobile phone 100 may then be unlocked. Unlocking the phone enables the phone to send and
`receive calls via long-range transceiver circuit 102, exchange information via short-range
`transceiver circuit 103, and allows the user to modify phone settings via keypad 105.
`Alternatively, authentication of the user by the mobile phone may include performing voice
`recognition of the user.
`Schiffer ’063 at 3:23-37.
`
`Schiffer ’063 further discloses that, when the authentication process starts, computer system 110 is
`also in a locked state:
`
`
`[1(e)] first, the mobile terminal
`is in a locked state, the another
`mobile terminal is in a locked
`state, and the another mobile
`terminal is within
`communication range of the
`short-range wireless
`communications of the
`transceiver while in the locked
`state;
`
`
`
`In accordance with an embodiment of the present invention, the subscriber identity module
`(SIM) in a user's mobile phone is used to gain access to a locked computer system. Initially,
`access to the computer system is limited.
`Id. at 61-64.
`
`Finally, the authentication process begins when short-range transceiver circuit 103 of mobile phone
`100 enters communications range of short-range transceiver circuit 111 of computer system 110:
`
`
`When a user with a mobile phone comes into short-range, wireless communication range of
`the computer system, a short-range, wireless communication link is automatically established
`(i.e. established without user intervention).
`Id. at 1:65-2:1; see also FIG. 2, at step 200:
`
`11
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`
`Alternatively, de la Huerga ’534 teaches this first set of conditions. De la Huerga ’534 teaches that
`the process of authentication via device 10 begins with device 10 being in a locked state (i.e., with
`the predetermined operation of providing authentication information to other devices being
`disabled):
`
`
`To improve the authentication process, the user may need to authenticate himself to security
`device 10 in order for device 10 to provide system authentication protocol information 1165
`to security server 168, which in turn authenticates the user 1380. The user must initially
`
`12
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`Defendant’s Invalidity Contentions
`Exhibit H1
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`provide device authentication protocol information 1153, which may be in the form of a
`number of challenge questions 1154 and corresponding answers 1155, to device 10.
`de la Huerga ’534 at 71:66-72:6.
`
`
`Authenticating a user to device 10 using device authentication protocol information 1153 can
`include presenting a biometric indicia to sensor 405, which measures or images the indicia.
`Id. at 72:65-73:1
`
`Because the user is trying to access computer system 194 (which may be a mobile device, as
`discussed above in element [1(b)]), the computer system is also locked at this stage:
`
`
`A patient monitoring device 80 (FIG. 4) or bedside treatment device 178 (FIG. 7) may reject
`a data exchange request from an ICD 10 if the physician wearing the ICD 10 is not authorized
`or cleared to diagnose or administer treatment to the patient.
`Id. at 42:12-16
`
`
`If there is a match, user is authenticated to device 10, which then retrieves stored system
`authentication protocol information 1165 corresponding to the computer system 194 as in
`list 1170. The authentication protocol information 1165 is then sent to server 168 for
`comparison with system authentication protocol information 1242 for the user identified by
`device 10. If there is a match the user is authenticated to computer system 194 and logged
`on.
`Id. at 72:54-64 (parentheticals omitted).
`
`Finally, device 10 and the other mobile device are in wireless communication range, as this initiates
`the authentication process:
`
`
`Transceiver 14 can be under control of processor 250 to repeatedly broadcast device
`identifier 1148 (or other message) when it is not in communication with a specific terminal
`60. This can also be instigated by pressing activation button 18. When the user with device
`10 approaches within communication range (e.g. 3 m) of terminal 60, transceiver 64 will
`receive identifier 1148.
`Id. at 69:23-29.
`
`
`
`13
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`[1(f)] second, after the mobile
`terminal is in the locked state,
`the another mobile terminal is
`in the locked state, and the
`
`
`
`14
`
`
`The motivation to modify Schiffer ’063 to employ de la Huerga ’534’s conditions would be so that
`the user can unlock their phone prior to entering communications range of the computer system.
`This would increase the convenience of Schiffer ’063’s system and would be a simple application
`of a known technique to a known device ready for improvement to yield predictable results.
`
`Alternatively Kirkup ’746 teaches this set of conditions. Kirkup ’746 teaches that entering the PIN
`into handheld electronic device 120 serves to unlock both it and PC 110 (thus, at the beginning of
`the authentication process, both devices are necessarily in the locked state):
`
`
`Advantageously, the described arrangements generally allow a user to unlock both the PC
`110 and the handheld electronic device 120 by simply inputting one authorization code,
`namely that for the handheld electronic device 120.
`Kirkup ’746 at ¶ [0053].
`
`Kirkup ’746 further teaches that the process may be initiated when handheld electronic device 120
`enters short-range wireless communications range of PC 110:
`
`
`Advantageously, providing wireless communication link 145 enables a user to approach PC
`110, activate the PC 110 and have it communicate automatically and wirelessly, for example
`using the Bluetooth short-range communication specification, with handheld electronic
`device 120 to access the user's authentication code (stored on the smart-card, SIM card or
`memory of the handheld electronic device) and authenticate the user.
`Id. at ¶ [0068].
`
`The motivation to modify Schiffer ’063 to employ Kirkup ’746’s conditions would be so that the
`user can unlock their phone prior to entering communications range of the computer system. This
`would increase the convenience of Schiffer ’063’s system and would be a simple application of a
`known technique to a known device ready for improvement to yield predictable results.
`Schiffer ’063 teaches that, upon entering short-range wireless communications range, the wireless
`communication link 121 is “automatically established”:
`
`
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`Maxell Ex. 2013
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`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`another mobile terminal is
`within communication range
`of the short-range wireless
`communications of the
`transceiver while in the locked
`state, performing, via the
`transceiver, the short-range
`wireless communications with
`the another mobile terminal;
`and
`
`For one embodiment of the present invention, the short-range, wireless communication link
`is established automatically, in response to bringing mobile phone 100 of FIG. 1 within the
`short-range, wireless communication range of computer system 110. In other words, no user
`intervention is required to establish the wireless communication link beyond entering the
`wireless communication range of the computer system while carrying the mobile phone.
`Schiffer ’063 at 3:64-4:5. Thus, in this disclosed embodiment, the phone need not be unlocked
`(which would require user interaction) prior to the establishment of the communication link.
`
`Schiffer ’063 further discloses that, in some embodiments, the computer system 110 transmits a
`request for authentication to the mobile device:
`
`
`At step 210 of FIG. 2, an access code is transmitted from short-range transceiver circuit 103
`of mobile phone 100 to short-range transceiver circuit 111 of computer system 110 via link
`121 of FIG. 1. In accordance with one embodiment of the present invention, this transmission
`is made in response to computer system 110 transmitting information to mobile phone 100,
`via link 121, to indicate that access to the computer system is limited. For one embodiment,
`computer system 110 may specifically request an access code from mobile phone 100 via link
`121.
`Id. at 4:10-19. Because computer system 110 cannot know whether mobile phone 100 is locked,
`this transmission (and thus communication) is performed even when mobile phone 100 is in the
`locked state.
`
`Alternatively, de la Huerga ’534 teaches this condition. As described above, de la Huerga ’534
`teaches that security device 10 and the terminal to be unlocked 60 communicate when both devices
`are in the locked state:
`
`
`Transceiver 14 can be under control of processor 250 to repeatedly broadcast device
`identifier 1148 (or other message) when it is not in communication with a specific terminal
`60. This can also be instigated by pressing activation button 18. When the user with device
`10 approaches within communication range (e.g. 3 m) of terminal 60, transceiver 64 will
`receive identifier 1148.
`De la Huerga ’534 at 69:23-29
`
`
`
`
`15
`
`Apple v. Maxell
`IPR2020-00202
`Maxell Ex. 2013
`
`Page 15 of 30
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`

`

`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`In other cases transceiver 64 will repeatedly broadcast a “are any devices present” status message
`and when device 10 comes within communication range of terminal 60, transceiver 14 will receive
`the message and processor 250 will respond by transmitting device identifier 1148.”
`Id. at 69:50-54
`
`See also step 1301 of FIG. 42 (depicting communication as the first step of
`authentication/unlocking process):
`
`the
`
`
`
`
`The motivation to modify Schiffer ’063 to employ de la Huerga ’534’s conditions would be to
`reduce the delay in unlocking computer system 110. This would increase the convenience of
`
`16
`
`Apple v. Maxell
`IPR2020-00202
`Maxell Ex. 2013
`
`Page 16 of 30
`
`

`

`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`[1(g)] third, after the
`performing, receiving, by the
`controller, the authentication
`input for switching the mobile
`terminal from the locked state
`to the unlocked state.
`
`
`
`17
`
`Schiffer ’063’s system and would be a simple application of a known technique to a known device
`ready for improvement to yield predictable results.
`
`Alternatively, Kirkup ’746 teaches this condition. Kirkup ’746 teaches that wireless communication
`device 120 automatically communicates over communication link 115 with PC 120 when both
`devices are locked when PC 120 detects the presence of wireless communication device 120 and
`initiates the authentication process by seeking the authentication code:
`When the user wishes to use PC 110, he or she may perform an activation action, such as
`typing on the keyboard or moving the mouse, whereupon the user may be requested to provide
`a user identification code (either to the PC 110 or the handheld electronic device 120) to
`unlock the PC desktop and enable use thereof […] PC 110 is preferably configured to
`automatically seek the authentication code from handheld electronic device 120 over
`communication link 115 in response to activation.
`Kirkup ’746 at ¶¶ [0048]-[0049].
`
`The motivation to modify Schiffer ’063 to employ Kirkup ’746’s condition would be to reduce the
`delay in unlocking computer system 110. This would increase the convenience of Schiffer ’063’s
`system and would be a simple application of a known technique to a known device ready for
`improvement to yield predictable results.
`Schiffer ’063 teaches that the user may be required to authenticate before the access code is
`transmitted from mobile device 100 to computer system 110:
`
`
`Note that for one embodiment, the user may authenticate himself or herself to the mobile
`phone by, for example, entering a password into the mobile phone. In this manner, the SIM
`is used not only to identify the user during cellular phone calls (or other long-range, wireless
`communication) but also to authenticate the user to the computer system. Note that for one
`embodiment, the user may authenticate himself or herself to the mobile phone by, for example,
`entering a password into the mobile phone.
`Schiffer ’063 at 2:14-19.
`
`
`In accordance with one embodiment of the present invention, before step 200 of FIG. 2 a user
`may authenticate him or herself to their mobile phone. Authentication of a user to the mobile
`phone may be accomplished by, for example, the user entering a password onto keypad 105
`
`Apple v. Maxell
`IPR2020-00202
`Maxell Ex. 2013
`
`Page 17 of 30
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`

`

`Defendant’s Invalidity Contentions
`Exhibit H1
`
`
`of mobile phone 100 of FIG. 1. This password may then be compared to information stored
`in the protected memory region of SIM 101 to verify the password. If the password is verified,
`mobile phone 100 may then be unlocked. Unlocking the phone enables the phone to send and
`receive calls via long-range transceiver circuit 102, exchange information via short-range
`transceiver circuit 103, and allows the user to modify phone settings via keypad 105.
`Alternatively, authentication of the user by the mobile