`
`U.S. Patent No. 8,749,251 (“’251 Patent”) in light of any of the purported “Secondary References,” alone or in combination,
`
`EXHIBIT C-22
`
`Complainant denies that any of the purported “Secondary References,” alone or in combination with any other reference,
`renders obvious any claim of U.S. Patent No. 8,749,251 (“’251 Patent”). As to obviousness, Respondents have failed to identify any
`limitation of any claim that is not disclosed by any of the purported “Secondary References” and have failed to identify any basis for
`combining any of the purported “Secondary References” with any other reference or with the alleged knowledge of one of ordinary
`skill in the art. Complainant does not admit that any of the “Secondary References” qualifies as prior art to the ’251 Patent.
`Complainant expressly denies that Respondents have adequately disclosed any obviousness theory based on a combination of
`references for which Respondents’ claim chart does not disclose the specific references to be combined and the purported motivation
`to combine these specific references.
`
`• U.S. Patent No. 3,277,381 (“Sullivan”)
`• U.S. Patent No. 3,483,401 (“Michalski”)
`• U.S. Patent No. 6,452,494 (“Harrison”)
`• U.S. Patent No. 5,333,119 (“Raatz”)
`• U.S. Patent No. 5,669,004 (“Sellers”)
`• U.S. Patent No. 8,654,083 (“Hotelling 083”)
`• KR2005-0045541 (“Oh”)
`• KR10-0674480 (“Lee 480”)
`• KR20-0266980 (“Yoon”)
`• “QT110: QTouch™ Sensor IC” (the “QT 110 Data Sheet”
`
`
`
`To the extent that Respondents’ Exhibit C-22 cites or incorporates by reference any other exhibit, Complainant likewise
`incorporates by reference its corresponding responsive exhibit.
`
`
`Claims
`1[pre] An apparatus comprising:
`
`1[a] a sensing element of a touch screen;
`and
`
`“Secondary References”
`To the extent the preamble is construed as a limitation, Respondents have not shown that
`any of the purported “Secondary References,” alone or in combination, discloses the
`claimed apparatus.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed “sensing element of a touch screen.”
`
`Page 1
`
`Petitioners Samsung and Sony Ex-1030, 0001
`
`

`

`Claims
`1[b] one or more computer-readable
`non- transitory storage media coupled to
`the sensing element and embodying
`logic that is operable when executed to:
`determine an amount of time that has
`elapsed since the sensing element last
`detected a change of capacitance
`indicative of a key touch on the touch
`screen; and if the amount of time that
`has elapsed exceeds a predetermined
`time duration, then initiate a particular
`function of the apparatus.
`2[a] The apparatus of claim 1, wherein
`the particular function comprises
`deactivation of measurement of changes
`in capacitance by the sensing element.
`
`3[a] The apparatus of claim 1, wherein
`the particular function comprises
`recalibration of measurement of changes
`in capacitance by the sensing element.
`
`EXHIBIT C-22
`
`“Secondary References”
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed “one or more computer-readable non- transitory
`storage media coupled to the sensing element and embodying logic that is operable when
`executed to: determine an amount of time that has elapsed since the sensing element last
`detected a change of capacitance indicative of a key touch on the touch screen; and if the
`amount of time that has elapsed exceeds a predetermined time duration, then initiate a
`particular function of the apparatus.”
`
`Neodron and the Staff contend that “deactivation of measurement of changes in
`capacitance” should be construed as: Plain and ordinary meaning: “deactivation of
`measurement of changes in capacitance.” Respondents contend that “deactivation of
`measurement of changes in capacitance” should be construed as “stopping all current and
`scheduled measurements of changes in capacitance.”
`
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the apparatus of claim 1.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed apparatus “wherein the particular function
`comprises deactivation of measurement of changes in capacitance by the sensing
`element.”
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the apparatus of claim 1.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed apparatus “wherein the particular function
`
`Page 2
`
`Petitioners Samsung and Sony Ex-1030, 0002
`
`

`

`EXHIBIT C-22
`
`Claims
`
`4[a] The apparatus of claim 1, wherein
`the logic is further operable to calculate
`the predetermined time duration based
`on one of a plurality of power supply
`voltages or an output voltage of the
`sensing element.
`
`5[a] The apparatus of claim 1, wherein
`the logic is further operable to calculate
`the predetermined time duration based
`on one of a plurality of delay multipliers
`determined by a polarity of a voltage
`pulse.
`
`6[a] The apparatus of claim 1, wherein
`the particular function comprises turning
`off the apparatus.
`
`7[a] The apparatus of claim 1, wherein
`sensing element comprises a control
`circuit.
`
`“Secondary References”
`comprises recalibration of measurement of changes in capacitance by the sensing
`element.”
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the apparatus of claim 1.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed apparatus “wherein the logic is further operable to
`calculate the predetermined time duration based on one of a plurality of power supply
`voltages or an output voltage of the sensing element.”
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the apparatus of claim 1.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed apparatus “wherein the logic is further operable to
`calculate the predetermined time duration based on one of a plurality of delay multipliers
`determined by a polarity of a voltage pulse.”
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the apparatus of claim 1.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed apparatus “wherein the particular function
`comprises turning off the apparatus.”
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the apparatus of claim 1.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed apparatus “wherein sensing element comprises a
`control circuit.”
`
`Page 3
`
`Petitioners Samsung and Sony Ex-1030, 0003
`
`

`

`EXHIBIT C-22
`
`Claims
`8[a] The apparatus of claim 7, wherein
`the sensing element further comprises a
`pattern of electrodes within the touch
`screen, the electrodes being coupled to
`the control circuit.
`
`9[a] The apparatus of claim 8, wherein
`the electrodes comprise indium tin oxide
`(ITO).
`
`16[pre] A computer- readable non-
`transitory storage media embodying
`logic that is operable when executed to:
`16[a] monitor detection by a sensing
`element of a key touch on a touch
`screen, the sensing element being of a
`touch screen;
`
`16[b] determine an amount of time that
`has elapsed since the sensing element
`last detected a change of capacitance
`indicative of a key touch on the touch
`screen; and
`
`16[c] if the amount of time that has
`elapsed exceeds a predetermined time
`
`“Secondary References”
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the apparatus of claim 7.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed apparatus “wherein the sensing element further
`comprises a pattern of electrodes within the touch screen, the electrodes being coupled to
`the control circuit.”
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the apparatus of claim 8.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed apparatus “wherein the electrodes comprise indium
`tin oxide (ITO).”
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses a “computer- readable non-transitory storage media embodying
`logic that is operable when executed to” perform the claimed steps.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed step “monitor detection by a sensing element of a
`key touch on a touch screen, the sensing element being of a touch screen.”
`See supra element 1[a].
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed step “determine an amount of time that has elapsed
`since the sensing element last detected a change of capacitance indicative of a key touch
`on the touch screen.”
`See supra element 1[b].
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed step “if the amount of time that has elapsed
`
`Page 4
`
`Petitioners Samsung and Sony Ex-1030, 0004
`
`

`

`Claims
`duration, then initiate a particular
`function of an apparatus.
`
`17[a] The media of claim 16, wherein
`the particular function comprises
`deactivation of measurement of changes
`in capacitance by the sensing element.
`
`18[a] The media of claim 16, wherein
`the particular function comprises
`recalibration of measurement of changes
`in capacitance by the sensing element.
`
`19[a] The media of claim 16, wherein
`the logic is further operable to calculate
`the predetermined time duration based
`on one of a plurality of power supply
`voltages or an output voltage of the
`sensing element.
`
`EXHIBIT C-22
`
`“Secondary References”
`exceeds a predetermined time duration, then initiate a particular function of an
`apparatus.”
`See supra element 1[b].
`Neodron and the Staff contend that “deactivation of measurement of changes in
`capacitance” should be construed as: Plain and ordinary meaning: “deactivation of
`measurement of changes in capacitance.” Respondents contend that “deactivation of
`measurement of changes in capacitance” should be construed as “stopping all current and
`scheduled measurements of changes in capacitance.”
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses a media of claim 16.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed media “wherein the particular function comprises
`deactivation of measurement of changes in capacitance by the sensing element.”
`See supra element 2[a].
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses a media of claim 16.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed media “wherein the particular function comprises
`recalibration of measurement of changes in capacitance by the sensing element.”
`See supra element 3[a].
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses a media of claim 16.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed media “wherein the logic is further operable to
`
`Page 5
`
`Petitioners Samsung and Sony Ex-1030, 0005
`
`

`

`EXHIBIT C-22
`
`Claims
`
`20[a] The media of claim 16, wherein
`the logic is further operable to calculate
`the predetermined time duration based
`on one of a plurality of delay multipliers
`determined by a polarity of a voltage
`pulse.
`
`
`
`“Secondary References”
`calculate the predetermined time duration based on one of a plurality of power supply
`voltages or an output voltage of the sensing element.”
`See supra element 4[a].
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses a media of claim 16.
`Respondents have not shown that any of the purported “Secondary References,” alone or
`in combination, discloses the claimed media “wherein the logic is further operable to
`calculate the predetermined time duration based on one of a plurality of delay multipliers
`determined by a polarity of a voltage pulse.”
`See supra element 5[a].
`
`Page 6
`
`Petitioners Samsung and Sony Ex-1030, 0006
`
`