EXHIBIT C-6
`
`U.S. Patent No. 8,749,251 (“’251 Patent”) in light of Krah
`
`
`
`Complainant denies that U.S. Patent Application Publication No. 2008/0162996 (“Krah”) anticipates any claim of U.S. Patent
`No. 8,749,251 (“’251 Patent”) and denies that Krah, alone or in combination with any other reference, renders obvious any claim of
`the ’251 Patent. As to obviousness, Respondents have failed to identify any limitation of any claim that is not disclosed by Krah, and
`have failed to identify any basis for combining Krah with any other reference or with the alleged knowledge of one of ordinary skill in
`the art.
`
`There is a list of purported prior art references identified at the top of Respondents’ claim chart for Krah. Complainant does
`
`not admit that any reference in that list 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.
`
`
`Claims
`1[pre] An apparatus comprising:
`
`1[a] a sensing element of a touch screen;
`and
`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.
`
`Krah
`To the extent the preamble is construed as a limitation, Respondents have not shown that
`Krah discloses the claimed apparatus.
`Respondents have not shown that Krah discloses the claimed “sensing element of a touch
`screen.”
`Respondents have not shown that Krah 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.”
`Furthermore, Respondents have not identified the particular portion(s) of Krah they
`contend correspond to the claimed “amount of time,” the claimed “key touch on the
`touch screen,” the claimed “predetermined time duration,” or the claimed “particular
`function of the apparatus.”
`Respondents identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`
`Page 1
`
`Petitioners Samsung and Sony Ex-1029, 0001
`
`

`

`Claims
`
`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-6
`
`Krah
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`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 Krah discloses the apparatus of claim 1.
`Respondents have not shown that Krah discloses the claimed apparatus “wherein the
`particular function comprises deactivation of measurement of changes in capacitance by
`the sensing element.”
`Respondents identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`Respondents have not shown that Krah discloses the apparatus of claim 1.
`Respondents have not shown that Krah discloses the claimed apparatus “wherein the
`particular function comprises recalibration of measurement of changes in capacitance by
`the sensing element.”
`Respondents identify an additional reference allegedly disclosing this claim element,
`which Complainant addresses in its corresponding claim charts for that reference.
`
`Page 2
`
`Petitioners Samsung and Sony Ex-1029, 0002
`
`

`

`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.
`
`EXHIBIT C-6
`
`Krah
`Respondents have failed to show that one of ordinary skill in the art would have
`combined the identified reference with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to identify specific reasons that one of
`ordinary skill in the art would have combined the teachings of these references.
`Respondents have not shown that Krah discloses the apparatus of claim 1.
`Respondents have not shown that Krah 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 identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`Respondents have not shown that Krah discloses the apparatus of claim 1.
`Respondents have not shown that Krah 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 identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`
`Page 3
`
`Petitioners Samsung and Sony Ex-1029, 0003
`
`

`

`Claims
`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.
`
`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.
`
`EXHIBIT C-6
`
`Krah
`Respondents have not shown that Krah discloses the apparatus of claim 1.
`Respondents have not shown that Krah discloses the claimed apparatus “wherein the
`particular function comprises turning off the apparatus.”
`Respondents identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`Respondents have not shown that Krah discloses the apparatus of claim 1.
`Respondents have not shown that Krah discloses the claimed apparatus “wherein sensing
`element comprises a control circuit.”
`Respondents identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`Respondents have not shown that Krah discloses the apparatus of claim 7.
`Respondents identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`
`Page 4
`
`Petitioners Samsung and Sony Ex-1029, 0004
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`

`

`Claims
`
`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
`
`EXHIBIT C-6
`
`Krah
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`Respondents have not shown that Krah discloses the apparatus of claim 8.
`Respondents identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`Respondents have not shown that Krah 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 Krah 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 identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`Respondents have not shown that Krah 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.”
`
`Page 5
`
`Petitioners Samsung and Sony Ex-1029, 0005
`
`

`

`Claims
`indicative of a key touch on the touch
`screen; and
`
`16[c] if the amount of time that has
`elapsed exceeds a predetermined time
`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.
`
`EXHIBIT C-6
`
`Krah
`
`See supra element 1[b].
`Respondents identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`Respondents have not shown that Krah discloses the claimed step “if the amount of time
`that has elapsed exceeds a predetermined time duration, then initiate a particular function
`of an apparatus.”
`See supra element 1[b].
`Respondents identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`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 Krah discloses a media of claim 16.
`
`Page 6
`
`Petitioners Samsung and Sony Ex-1029, 0006
`
`

`

`EXHIBIT C-6
`
`Krah
`Respondents have not shown that Krah 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 identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`Respondents have not shown that Krah discloses a media of claim 16.
`Respondents have not shown that Krah 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 identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`Respondents have not shown that Krah discloses a media of claim 16.
`
`Claims
`
`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
`
`Page 7
`
`Petitioners Samsung and Sony Ex-1029, 0007
`
`

`

`Claims
`voltages or an output voltage of the
`sensing element.
`
`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.
`
`
`
`EXHIBIT C-6
`
`Krah
`Respondents have not shown that Krah discloses the claimed media “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.”
`See supra element 4[a].
`Respondents identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`Respondents have not shown that Krah discloses a media of claim 16.
`Respondents have not shown that Krah 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].
`Respondents identify additional references allegedly disclosing this claim element, which
`Complainant addresses in its corresponding claim charts for those references.
`Respondents have failed to show that one of ordinary skill in the art would have
`combined any of the identified references with Krah. Respondents’ boilerplate language
`regarding alleged motivation to combine fails to specify which references comprise the
`proposed combination and fails to identify specific reasons that one of ordinary skill in
`the art would have combined the teachings of these references.
`
`Page 8
`
`Petitioners Samsung and Sony Ex-1029, 0008
`
`