IPR2020-00905
`Apple Inc. v. Corephotonics, Ltd.
`
`U.S. Patent No. 10,225,479
`
`IPR2020-00905 | SLIDE 1
`
`
`Apple Inc. v. Corephotonics, Ltd.
`
`U.S. Patent No. 10,225,479
`
`IPR2020-00905 | SLIDE 1
`
`
`
`Instituted Grounds
`• Ground 1: Claims 1, 10-14, 16, 18, 23, 32-36, 38, 40
`Obviousness over Parulski and Konno
`• Ground 2: Claims 2-4 and 24-26
`Obviousness over Parulski, Konno, and Szeliski
`• Ground 3: Claims 5-9 and 27-31
`Obviousness over Parulski, Konno, Szeliski, and Segall
`• Ground 4: Claims 15 and 37
`Obviousness over Parulski, Konno, and Stein
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`2
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`
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`Overview of Argument
`• All Instituted Grounds:
`• Erroneous claim construction equating POV with FOV
`• Lack of motivation to combine multiple Parulski embodiments and
`Konno
`• Parulski’s “range map” does not teach a “fused image with a point
`of view (POV) of the Wide camera”
`
`• Grounds 2, 3, and 4
`• Combinations with and Szeliski, Segall, and Stein motivated by
`hindsight
`
`• Secondary Considerations of Non-Obviousness
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00905 | SLIDE
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`3
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`
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`Claim Construction
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`IPR2020-00905 | SLIDE 4
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`
`
`“fused image with a point of view (POV) of the Wide camera”
`Corephotonics’s Construction
`Apple’s First Construction
`“fused image in which the
`“a fused image that maintains the
`positions and shapes of objects
`Wide camera’s field of view or both
`reflect the POV of the Wide
`the Wide camera’s field of view and
`camera”
`position”
`
`POR, at 13; Sur-Reply, at 3-5.
`
`Ex. 1003, ¶¶ 29-33
`
`Sur-Reply, at 1-12.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`5
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`
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`Petitioner’s Construction Is Incorrect
`
`“POV” is not “field of view” and
`does not encompass FOV
`
`• POV is independent of FOV, and vice versa
`• One can have two cameras with the same FOV, taking photos of a
`scene with different POVs
`• Likewise, the ’479 patent specification and claims use “point of
`view”/“POV” and “field of view”/“FOV” differently.
`
`Sur-Reply, at 5-6
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`6
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`
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`FOV: A Planar Angle Inherent to the Camera and Lens
`• FOV:
`• A numerical, angle value referring to the extent of a scene a
`given camera and lens can capture
`
`• Term of art with specific technical definition
`
`See POR, at 10; Ex. 1001, at 7:1-20
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`7
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`
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`Point-of-View versus Field of View
`
`Field of View 1 of
`46° (function of
`camera and lens)
`
`Field of View 2 of
`46° (function of
`camera and lens)
`
`IPR2020-00905 | SLIDE 8
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`
`
`Point-of-View versus Field of View
`
`IPR2020-00905 | SLIDE 9
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`
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`Point-of-View versus Field of View
`
`Field of View 3 of
`86° (function of
`camera and lens)
`
`Field of View 2 of
`46° (function of
`camera and lens)
`
`IPR2020-00905 | SLIDE 10
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`
`
`Point-of-View versus Field of View
`
`Point-of-view 1 showing
`objects with certain shape
`and location (function of
`position and direction of
`camera)
`
`IPR2020-00905 | SLIDE 11
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`
`
`Point-of-View versus Field of View
`
`Point-of-view 2 showing
`objects with certain shape
`and location (function of
`position and direction of
`camera)
`
`IPR2020-00905 | SLIDE 12
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`
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`Point-of-View versus Field of View
`
`Apple’s interpretation of “point of
`view” in related IPRs
`
`(e.g., slide 7 of Apple
`demonstratives in IPR2020-00487)
`
`IPR2020-00905 | SLIDE 13
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`
`
`POV: Depends on Position and Direction of Camera
`• POV:
`• Depends on position and direction of the camera
`• Different points-of-view will result in different object
`positions and shapes, irrespective of FOV
`• Cannot be fully expressed by a single numerical angle that is
`an inherent property of the camera and lens
`
`See POR, at 11-13, Ex. 1001 at 5:10-14.
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`14
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`
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`Specification Confirms: FOV is A Planar Angle Inherent to the
`Camera and Lens
`
`Ex. 1001, at 7:11-13
`
`All examples of FOV are in degrees:
`
`See POR, at 10; Ex. 1001, at 7:1-20
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`15
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`
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`Petitioner’s Expert Confirms FOV Is Property of Camera and Lens
`
`Q. Would you agree that a camera’s field of view is
`a property of the camera that’s independent of
`what direction the camera is pointing?
`
`A. So one definition or understanding of field of
`view would be – would be just an angle that’s a
`property of the combination of a camera and lens.
`
`Dr. Fredo Durand
`Petitioner’s Expert
`
`Ex. 2036, at 22:25-23:6.
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`IPR2020-00905 | SLIDE 16
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`See Patent Owner Sur-Reply, at 4-6
`
`
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`Petitioner’s Expert Admits that His Construction Uses “FOV” As
`An Angle, Not The Position/Direction of the Camera
`
`Q. So when you’re using the term “field of view” in
`this construction, you’re reviewing – you’re
`referring to how much of the scene is captured by
`the camera; is that right?
`
`A. This is a vague version of the definition, I would
`say one definition of the field of view. For example,
`the horizontal field of view is to look at the angle
`between the two edges of the – of the image.
`
`Dr. Fredo Durand
`Petitioner’s Expert
`
`Ex. 2036, at 22:4-12.
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`IPR2020-00905 | SLIDE 17
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`See Patent Owner Sur-Reply, at 4-6
`
`
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`POV: Depends on Position and Direction of Camera
`• POV is how objects are “seen by the sub-camera” and
`“will be shifted and have different perspective (shape)”
`given different cameras
`
`See POR, at 11-13, Ex. 1001 at 5:10-14.
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`18
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`
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`Examples of Different POVs
`
`See POR, at 12; Ex. 1013, at 468
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`19
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`
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`The Claims Confirm FOV and POV Are Different Concepts
`Claim 1
`
`POR, at 10; Ex. 1001, cls. 1, 23.
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`20
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`
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`The Claims Confirm FOV and POV Are Different Concepts
`Claim 23
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`POR, at 10; Ex. 1001, cls. 1, 23.
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`21
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`
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`Petitioner’s New Construction is Waived, Improper, and Wrong
`
`“fused image with a point of view (POV) of the Wide camera
`Corephotonics’s Construction
`Apple’s New, Second Construction
`“fused image in which the positions or
`“fused image in which the
`positions and shapes of objects
`shapes of objects reflect those of the
`reflect the POV of the Wide
`Wide Camera”
`camera”
`
`Reply, at 6 (emphasis added)
`
`POR, at 13; Sur-Reply, at 3-5.
`
`Sur-Reply, at 1-12.
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`22
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`
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`Petitioner’s New Construction is Waived, Improper, and Wrong
`
`“fused image with a point of view (POV) of the Wide camera
`Corephotonics’s Construction
`Apple’s New, Second Construction
`“fused image in which the positions or
`“fused image in which the
`positions and shapes of objects
`shapes of objects reflect those of the
`reflect the POV of the Wide
`Wide Camera”
`camera”
`
`Reply, at 6 (emphasis added)
`
`POR, at 13; Sur-Reply, at 3-5.
`Apple’s “Reply” construction:
`
`Sur-Reply, at 1-12.
`
`1.
`2.
`
`Is Inconsistent with the specification
`Is inconsistent with plain and ordinary
`meaning
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`23
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`
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`Petitioner’s Reply Construction is Contrary to the Specification
`
`See POR, at 12-13, Ex. 1001 at 5:1-34
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`24
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`
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`Petitioner’s Reply Construction is Contrary to the Specification
`
`Sentence relied upon by Apple
`for its new construction
`
`See POR, at 12-13, Ex. 1001 at 5:1-34
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`25
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`
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`Petitioner’s Reply Construction is Contrary to the Specification
`High order definition for
`POV: includes both
`perspective and position
`
`“Perspective POV” and
`“Position POV”: two
`subsidiary concepts
`
`See POR, at 12-13, Ex. 1001 at 5:1-34
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`26
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`
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`Petitioner’s Reply Construction is Contrary to the Specification
`
`No basis to conflate lower-
`order concepts with higher
`order concept
`
`See POR, at 12-13, Ex. 1001 at 5:1-34
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`27
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`
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`Challenged Claims Require a “point of view (POV)”
`
`See POR, at 12-13, Ex. 1001 at 5:1-34
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`28
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`
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`Petitioner’s Reply Construction is Contrary to the Specification
`
`Apple’s New, Second Construction
`“fused image in which the positions or
`shapes of objects reflect those of the
`Wide Camera”
`
`Reply, at 6 (emphasis added)
`
`See POR, at 12-13, Ex. 1001 at 5:1-34
`
`IPR2020-00905 | SLIDE 29
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`
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`The Board Should Adopt Patent Owner’s Construction
`
`“fused image with a point of view (POV) of the Wide camera
`Corephotonics’s Construction
`Apple’s First Construction
`“fused image in which the positions
`“a fused image that maintains the
`and shapes of objects reflect the POV
`Wide camera’s field of view or both
`of the Wide camera”
`the Wide camera’s field of view and
`position”
`Apple’s New, Second Construction
`“fused image in which the positions
`or shapes of objects reflect those of
`the Wide Camera”
`
`Sur-Reply, at 1-12.
`
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`IPR2020-00905 | SLIDE
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`30
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`
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`The Board Should Adopt Patent Owner’s Construction
`
`“fused image with a point of view (POV) of the Wide camera
`Corephotonics’s Construction
`Apple’s First Construction
`“fused image in which the positions
`“a fused image that maintains the
`and shapes of objects reflect the POV
`Wide camera’s field of view or both
`of the Wide camera”
`the Wide camera’s field of view and
`position”
`Apple’s New, Second Construction
`“fused image in which the positions
`or shapes of objects reflect those of
`the Wide Camera”
`
`Sur-Reply, at 1-12.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00905 | SLIDE
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`31
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`
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`Failure to Show Unpatentability
`With The Correct Construction
`
`IPR2020-00905 | SLIDE32
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`
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`Petitioner Has No Arguments Under the Correct Claim Construction
`• The Petition only addressed unpatentability under a clearly incorrect
`construction.
`
`• No evidence or argument supporting unpatentability in Petition using
`correct construction or even Apple’s Reply construction
`
`• Petitioner’s new, untimely arguments using a new, untimely claim
`construction on Reply cannot establish unpatentability.
`
`• Neither does Petitioner have any argument for unpatentability using
`Patent Owner’s construction.
`
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`IPR2020-00905 | SLIDE 33
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`
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`Petitioner Has No Arguments Under the Correct Claim Construction
`
`“I have not provided an opinion about whether
`Parulski satisfies Dr. Hart’s claim construction.”
`
`Ex. 2041, at 52:25-54:20
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`IPR2020-00905 | SLIDE 34
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`See Patent Owner Sur-Reply, at 4-6
`
`Dr. Fredo Durand
`Petitioner’s Expert
`
`
`
`Petitioner’s New Reply Arguments Are Waived
`
`PTAB Trial Practice Guide (August 2018 revision), at 15
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`IPR2020-00905 | SLIDE
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`35
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`
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`New Arguments Are Not Permitted On Reply
`
`“Rather than explaining how its original petition was correct, Continental’s
`subsequent arguments amount to an entirely new theory of prima facie
`obviousness absent from the petition. Shifting arguments in this fashion is
`foreclosed by statute, our precedent, and Board guidelines.”
`Wasica v. Con’t Auto Sys., 853 F.3d 1272, 1286 (Fed. Cir. 2017).
`
`“Thus, although ‘the introduction of new evidence in the course of the trial is
`to be expected in inter partes review trial proceedings,’ [] the shifting of
`arguments is not.”
`
`Pfizer Inc. v. Chugai Pharmaceutical, IPR2017-01357,
`Paper 56, at 19 (Nov. 28, 2018) (citations omitted)
`
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`IPR2020-00905 | SLIDE
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`36
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`
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`No Motivation to Combine
`Multiple Parulski Embodiments
`
`IPR2020-00905 | SLIDE37
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`
`
`Challenged Independent Claim 1
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`IPR2020-00905 | SLIDE
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`38
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`
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`Challenged Independent Claim 1
`
`Petition relies on Parulski
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`39
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`
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`Challenged Independent Claim 1
`
`1. Missing from Parulski and
`2.
`Relies on combining
`disparate embodiments
`without sufficient showing.
`
`Petition relies on Parulski
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`IPR2020-00905 | SLIDE
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`40
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`
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`U.S. Patent No. 7,859,588 (“Parulski”)
`
`Title:
`“Method and apparatus for operating a dual
`lens camera to augment an image”
`
`Date:
`March. 9, 2007
`
`IPR2020-00905 | SLIDE 41
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`
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`Petitioner Relies on Two Parulski Embodiments for [1.5.1]/[1.5.2]
`
`Parulski Embodiment
`
`Petition’s Citations
`
`Figure 11
`(“Range map”)
`Figures 14 and 26
`(“Broadened DOF”)
`
`Ex. 1005, at 20:1-15, 20:50-59,
`21:34-44
`Ex. 1005, at 22:14-42, 28:45-57
`
`POR, at 26-29; Pet. at 26-30
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`IPR2020-00905 | SLIDE 42
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`
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`Petitioner Relies on “Range Map” Embodiment for Pixel Mapping
`
`Pet. at 29-30
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`IPR2020-00905 | SLIDE 43
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`
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`“Range Map”: No Disclosure of Fused Images
`• Nothing in
`Parulski describes
`using a “range
`map” as part of a
`system that
`outputs a fused
`image.
`
`Ex. 1005, Fig. 11
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`IPR2020-00905 | SLIDE 44
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`
`
`“Range Map”: No Disclosure of Fused Images
`• Nothing in
`Parulski describes
`using a “range
`map” as part of a
`system that
`outputs a fused
`image.
`
`Ex. 1005, 20:1-15
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00905 | SLIDE 45
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`
`
`“Range Map”: No Disclosure of Fused Images
`• Nothing in
`Parulski describes
`using a “range
`map” as part of a
`system that
`outputs a fused
`image.
`
`Ex. 1005, 20:50-59
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00905 | SLIDE 46
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`
`
`“Range Map”: No Disclosure of Fused Images
`• Nothing in
`Parulski describes
`using a “range
`map” as part of a
`system that
`outputs a fused
`image.
`
`Ex. 1005, 21:34-44
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00905 | SLIDE 47
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`
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`Challenged Independent Claim 1
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`IPR2020-00905 | SLIDE
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`48
`
`
`
`Challenged Independent Claim 1
`
`Fusion not disclosed in
`“range map” embodiment
`
`Petitioner uses “range
`map” embodiment for
`“mapping” limitation
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`IPR2020-00905 | SLIDE
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`49
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`
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`Petitioner Relies on “Broadened DOF” Embodiment for Fusion
`
`Pet. at 27-28
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`IPR2020-00905 | SLIDE 50
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`
`
`Challenged Independent Claim 1
`
`Petitioner uses “broadened
`DOF” embodiment for fusion
`limitation
`
`“Broadened DOF” embodiment
`has no disclosure of “mapping”
`elements
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`IPR2020-00905 | SLIDE
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`51
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`
`
`But No Motivation to Combine “Range Map” Algorithm with
`“Broadened DOF” Algorithm
`
`“Range map”
`
`“Broadened DOF”
`
`+
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`IPR2020-00905 | SLIDE 52
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`
`
`But No Motivation to Combine “Range Map” Algorithm with
`“Broadened DOF” Algorithm
`• Petitioner offers insufficient motivation to combine the
`“range map” teachings with any of Parulski’s other
`embodiments.
`
`• Petitioner also ignores:
`• The “broadened DOF” embodiment does not need a range
`map to achieve its intended function
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00905 | SLIDE 53
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`
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`Petitioner’s “Blurring” Argument Is Contradicted by Parulski
`• Petitioner’s argument a
`POSITA would want to
`“blur” images is
`unsupported.
`
`• Blurring can be done
`without fusing image data
`from one camera with
`image data of another.
`
`Sur-Reply, at 7
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00905 | SLIDE 54
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`
`
`Petitioner’s Reply Acknowledges No Showing of Motivation
`• Instead, Petitioner’s
`Reply argues:
`“common sense,
`common wisdom and
`common knowledge”
`would have
`precipitated the
`combination.
`
`Reply, at 6-7.
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`IPR2020-00905 | SLIDE 55
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`
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`Petitioner’s “Common Sense” Argument Is Waived
`• The Petition contains
`no argument about
`motivation to
`combine Parulski’s
`“range map” data
`with the “broadened
`DOF” algorithm
`
`Reply, at 6-7.
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`IPR2020-00905 | SLIDE 56
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`
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`Motivation to Combine Disparate Embodiments Is Needed
`
`Abiomed, Inc. v. Maquet Cardiovascular, LLC,
`IPR2017-01204, Paper 9, at 11 (Oct. 23, 2017)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00905 | SLIDE 57
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`
`
`New Arguments Are Not Permitted On Reply
`
`“Rather than explaining how its original petition was correct, Continental’s
`subsequent arguments amount to an entirely new theory of prima facie
`obviousness absent from the petition. Shifting arguments in this fashion is
`foreclosed by statute, our precedent, and Board guidelines.”
`Wasica v. Con’t Auto Sys., 853 F.3d 1272, 1286 (Fed. Cir. 2017).
`
`“Thus, although ‘the introduction of new evidence in the course of the trial is
`to be expected in inter partes review trial proceedings,’ [] the shifting of
`arguments is not.”
`
`Pfizer Inc. v. Chugai Pharmaceutical, IPR2017-01357,
`Paper 56, at 19 (Nov. 28, 2018) (citations omitted)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2020-00905 | SLIDE
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`58
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`
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`No Motivation to Combine With
`Szeliski, Segall, and Stein
`
`IPR2020-00905 | SLIDE59
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`
`
`Ground 2: Combination with Szeliski Motivated By Hindsight
`• Petitioner gives no
`reason why POSITA
`would have picked
`Szeliski’s “rectification”
`method over
`numerous alternatives
`
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`IPR2020-00905 | SLIDE
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`60
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`POR, at 32
`
`
`
`Ground 3: Combination with Segall Motivated by Hindsight
`• No dispute that
`Segall’s motion-
`estimation techniques
`would add significant
`costs to Parulki’s
`stereo-based image
`registration system
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`IPR2020-00905 | SLIDE
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`61
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`POR, at 33
`
`
`
`Ground 4: Combination with Stein Motivated By Hindsight
`• Stein directed to car-
`mounted camera
`system for fast motion
`tracking
`• Parulski is not, and
`does not share need
`with Stein to carefully
`synchronize shutters to
`capture fast motion
`
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`IPR2020-00905 | SLIDE
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`62
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`
`
`ADDITIONAL DEMONSTRATIVE SLIDES
`ADDITIONAL DEMONSTRATIVE SLIDES
`
`core | photonics
`
`IPR2020-00905 | SLIDE63
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`
`
`Secondary Considerations
`
`IPR2020-00905 | SLIDE64
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`
`
`Long History of Interest in Corephotonics’ Fusion Technology
`• 2012-2013:
`Apple emails Corephotonics
`to request more information
`about “software that fuses
`wide angle and telephoto
`video together,” and “image
`registration in GPU.”
`• Apple admits: it knows
`“image processing includes
`much of [Corephotonics’] IP.”
`
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`IPR2020-00905 | SLIDE
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`65
`
`Exs. 2011, 2012
`
`
`
`Long History of Interest in Corephotonics’ Fusion Technology
`•
`July 2013:
`Apple emails Corephotonics
`to saying:
`“Thank you for the images. We
`don’t see any parallax issues,
`and the Corephotonics images
`blend the wide and tele image
`data very smoothly.”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00905 | SLIDE
`
`66
`
`Ex. 2019
`
`
`
`Long History of Interest in Corephotonics’ Fusion Technology
`• October 2013:
`Apple confirms
`Corephotonics’ image fusion
`algorithm produces good
`results.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00905 | SLIDE
`
`67
`
`Ex. 2020
`
`
`
`Long History of Interest in Corephotonics’ Fusion Technology
`• May 2014:
`Apple’s company executives send “very clear message” Corephotonics’
`technology is valuable
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00905 | SLIDE
`
`68
`
`Ex. 2023
`
`
`
`Long History of Interest in Corephotonics’ Fusion Technology
`•
`June 2014:
`Corephotonics proposes
`to Apple an engagement
`framework for licensing
`Corephotonics’ “fusion
`technology along with
`additional components
`relating to zoom.”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2020-00905 | SLIDE
`
`69
`
`Ex. 2006
`
`
`
`Begin Protective Order Material
`
`IPR2020-00905 | SLIDE70
`
`
`
`End Protective Order Material
`
`IPR2020-00905 | SLIDE78
`
`
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