Patent Owner’s Demonstratives
`
`Google LLC,
`v.
`Uniloc 2017 LLC,
`Case IPR2020-00756
`U.S. Patent No. 9,564,952
`
`Oral Hearing
`June 15, 2021
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Google LLC,
`v.
`Uniloc 2017 LLC,
`Case IPR2020-00756
`U.S. Patent No. 9,564,952
`
`Oral Hearing
`June 15, 2021
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`
`
`Claim 9, the only challenged independent claim
`
`9. A method for near field authentication of a source,
`the source using an audio transceiver computing device,
`the method comprising:
`scanning a plurality of predetermined frequencies for
`a free frequency;
`selecting the free frequency from the plurality
`of predetermined frequencies;
`generating a periodic enclosed content message;
`generating a modulated carrier wave representing
`the periodic enclosed content message; and
`transmitting the modulated carrier wave at the free frequency;
`wherein each period of the periodic enclosed content message
`includes a begin indication, a content, and an end indication;
`wherein the content includes device identification data
`including a bit array derived from user-configurable and
`non-user-configurable data specific to the audio transceiver
`computing device; and wherein the modulated carrier wave
`comprises a sound wave.
`
`2
`
`
`
`“scanning a plurality of predetermined
`frequencies for a free frequency”
`
`Among other example deficiencies addressed in the
`briefing, Google failed to persuasively defend the
`Petition against the following deficiencies:
`
`(1) obviousness of “scanning a plurality of
`predetermined frequencies for a free frequency”
`has not been shown by “Paulson’s sampling of
`frequencies that are not predetermined”
`(POR at 10-13; POSR 1-5); and
`
`(2) obviousness of “scanning … for a free frequency”
`has not been shown by Paulson’s sampling for the
`“most prevalent sounds”
`(POR 12; POSR 5-7).
`
`3
`
`
`
`“scanning a plurality of predetermined
`frequencies for a free frequency”
`
`Paulson has not been shown to scan predetermined frequencies
`
` The Petition asserts that Paulson discloses “the
`frequencies [are] initially determined in Step 402”—i.e.,
`they are not predetermined.
`
` In its Reply, Google attempts to advance a new (and
`hence waived) position that Step 404 of Paulson renders
`obvious “scanning a plurality of predetermined
`frequencies for a free frequency” ostensibly because the
`frequency range sampled in Step 404 is preset by
`whatever is “determined to be viable in Step 402.”
`
` Paulson makes explicit that the frequencies
`indiscriminately sampled in Step 404 include those
`which are “too high” to be viable. Thus, the sampled
`frequencies in step 404 clearly are not preset by “those
`determined to be viable in Step 402,” as Google argues.
`
`4
`
`
`
`“scanning a plurality of predetermined
`frequencies for a free frequency”
` Paulson describes its Step 404 as indiscriminately sampling
`frequencies which are “too high for the receive device to sample
`and demodulate.” Paulson, 13:29-32.
`
` An example of sampled frequencies which are “too high” for the
`system to decode are represented in Figure 5 as those which
`exceed the vertical axis indicated by reference 502 (i.e., the
`portion of the graph emphasized below with red highlighting).
`
`Paulson, Fig. 5.
`
`5
`
`
`
`“scanning a plurality of predetermined
`frequencies for a free frequency”
`
`Paulson has not been shown to scan for a free frequency (among
`predetermined frequencies)
` Because the claimed “scanning” pertains to
`“predetermined frequencies,” a “free frequency”
`selected from within the “predetermined frequencies”
`is necessarily one that is transmittable” (i.e., usable for
`implementing the method as claimed).
` In the example description below, the scanning itself
`identifies the “first” free frequency.
`
`In step 604, the audio transceiver computing device 102 selects
`the free frequency from the plurality of predetermined
`frequencies. For example, the mobile phone can identify the
`first free frequency it scans that has no discernible signal, or
`that has no signal strength that satisfies a minimum amplitude
`threshold, or that otherwise meets a pre-established criteria for
`being a free frequency.
`(Ex. 1001, 11:18-24)
`
`6
`
`
`
`“scanning a plurality of predetermined
`frequencies for a free frequency”
`
`Paulson has not been shown to scan for a free frequency (among
`predetermined frequencies)
`
` Paulson, by contrast, uses a scheme that samples
`sonic frequencies regardless of whether they
`ultimately may be used to effect a successful
`transmission.
`
` For example, Paulson describes its Step 404 as
`involving indiscriminately sampling frequencies
`that are “too high” to be usable by the system—e.g.,
`because the sampled frequencies exceed the “sonic
`frequency limit 502” (as shown in Figure 5).
`Paulson, Fig. 5, 13:29-32, 14:34-36.
`
`7
`
`
`
`Google fails to prove any asserted combination satisfies what the
`transmitted “content” must include
`
`Google’s reliance on Surprenant is predicated on logical fallacy
` Google acknowledges that the theory of the Petition is that
`Surprenant’s “AMP ID is derived in part from ‘non-user-
`configurable data,’ as claimed, because ‘the AMP ID is a
`unique identification string’ that is disclosed as being
`specific to ‘the transmit device 101.’” Reply, 14.
`
` Google fails to prove its underlying premise—i.e., if
`an identification string is deemed unique and specific to a
`device, then it must be considered “non-user-configurable
`data.”
`
` The claim language acknowledges—and indeed it
`requires—the capability for a user to configure certain
`“data” that is nevertheless specific to the audio transceiver
`computing device.”
`
`wherein the content includes device identification data
`including a bit array derived from user-configurable . . . data
`specific to the audio transceiver computing device
`
`8
`
`
`
`Google fails to prove any asserted combination satisfies what the
`transmitted “content” must include
`
`The term “non-user-configurable data” at least means what it says
`
` While Uniloc has no burden to defend patentability by
`advancing and defending a construction for “non-user-
`configurable data,” at a minimum, the term means what it
`says. It must be data that is not configurable by the user.
`
` Google fails to identify any express or inherent disclosure
`in Surprenant qualifying its “AMP ID” as data that is not
`configurable by the user, let alone the specific combination
`of limitations in which the “non-user-configurable data”
`qualifier appears.
`
` At most, Surprenant states “the AMP ID is a unique
`identification string that serves as a reference pointer to a
`larger data set stored in the receive device 103 or remote
`therefrom, and is associated with the transmit device 101
`and/or the user of the transmit device 101.”
`Suprenant, 7:45-49.
`
`9
`
`
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