Defendant’s Invalidity Contentions
`Exhibit H3
`
`
`Invalidity of U.S. Patent No. 10,212,586
`by
`U.S. Patent No. 7,941,534 to de la Huerga (“de la Huerga ’534”)
`
`
`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.
`
`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, should the claims of the ‘586 patent be found
`to not be entitled to priority to the foreign filing date, de la Huerga ’534 qualifies as prior art under §§ 102(a)(1) and 102(a)(2) (post-
`AIA). Using Plaintiff’s interpretation of the claims, de la Huerga ’534 anticipates claims 1-2, 6-7, 9-10, 13-14, and 16-18 under 35
`U.S.C. § 102(a), (b) and (e).
`
`Alternatively, 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).
`
`Alternatively, de la Huerga ’534 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).
`
`Alternatively, de la Huerga ’534 in view of U.S. Patent No. 6,871,063 to Schiffer (“Schiffer ’063”) renders obvious claims 1-2, 6-7, 9-
`10, 13-14, and 16-18 under 35 U.S.C. § 103(a). Schiffer ’063 was filed on Jun 20, 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).
`
`
`
`1
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`Maxell Ex. 2014
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`Defendant’s Invalidity Contentions
`Exhibit H3
`
`
`Alternatively, Kirkup ’746 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).
`
`
`de la Huerga ’534
`
`To the extent the preamble is limiting, de la Huerga ’534 teaches an electronic security device that
`can take the form of a cell phone (a mobile terminal):
`
`
`As before, security device 10 can be in the form [of a] security badge or a cell phone or PDA
`or other convenient shape that is typically worn or held by an employee of an enterprise,
`henceforth referred to as computer user.
`de la Huerga ’534 at 65:47-51.
`
`De la Huerga ’534’s mobile terminal can be unlocked or locked (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 authentication of the user to security 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.
`De la Huerga ’534’s security device 10 includes “communications transceiver 14”:
`
`
`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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`Exhibit H3
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`
`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). In some cases
`a small key pad (e.g. buttons 207, 209, 211, 213, and 215 or others) is also provided and
`display 258 can be provided as a graphic display, e.g. a LCD.
`de la Huerga ’534 at 65:53-62.
`
`De la Huerga ’534 characterizes the transmission range of security device 10 as three meters (“3
`m”):
`
`
`[1(b)] a memory which
`previously stores information
`about an another mobile
`terminal; and
`
`
`
`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.
`
`De la Huerga ’534 further characterizes this as “limited range” communication:
`When the electronic device has wireless communication it can be used to log the user onto
`the computer system. This can be done by pressing an activation button on the device, which
`then transmits the reauthentication code and other user information as needed within a
`limited range.
`Id. at 12:53-57
`
`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.
`
`
`3
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`Exhibit H3
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`
`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
`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:
`
`
`
`4
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`Defendant’s Invalidity Contentions
`Exhibit H3
`
`
`
`
`
`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
`laptops, portable instruments, medical equipment such as respirators, or electronically-
`controlled medication dispensers.
`Id. at 11:38-42.
`
`Additionally, Schiffer ’063 teaches this limitation. 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,
`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.
`
`5
`
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`
`
`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
`may include, for example, the subscriber identity number, or some portion thereof, or other
`security code.
`
`
`
`6
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`Defendant’s Invalidity Contentions
`Exhibit H3
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`
`
`
`7
`
`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.
`
`The motivation to modify de la Huerga ’534 to include Schiffer ’063’s teachings of storing
`information about the device or devices to be unlocked would be to provide additional, more
`granular unlocking capabilities (so that a device would know that it can access a medication
`dispenser but not a laboratory system, for example). Modifying de la Huerga ’534 in this way would
`be the use of a known technique to improve a similar device in the same way.
`
`Additionally, Kirkup ’746 teaches this element. Kirkup ’746 teaches storing the user’s
`authentication code for PC 110 (which “may be of any kind of computer, such as a normal desktop
`computer, laptop or other portable or fixed computer system,” see ¶ [0047]) in a memory of the
`mobile device:
`
`
`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.
`Kirkup ’746 at ¶ [0068].
`
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`IPR2020-00202
`Maxell Ex. 2014
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`Defendant’s Invalidity Contentions
`Exhibit H3
`
`
`
`This memory can be, in various disclosed embodiments, smartcard 130, SIM 316 or non-volatile
`memory 324:
`
`
`
`
`The motivation to modify de la Huerga ’534 to include Kirkup ’746’s teachings of storing
`information about the device or devices to be unlocked would be to provide additional, more
`granular unlocking capabilities (so that a device would know that it can access a medication
`dispenser but not a laboratory system, for example). Modifying de la Huerga ’534 in this way would
`be the use of a known technique to improve a similar device in the same way.
`De la Huerga ’534 teaches that security device 10 includes a processor:
`
`
`8
`
`[1(c)] a controller which
`switches the mobile terminal
`between an unlocked state and
`
`
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`Defendant’s Invalidity Contentions
`Exhibit H3
`
`
`a locked state based on an
`authentication input to the
`mobile terminal, wherein the
`locked state prevents
`unauthorized access to the
`mobile terminal;
`
`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).
`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):
`
`
`[1(d)] wherein, when
`conditions are met, the
`controller controls the mobile
`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:
`
`
`
`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.
`
`De la Huerga ’534 teaches that electronic device 10 transmits the reauthentication code to the other
`device when the conditions are met, as described below:
`
`
`When the electronic device has wireless communication it can be used to log the user onto
`the computer system. This can be done by pressing an activation button on the device, which
`then transmits the reauthentication code and other user information as needed within a
`limited range.
`de la Huerga ’534 at 12:53-57.
`
`Additionally, Kirkup ’746 teaches this claim limitation. Kirkup ’746 teaches that handheld
`electronic device 120, controlled by the controller, transmits the authentication information to PC
`110 when the conditions are met, as described below.
`
`9
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`Defendant’s Invalidity Contentions
`Exhibit H3
`
`
`
`
`The handheld electronic device is configured to transmit the authentication code to the
`computer so as to enable the user to unlock the desktop of the computer and thus gain access
`to the computer functions.
`Kirkup ’746 at ¶ [0040].
`
`The motivation to modify de la Huerga ’534 to include Kirkup ’746’s automatic transmission of
`the authentication code would be to speed up the process of unlocking the various devices, thereby
`increasing user convenience. This would be a simple combination of prior art elements according
`to known methods to yield predictable results.
`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):
`
`
`[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;
`
`
`
`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
`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
`
`
`10
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`Defendant’s Invalidity Contentions
`Exhibit H3
`
`
`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:
`
`
`[1(f)] second, after the mobile
`terminal is in the locked state,
`the another mobile terminal is
`in the 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, performing, via the
`transceiver, the short-range
`wireless communications with
`the another mobile terminal;
`and
`
`
`
`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
`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
`
`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
`
`
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`Exhibit H3
`
`
`See also step 1301 of FIG. 42 (depicting communication as the first step of
`authentication/unlocking process):
`
`the
`
`[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.
`
`
`
`
`De la Huerga ’534 teaches that the user must enter authentication information to unlock electronic
`security device 10:
`
`
`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
`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. To
`12
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`Defendant’s Invalidity Contentions
`Exhibit H3
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`
`authenticate himself to device 10 challenge question 1154 can be randomly retrieved and
`transmitted by device 10 to terminal 60 for presentation on display 103 (step 1382). In some
`cases the challenge question is presented on display 16 of security device 10. The answer to
`the challenge question can be entered using an input device such as activation button 18, a
`small key pad or touch screen (not shown) on security device 10. Using a security device
`input device for entering the answer prevents any software in terminal 60 from secretly
`recording the answer. However, question 1154 (e.g. a request for a password) can be sent to
`terminal 60 for presentation on display 103 and the answer (e.g. a password) can be entered
`using input device 105.
`de la Huerga ’534 at 71:66-72:18; see also step 1301 of FIG. 42 supra (performing
`communication); step 1324 of FIG. 43 (continuing method of FIG. 42) (depicting a step of
`performing the standard authentication process 1340); steps 1342 and 1348 (requesting/receiving
`user authentication inputs as a part of authentication process 1340).
`
`
`
`13
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`Defendant’s Invalidity Contentions
`Exhibit H3
`
`
`Claim 2
`terminal
`[2] The mobile
`according to claim 1, wherein
`the operation
`includes a
`biometrics authentication.
`
`
`
`
`
`De la Huerga ’534 teaches that, in the disabled state, ICD 401 (“essentially identical” to security
`device 10; see 32:17-22) disables itself (including its biometric authentication functions) when it
`locks itself:
`
`
`Where the discerned fingerprint characteristics do no match the stored characteristics, ICD
`401 may do any of several different things. First, ICD 401 may simply disable itself until an
`authorized facility administrator resets the ICD 401 for another identification attempt.
`Second, ICD 401 may allow several (e.g. 3 or 4) attempts to generate a match and only after
`several failed attempts disable itself. Moreover, when ICD 401 disables itself, ICD 401 may
`
`14
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`
`either cause an audible or a visual signal indicating a mismatch and may continue to cause
`the signal to alert passersby that an unauthorized person attempted to use the ICD 401.
`de la Huerga ’534 at 32:63-33:6 (allowing only one authentication attempt as in the first option
`implicitly discloses disabling the biometric authentication function).
`
`Alternatively, to the extent that this claim is construed to require biometric authentication to unlock
`the device, de la Huerga ’534 teaches biometric authentication to electronic security device 10 as
`well:
`
`
`
`
`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.
`Processor 250 then compares it to biometric reference information, measurements, or images
`1152 stored in memory 262. When there is a match the user is authenticated to device 10,
`which then retrieves stored authentication protocol 1165 (e.g. user name 1166 and password
`1167, a time varying algorithm to compute a time based response code, or other user unique
`code) for corresponding to received computer identifier 1202.
`Id. at 72:65-73:7.
`
`Alternatively, Lin ’089 teaches this limitation. In particular, Lin ’089 teaches that the user can
`authenticate via “biological recognition technology:”
`
`
`The present invention relates to a method for unlocking a locked computing device and, more
`specifically, to a method that utilizes biological recognition technology to unlock a locked
`computing device.
`Lin ’089 at 1:9-12.
`
`
`The locked computing device 220 then obtains biometric infor mation, Step 120, by using a
`camera sensor 230 to capture an image of the external environment in this scenario 200.
`Then the computing device 220 determines in Step 130 whether the biometric information
`meets a predetermined requirement; in this scenario 200, the biometric information obtained
`is a facial profile of user 210, and the predetermined requirement is whether the obtained
`image comprises a facial profile of a human face (such as that of user 210). When the obtained
`biometric information (facial profile) does not meet the requirement, the computing device
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`Maxell Ex. 2014
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`Defendant’s Invalidity Contentions
`Exhibit H3
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`220 proceeds to Step 180 and remains locked; when the predetermined requirement is met,
`then the process continues to Step 150.
`Id. at 3:20-33
`
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`For example, in another embodiment of the present invention, the locked computing device
`220 includes a fingerprint reader (touch screen 240) utilized for capturing a fingerprint
`image of a finger 250 of the user 210 to thereby obtain the biometric information. If specific
`user authorization is (step 150) is not enabled, the computing device 220 unlocks upon
`recognition of the fingerprint image. On the other hand, if further security is required, the
`locked computing device 220 can also check to see if the fingerprint image matches a
`predetermined fingerprint image of an authorized user of the computing device and only
`unlock upon the fingerprint image matching that of the authorized user.
`Id. at 4:34-45; see also FIGs 1, 2 infra:
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`IPR2020-00202
`Maxell Ex. 2014
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`Page 16 of 27
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`Defendant’s Invalidity Contentions
`Exhibit H3
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`The motivation to modify de la Huerga ’534’s system to incorporate the biometric authentication
`teachings of Lin ’089 would be to increase user convenience adding additional authentication
`techniques. Doing so would the the use of a known technique to improve a similar device in the
`same way.
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`IPR2020-00202
`Maxell Ex. 2014
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`Page 17 of 27
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`Defendant’s Invalidity Contentions
`Exhibit H3
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`De la Huerga ’534 teaches that security device 10 can unlock multiple devices, and therefore stores
`information about each of them (see element [1(b)] supra):
`
`
`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; see also FIG. 34 (showing “list of computer systems 1160”), each of
`which can be unlocked by security device 10:
`
`
`FIG. 34 shows the expanded list of trusted or registered computer system information 1160
`stored in memory 262 of device 10. For each electronic or computer system 194 the user is
`to access, security information 1161 is provided including trusted computer system identifier
`1162 that electronic device 10 has been programmed to recognize or trust and may be in the
`form of a name, a URL address, an internet protocol (IP) address, or other method of
`identifying a computer system.
`Id. at 66:39-49.
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`De la Huerga ’534 teaches embodiments which use of low-power, limited-range radio transmission.
`A POSITA would understand these teachings to implicitly disclose a Bluetooth connection.
`
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`In another embodiment, the wireless communication means 52 of wrist bracelet 40 (FIG. 2)
`may utilize alternate communication means, such as magnetic coupling or low power radio
`transmission, rather than the preferred infrared means of the ICD 10. Similarly, the bedside
`communication device 96 (FIG. 4) of a patient bed 88 may also utilize alternate
`communication means. Further, the communication range of wrist bracelets 40 or other smart
`devices may be limited in order to prevent two devices from receiving the same request.
`de la Huerga ’534 at 41:36-45.
`
`Alternatively, it would be obvious to modify de la Huerga ’534 to include Bluetooth
`communication as the disclosed “low-power radio communication.” The motivation to do so would
`be that is would be obvious to try, as it simply requires choosing from a finite number of identified,
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`18
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`Claim 6
`[6] The mobile terminal
`according to claim 1, further
`configured to store
`information about two or more
`another mobile terminals.
`
`Claim 7
`[7] The mobile terminal
`according to claim 1, wherein
`the short-range wireless
`communication is via a
`Bluetooth connection.
`
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`Apple v. Maxell
`IPR2020-00202
`Maxell Ex. 2014
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`Page 18 of 27
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`Defendant’s Invalidity Contentions
`Exhibit H3
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`predictable solutions (low-power radio communication protocols), with a reasonable expectation
`of success.
`
`Additionally, Schiffer ’063 teaches the use of Bluetooth for low-power, short range
`communications. In particular, Schiffer ’063 teaches that “short-range wireless communication link
`121” may be a Bluetooth link
`
`
`In accordance with one 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. (See, e.g., Bluetooth Specification, Version
`1.0A, released Jul.