IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`PATENT
`
`In re application of: Magnus Goertz
`
`Serial No.: 10/315,250
`
`Filed: December 10, 2002
`
`Title: User Interface
`
`Attorney Docket No.: 12511-00003 (New)
`(3682-32) (Previous)
`
`Group Art Unit: 2174
`
`Examiner: Ryan F. Pi taro
`
`Confirmation No.: 1226
`
`Commissioner for Patents
`Alexandria, VA 22313-1450
`
`March 14, 2008
`
`AMENDMENT AND RESPONSE TO NON-FINAL OFFICE ACTION
`
`This is in response to the Office Action (paper no. 200711 09) regarding the above(cid:173)
`
`identified patent application that was mailed from the U.S. Patent and Trademark Office on
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`November 14, 2007.
`
`A Status of the Claims starts on the following page 2.
`
`Remarks concerning the Office Action start on the following page 15.
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`Page 1 of32
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`Law Offices of
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`199 Main Street, P.O. Box 190
`Burlington, VT 05402-0 190
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`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 1
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`STATUS OF THE CLAIMS
`
`1.
`
`(Currently Amended) A computer readable medium storing a computer program with
`
`computer program code, which-eede, when read by a mobile handheld computer unit, allows
`
`the computer to present a user interface for the mobile handheld computer unit, the user
`
`interface comprising:
`
`a touch sensitive area that is simultaneously divided into a menu area and a display area,
`
`the mobile handheld computer unit being adapted to run several applications simultaneously,
`
`and to present an active application on top of any other application on ffie--said display
`
`area, characterised in, that
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`fue-said menu area simultaneously presenting presents representations of a first function
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`that is a general application dependent function, a second function that is a keyboard
`
`function, and a third function that is a task and file manager, and
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`each of the three said first second, and third functions simultaneously represented in fue
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`said menu area being activated by the single step of a&a blunt object moving in a
`
`direction from a starting point that is the representation of the corresponding one of
`
`said first, second. and third function~ in fue-said menu area to the-said display area
`
`being detected by the-said touch sensitive area, thereby allowing low precision
`
`navigation of the user interface using a-the blunt object, so that the user interface can
`
`be operated by one hand, where the blunt object is a finger.
`
`2. (Currently Amended) The computer readable medium of claim 1, wherein the mobile
`
`handheld computer unit runs an operating system, the user interface is characterized
`
`characterised in, that, if said first function is activated, said display area the user interface is
`
`adapted to display icons representing different services or settings depending on the current
`
`active application, that one of said icons always represents a "help" -service, regardless of
`
`application, and that, if no application is current active on said-the mobile handheld computer
`
`unit, said icons are adapted to represent services or settings of the operating system of said
`
`the mobile handheld computer unit.
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`Page 2 of32
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`Law Offices of
`Downs Rachlin Martin PLLC
`199 Main Street, P. 0. Box 190
`Burlington, VT 05402-0190
`(802) 863-2375
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`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 2
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`3. (Previously Presented) The computer readable medium of claim 2, wherein the user
`
`interface is characterised in, that a selection of a preferred service or setting is done by
`
`tapping on a corresponding icon.
`
`4.
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`(Previously Presented) The computer readable medium of claim 1, wherein the user
`
`interface is characterised in,
`
`-that, if said second function is activated, said display area is adapted to display a keyboard
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`and a text field,
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`- that, if a text passage in said active application is highlighted, said text passage is displayed
`
`in said text field for editing through said keyboard and that said highlighted test passage
`
`is replaced by said edited text passage when said second function is deactivated, and
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`-that, if no text passage in said active application is highlighted, said text field is available
`
`for inputting and editing of text thmugh said keyboard.
`
`5. (Previously Presented) The computer readable medium of claim 4, wherein the user
`
`interface is characterised in, that if no text passage in said active application is highlighted,
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`said text field is used for inputting and editing of text through said keyboard, then
`
`-said first function can be activated, or
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`- said second function can be closed, in which a choice of saving or deleting said inputted
`
`text is given, where the choice of saving said inputted text results in an activation of said
`
`first function,
`
`in which said first function will present services or settings available for said inputted text.
`
`6. (Currently Amended) The computer readable medium of claim 1, wherein the user
`
`interface is characterised in, that, if said third function is activated, said display area is
`
`adapted to display a list with a library of available applications and files on saffithe mobile
`
`handheld computer unit, that a selection of an application will start said application, and that
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`a selection of a file will open said file in an application intended for said file.
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`Page 3 of32
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`Law Offices of
`Downs Rachlin Martin PLLC
`199 Main Street, P.O. Box 190
`Burlington, VT 05402-0190
`(802) 863-2375
`
`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 3
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`7. (Currently Amended) The computer readable medium of claim 6, wherein the user
`
`interface is characterised in, that a selection of an application or file is done by moving said
`
`the blunt object so that the-.§Jepresentation of st. desired one of said application or file is
`
`highlighted, removing said object from said touch sensitive area, and then tapping on said
`
`touch sensitive area, and that aH:-said desired one of said application or file is highlighted by
`
`placing some kind of marking on the-said representation of said application or file.
`
`8. (Currently Amended) The computer readable medium of claim 7, wherein the user
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`interface is characterised in, that said list is adapted to present only said files or only said
`
`applications, that the-st. top area of said list presents a field through which the content of said
`
`list can be altered, that, if said list only presents files, said field displays a representation of a
`
`task manager and a selection of said field will cause said list to alter to present only
`
`applications, and that, if said list only presents applications, said field displays a
`
`representation of a file manager and a selection of said field will cause said list to alter and
`
`present only files.
`
`9. (Currently Amended) The computer readable medium of claim 7, wherein the user
`
`interface is characterised in, that, a navigation in said list is performed by moving said-the
`
`blunt object in a direction towards the top of said list or towards the bottom of said list, that
`
`the movement of said-the blunt object will cause said marking to move in the same direction,
`
`and that the speed of movement of said marking is lower than the speed of movement of said
`
`the blunt object.
`
`10. (Currently Amended) The computer readable medium of claim 9, wherein the user
`
`interface is characterised in, that, if the number of applications and/or files in said list
`
`exceeds the number of application and files that can be presented on said display area as
`
`content, and if said-the blunt object is moved to the top of bottom position of said display
`
`area, then lifted, replaced on said display area, and again moved to the top of bottom of said
`
`display area, the content of said display area will be replaced one whole page, meaning that if
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`Page 4 of32
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`Law Offices of
`Downs Rachlin Martin PLLC
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`Burlington, VT 05402-0190
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`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 4
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`saicl-the blunt object is positioned at the bottom of said display area, replaced on said display
`
`area, and then again moved to the bottom of said display area, the content of said display area
`
`will be replaced by the following applications and/or files in said list, and if said-the blunt
`
`object is positioned at the top of said display area, then lifted, replaced on said display area,
`
`and then again moved to the top of said display area, the content of said display area will be
`
`replaced by the preceding applications and/or files in the list.
`
`11. (Currently Amended) The computer readable medium of claim 10, wherein the user
`
`interface is characterised in, that if said-the blunt object is removed from any first position on
`
`said display area and then replaced on any second position on said display area, said
`
`navigation can be continued from said second position.
`
`12. (Currently Amended) The computer readable medium of claim 1, wherein the user
`
`interface is characterised in, that an active application, function, service or setting is moved
`
`on one step by moving said-the blunt object from the left of said display area to the right of
`
`said display area, and that the active application, function, service or setting is closed or
`
`backed one step by moving said-the blunt object from the right of said display area to the left
`
`of said display area.
`
`13. (Previously Presented) The computer readable medium of claim 1, wherein the user
`
`interface is characterised in, that said menu area is positioned at the bottom of said touch
`
`sensitive area, that said representation of said first function is positioned at the left side of
`
`said menu area, that said representation of said second function is positioned at the middle of
`
`said menu area, and that said representation of said third function is positioned at the right
`
`side of said menu area.
`
`14. (Currently Amended) The computer readable medium of claim 1, wherein the user
`
`interface is characterised in, that said user interface is adapted to a touch sensitive area with a
`
`size that is on the order of2-3 inches in diagonal dimension, and that said user interface is
`
`Page 5 of32
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`Law Offices of
`Downs Rachlin Martin PLLC
`199 Main Street, P.O. Box 190
`Burlington, VT 05402-0190
`(802) 863-2375
`
`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 5
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`adapted to be operated by one hand when the mobile handheld computer unit is held in the
`
`one hand, wherein said blunt object ean-13eis a fffigeffleshy part of the thumb of the one hand.
`
`15. (Currently Amended) An enclosure adapted to cover a computer unit, said computer unit
`
`oong adapted to read computer program code of a computer program stored on a computer
`
`readable medium, '.vhich code, when read, presents a user interface the mobile handheld
`
`computer unit according to Claim 1, characterised in, that said enclosure is provided with an
`
`opening for said display area, and that a representation of said menu area is printed on top of
`
`said enclosure.
`
`16. (Previously Presented) The enclosure according to claim 15, characterised in, that said
`
`enclosure is removable and exchangeable.
`
`17. (Original) A computer readable medium, with a computer program product stored therein,
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`characterised in, that said computer program product comprises computer readable code,
`
`which, when read by a computer, will make it possible for said computer to present a user
`
`interface according to Claim 1.
`
`18. (Original) A computer readable medium according to claim 17, characterized in, that said
`
`computer program product is adapted to function as a shell upon an operating system.
`
`19. (New) An apparatus, comprising:
`
`a computing device configured to provide a plurality of features and/or services to a user,
`
`said computing device including a user interface that comprises:
`
`a touchscreen for displaying to the user, individually at differing times, a plurality of
`
`display screens conesponding to said plurality of features and/or services and for
`
`allowing the user to navigate among said various differing features and/or services
`
`and among said plurality of display screens; and
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`Page 6 of32
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`Law Offices of
`Downs Rachlin Martin PLLC
`199 Main Street, P.O. Box 190
`Burlington, VT 05402-0 190
`(802) 863-2375
`
`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 6
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`user interface software responsive to interaction of an object with said touchscreen so as
`
`to allow the user to navigate among said plurality of features and! or services and
`
`among said plurality of display screens, said user interface software configured to:
`
`when said touchscreen is displaying a first display screen of said plurality of display
`
`screens, cause said computing device to display a second display screen of said
`
`plurality of display screens in response to a first sweeping movement of the object
`
`along said touchscreen in a first direction, said computing device displaying said
`
`second display screen after the object has traversed a first predetermined extent of
`
`said touchscreen along said first direction; and
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`when said touchscreen is displaying said second display screen, cause said computing
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`device to display said first display screen in response to a second sweeping
`
`movement of the object along said touchscreen in a second direction opposite said
`
`first direction, said computing device displaying said first display screen only
`
`after the object has traversed a second predetermined extent of said touchscreen
`
`along said second direction.
`
`20. (New) An apparatus according to claim 19, wherein said touchscreen has a left edge and a
`
`right edge when said touchscreen is properly oriented for viewing by the user and said first
`
`direction proceeds from a location at or proximate said left edge toward said right edge and
`
`said second direction proceeds from a location at or proximate said right edge toward said
`
`left edge.
`
`21. (New) An apparatus according to claim 20, wherein said touchscreen has a width extending
`
`from said left edge to said right edge and each of said first and second extents is substantially
`
`equal to said width.
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`22. (New) An apparatus according to claim 21, wherein said touchscreen has a diagonal
`
`dimension of two inches to three inches.
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`Page 7 of32
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`Law Offices of
`Downs Rachlin Martin PLLC
`199 Main Street, P.O. Box 190
`Burlington, VT 05402-0190
`(802) 863-2375
`
`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 7
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`

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`23. (New) An apparatus according to claim 19, wherein said computing device is sized to be
`
`cradled in a hand of an adult human user and so that, when so cradled, all points on said
`
`touchscreen are touchable by the thumb of the adult human user, the object being the thumb
`
`ofthe hand.
`
`24. (New) An apparatus according to claim 19, wherein each of the first and second sweeping
`
`movements does not drag any graphical feature displayed on said touchscreen during that one
`
`of the first and second sweeping movements.
`
`25. (New) An apparatus, comprising:
`
`a computing device configured to provide first and second menu-area functions to a user,
`
`said first menu-area function having a first-function display screen and said second
`
`menu-area function having a second-function display screen differing from said first(cid:173)
`
`function display screen, said computing device including a user interface that comprises:
`
`a touchscreen simultaneously divided into a menu region and a display region, said menu
`
`region containing first and second representations corresponding respectively to said
`
`first and second menu-area functions, said display region for displaying to the user at
`
`differing times said first-function and second-function display screens; and
`
`user interface software responsive to interaction of an object with said touchscreen so as
`
`to allow the user to select at differing times each of said first and second menu-area
`
`functions, said user interface software configured to:
`
`display said first-function display screen in response to a first sweeping movement of
`
`the object along said touchscreen, the first sweeping movement starting at said
`
`first representation in said menu region and proceeding into said display region;
`
`and
`
`display said second-function display screen in response to a second sweeping
`
`movement of the object along said touchscreen, the second sweeping movement
`
`starting at said second representation in said menu region and proceeding into said
`
`display region.
`
`Page 8 of32
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`Law Offices of
`Downs Rachlin Martin PLLC
`199 Main Street, P.O. Box 190
`Burlington, VT 05402-0190
`(802) 863-2375
`
`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 8
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`26. (New) An apparatus according to claim 25, wherein:
`
`said touchscreen has a first edge and a second edge spaced from said first edge;
`
`said first and second representations are each located proximate said first edge and spaced
`
`from one another along said first edge; and
`
`the first and second sweeping movements each proceed in a direction toward said second
`
`edge.
`
`27. (New) An apparatus according to claim 25, wherein said first-function display screen
`
`contains a plurality of icons corresponding respectively to a plurality of applications, said
`
`user interface software configured to activate any one of said plurality of applications in
`
`response to the user tapping the object on said touchscreen at a conesponding one of said
`
`plurality of icons.
`
`28. (New) An apparatus according to claim 27, wherein said second-function display screen
`
`contains a set of application functions, said set varying as a function of which one of said
`
`plurality of applications is active when the user makes the second movement.
`
`29. (New) An apparatus according to claim 27, wherein a particular application of said plurality
`
`of applications has a plurality of application screen displays, said user interface software
`
`configured so that when said particular application is active, the user forwardly steps through
`
`said plurality of application screen displays by sweeping the object across said touchscreen in
`
`a first direction and reversely steps through said plurality of application screen displays by
`
`sweeping the object across said touchscreen in a second direction opposite said first
`
`direction.
`
`30. (New) An apparatus according to claim 25, wherein said first display screen contains a soft(cid:173)
`
`interface telephony keypad.
`
`Page 9 of32
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`Law Offices of
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`199 Main Street, P.O. Box 190
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`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 9
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`

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`31. (New) An apparatus, comprising:
`
`a computing device configured to run a software application configured to display a plurality
`
`of predetennined display screens, said computing device including a user interface that
`
`comprises:
`
`a touchscreen for displaying to the user, individually at differing times, said plurality of
`
`predetermined display screens and for allowing the user to navigate among said
`
`plurality of predetermined display screens; and
`
`user interface software responsive to interaction of an object with said touchscreen so as
`
`to allow the user to navigate an1ong said plurality of predetennined display screens,
`
`said user interface software configured to:
`
`activate said software application in response to a particular interaction of the object
`
`with said touchscreen;
`
`forwardly step in series through ones of said plurality of predetermined display
`
`screens in response to corresponding respective individual instances of a first
`
`sweeping movement ofthe object along said touchscreen in a first direction; and
`
`reversely step in series through ones of said plurality of predetermined display
`
`screens in response to corresponding respective individual instances of a second
`
`sweeping movement of the object along said touchscreen in a second direction
`
`different from said first direction.
`
`32. (New) An apparatus according to claim 31, wherein said particular interaction of the object
`
`with said touchscreen to activate said software application is a third sweeping movement of
`
`the object along said touchscreen in a third direction different from each of said first and
`
`second directions.
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`33. (New) An apparatus according to claim 32, wherein said first and second directions are
`
`opposite one another and said third direction is perpendicular to each of said first and second
`
`directions.
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`Page 10 of32
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`Law Offices of
`Downs Rachlin Martin PLLC
`199 Main Street, P.O. Box 190
`Burlington, VT 05402-0190
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`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 10
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`.· .. ·.--·-----~·''- --~-·-··-'···------·--·-------~::..:.,-_l .. ·.· 1., . ..-.~""···-•->'>->':~''"'
`
`.,.,.· .. ···.··• · .. ··.-
`
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`
`. I·~·.,;.·.:-~··-'· •. ~_,._,,_,,_,.;~ .• =·,_-<_,,_ .. · ..
`
`34. (New) An apparatus, comprising:
`
`a computing device configured to run software for providing to a user a plurality of services
`
`and/or functions, said computing device including:
`
`a touchscreen for displaying to the user a graphical user interface and for allowing the
`
`user to navigate among said plurality of services and/or functions; and
`
`user interface software responsive to interaction of an object with said touchscreen so as
`
`to allow the user to navigate among said plurality of services and/or functions, said
`
`user interface software configured to:
`
`present, in response to a sweeping movement of the object across said touchscreen, a
`
`display screen containing a plurality of display icons conesponding respectively
`
`to ones of said plurality of services and/or functions, the sweeping movement
`
`being spatially uncorrelated with infonnation displayed on said touchscreen; and
`
`when said touchscreen is displaying said plurality of display icons, launch one of said
`
`plurality of services and/or functions in response to the user tapping the object on
`
`said touchscreen at a location where said touchscreen displays the conesponding
`
`one of said plurality of display icons.
`
`35. (New) An apparatus according to claim 34, wherein said computing device contains a
`
`software application and said user interface is configured to present said plurality of display
`
`icons only if said software application is active during the sweeping movement of the object.
`
`36. (New) An apparatus according to claim 35, wherein when said software application is active
`
`during the sweeping of the object, said display icons correspond to services and/or functions
`
`specific to said software application.
`
`37. (New) An apparatus, comprising:
`
`a computing device containing software for providing to a user a plurality of services and/or
`
`functions, said computing device including:
`
`Page 11 of32
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`Law Offices of
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`199 Main Street, P.O. Box 190
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`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 11
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`

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`a touchscreen for displaying to the user, individually at differing times, ones of various
`
`display screens associated with said plurality of services and/or functions and for
`
`allowing the user to navigate among said plurality of display screens so as to provide
`
`the user with access to said plurality of services and/or functions and for allowing the
`
`user to control functioning of ones of said plurality of services and/or functions; and
`
`user interface software responsive to a set of movements of an object with respect to said
`
`touchscreen so as to allow the user to navigate among said plurality of display screens
`
`and to control functioning of ones of said plurality of services and/or functions, said
`
`set of movements including a plurality of sweeping movements having differing
`
`directionalities along said touchscreen, wherein said plurality of sweeping movements
`
`being spatially unconelated with information displayed on said touchscreen, said user
`
`interface software being configured to distinguish the plurality of sweeping
`
`movements from one another as a function of the differing directionalities so as to
`
`provide differing responses as a function of said differing directionalities.
`
`38. (New) An apparatus according to claim 37, wherein two sweeping movements of the
`
`plurality of sweeping movements have opposing directionality and said user interface
`
`software is configured to provide two opposing responses corresponding respectively to said
`
`two sweeping movements.
`
`39. (New) An apparatus according to claim 38, wherein one ofthe two opposing responses is
`
`moving forward in a series of display screens and the other of the two opposing responses is
`
`moving backward in the series of display screens.
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`40. (New) An apparatus according to claim 37, wherein each ofthe plurality of sweeping
`
`movements does not drag any graphical feature displayed on said touchscreen during that one
`
`of the plurality of sweeping movements.
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`Page 12 of32
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`Law Offices of
`Downs Rachlin Martin PLLC
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`Burlington, VT 05402-0190
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`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 12
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`41. (New) An apparatus, comprising:
`
`a computing device configured to provide a plmality of features, settings, applications and/or
`
`services to a user, said computing device including a user interface that comprises:
`
`a touchscreen for displaying to the user a list of items conesponding to at least one of a
`
`plmality of features, settings, applications and/or services and for allowing the user to
`
`select any one of said items using said list; and
`
`user interface software responsive to interaction of an object with said touchscreen so as
`
`to allow the user to navigate among said list and to select any one of said items, said
`
`user interface software configured to move a highlight marking, having a displayed
`
`location on said touchscreen, in a desired direction within said list in response to the
`
`user:
`
`(a) contacting said touchscreen with the object at a first location that is a function of
`
`the desired direction, not said displayed location of said highlight marking;
`
`(b) while keeping the object in contact with said touchscreen, moving the object
`
`along said touchscreen in the desired direction to a second location; and
`
`(c) immediately following said moving of the object along said touchscreen to said
`
`second location, lifting the object fi·om said touchscreen so as to establish a new
`
`location of said highlight marking.
`
`42. (New) An apparatus according to claim 41, wherein said user interface software is
`
`configured to, after the user has marked a desired one of said items by performing steps (a)
`
`through (c) so as to highlight said desired one with the highlight marking, select said desired
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`one in response to the user tapping the object on said touchscreen without regard to said
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`display location of the highlight marking.
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`43. (New) An apparatus, comprising:
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`a computing device configured to provide a plurality of features, settings, applications and/or
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`services to a user, said computing device including a user interface that comprises:
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`Page 13 of32
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`Law Offices of
`Downs Rachlin Martin PLLC
`199 Main Street, P.O. Box 190
`Burlington, VT 05402-0190
`(802) 863-2375
`
`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 13
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`

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`a touchscreen for displaying to the user a list of items conesponding to at least one of
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`said plurality of features, settings, applications and/or services and for allowing the
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`user to select any one of said items using said list; and
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`user interface software responsive to interaction of an object with said touchscreen so as
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`to allow the user to scroll said list and to select any one of said plurality items, said
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`user interface software configured to scroll said list in a desired direction in response
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`to the user:
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`(a) contacting said touchscreen with the object at a first location that is a function of
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`the desired direction of said scroll and that is not based on any soft scroll control
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`displayed on said touchscreen; and
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`(b) while keeping the object in contact with said touchscreen, moving the object
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`along said touchscreen in the desired direction to a second location, wherein said
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`moving of the object causes said list to scroll in the desired direction.
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`44. (New) An apparatus according to claim 43, wherein said user interface software is
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`configured to activate a selected one of said items in response to a user tapping the object on
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`said touchscreen following the user lifting the object from the touchscreen after the user
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`perfonns step (b).
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`45. (New) An apparatus according to claim 43, wherein said items are files.
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`46. (New) An apparatus according to claim 43, wherein said items are email messages.
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`47. (New) An apparatus according to claim 43, wherein each item is contact information for a
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`conesponding contact.
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`Page 14 of32
`
`Law Offices of
`Downs Rachlin Martin PLLC
`199 Main Street, P.O. Box 190
`Burlington, VT 05402-0190
`(802) 863-2375
`
`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 14
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`

`

`REMARKS
`
`Claims 1-47 are presently pending. Claims 1, 2 and 6-12, 14 and 15 have been amended
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`for form and not for reasons relating to patentability ofthe claims in view of the references of
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`record. Claims 19-47 are new.
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`Applicant respectfully requests reconsideration of the application in view of the
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`foregoing amendments and the remarks appearing below.
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`The Current Patent Application
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`Before addressing in detail the specific rejections made in the current Office Action,
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`Applicant would like to emphasize that the unique touchscreen-based user interface of the
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`current patent application allows a user to navigate among, for example, applications, display
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`screens, services, functions and settings using "low-precision" navigation techniques. These
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`techniques are very different from conventional touchscreen interfaces, such as the touchscreen(cid:173)
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`based user interface of the Palm operating system described in the Carlson publication, which is
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`addressed in detail below in the context of the rejections set forth in the present Office Action.
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`Such conventional touchscreen-based user interfaces typically require the precise locating of a
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`pointing object, for example a stylus, within clearly identified bounds of a displayed graphical
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`feature, such as a page-up or page-down icon, scroll bar, button, menu item, application icon,
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`etc., to effect a desired action.
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`Low-precision navigation user interfaces made in accordance with the current application
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`can be implemented on very small touchscreens, for example, on the order of 2 inches to 3-
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`inches in diagonal dimension, yet still allow very easy and accurate navigation with, for
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`example, a user's thumb (even when gloved), despite the fact that the (gloved) thumb covers a
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`significant portion of the small screen during a navigation operation. For a demonstration of a
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`number of features disclosed in the current patent application and covered by the claims therein
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`and in the present Response, the Examiner is encouraged to access http://www.neonode.com/en(cid:173)
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`us/on-stage/products/n2/introduction/ and watch the video demonstration of the N2 mobile
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`phone/personal digital assistant device made by N eonode AB. The N2 device and its
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`Page 15 of32
`
`Law Offices of
`Downs Rachlin Martin PLLC
`199 Main Street, P.O. Box 190
`Burlington, VT 05402-0190
`(802) 863-2375
`
`Neonode Smartphone LLC, Exhibit 2035
`Page 2035 - 15
`IPR2021-00144, Samsung Elecs. Co. Ltd. et al. v. Neonode Smartphone LLC
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`

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`predecessor