`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`APPLE INC.,
`Petitioner
`v.
`COREPHOTONICS LTD.,
`Patent Owner
`
`_______________
`
`IPR2020-00905 & IPR2020-00906
`U.S. Patent No. 10,225,479
`
`_______________
`
`
`PETITIONER’S NOTICE FOR FILING TWO PETITIONS
`
`
`
`
`
`
`Petitioner’s Notice for Filing Two Petitions
`IPR2020-00905 & IPR2020-00906 / US Pat. No. 10,225,479
`Pursuant to the Consolidated Trial Practice Guide November 2019,
`
`
`
`Petitioner submits this paper to aid the Board’s understanding of why two petitions
`
`are needed to challenge validity of U.S. Patent No. 10,225,479 (“the ’479 Patent”).
`
`I.
`
`Petition’s Preference for Consideration
`
`Petitioner believes that both petitions should be instituted but ranks them in
`
`the following order for consideration:
`
`Preference
`1
`
`Petition
`Petition 1: IPR2020-00906
`
`Claims
`19-22
`
`2
`
`Petition 2: IPR2020-00905
`
`1-16, 18, 23-38, 40
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`II. Why Both Petitions Should be Instituted
`
`
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`Both Petitions should be instituted here because the non-overlapping
`
`claims recite different image processing techniques performed by different camera
`
`systems. While all of the claims are directed to a dual-lens camera with wide and
`
`telephoto lenses (1) having overlapping fields of view (FOV) and (2) an autofocus
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`mechanism providing each lens with separate focusing control, the cameras
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`perform different image processing steps.
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`The first camera in claim 19 performs a method that includes (1)
`
`controlling the autofocus mechanism, (2) calculating a depth map by finding
`
`corresponding points between the images to determine depth information, and (3)
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`creating a fused image that mimics a portrait photo captured with a DSLR lens
`
`
`
`1
`
`
`
`Petitioner’s Notice for Filing Two Petitions
`IPR2020-00905 & IPR2020-00906 / US Pat. No. 10,225,479
`suitable for creating a bokeh effect (i.e., principle subject in focus with a blurred
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`background).
`
`The second camera in claims 1 and 23 performs a different method that
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`includes (1) controlling the autofocus mechanism and (2) outputting a fused image
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`where just in-focus objects from the telephoto image are fused with the wide image
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`by mapping pixels that correspond to the object to corresponding pixels in the wide
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`image. The Parulski reference describes this as “broadening” the output image’s
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`depth of field. The overlapping dependent claims recite additional image
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`processing steps and camera specifications.
`
`Petition 1 challenges the first camera in claims 19-22 as obvious over
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`Parulski, Ogata, Kawamura, and Soga; relying on Parulski to show prior art
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`disclosure of the camera and the first two method steps, Ogata for the wide lens,
`
`Kawamura for the telephoto lens, and primarily Soga for the third method step.
`
`Petition 2 challenges the second camera in claims 1-16, 18, 23-38, and 40
`
`as obvious over Parulski and Konno; relying on Parulski and Konno to show prior
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`disclosure of the camera and Parulski for the method steps.
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`Consequently, the large number of claims and functional differences
`
`between them support instituting two petitions here. While Petition 1 only
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`challenges four claims, it requires a different combination and application of the
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`prior art than the 34 claims challenged in Petition 2.
`
`
`
`2
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`
`
`Petitioner’s Notice for Filing Two Petitions
`IPR2020-00905 & IPR2020-00906 / US Pat. No. 10,225,479
`Petitioner therefore respectfully requests that the Board consider and
`
`institute both petitions under 35 U.S.C. § 314(a).
`
`
`
`Dated: May 6, 2020
`HAYNES AND BOONE, LLP
`2323 Victory Avenue, Suite 700
`Dallas, Texas 75219
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Michael S. Parsons/
`Michael S. Parsons
`Lead Counsel for Petitioner
`Registration No. 58,767
`
`
`
`
`
`
`
`3
`
`
`
`Petitioner’s Notice for Filing Two Petitions
`IPR2020-00905 & IPR2020-00906 / US Pat. No. 10,225,479
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned certifies that, in accordance with 37 C.F.R. § 42.6(e) and
`
`37 C.F.R. § 42.105, service was made on Patent Owner as detailed below. Patent
`
`Owner has authorized electronic service due to the United States Post Office
`
`suspending deliver to the address listed in accordance with 37 CFR § 42.105(a).
`
`See APPL-1027.
`
`Date of service May 6, 2020
`Manner of service Electronically: mafenster@raklaw.com,
`bwang@raklaw.com, jtsuei@raklaw.com,
`nrubin@raklaw.com
`Documents served Petitioner’s Notice for Filing Two Petitions
`Persons served
`
`Marc A. Fenster, Benjamin T. Wang
`James S. Tsuei, Neil A. Rubin
`Russ August & Kabat
`12424 Wilshire Blvd., 12th Floor
`Los Angeles, CA 90025
`
`
`
`
`
`/Michael S. Parsons/
`Michael S. Parsons
`Lead Counsel for Petitioner
`Registration No. 58,767
`
`
`
`
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`4
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