`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`In re Patent of: Magnus Goertz
`U.S. Patent No.:
`8,812,993 Attorney Docket No.: 50095-0016IP1
`Issue Date:
`August 19, 2014
`
`Appl. Serial No.: 13/310,755
`
`Filing Date:
`December 4, 2011
`
`Title:
`USER INTERFACE
`
`DECLARATION OF DR. BENJAMIN B. BEDERSON
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`Declaration of Dr. Benjamin B. Bederson
`U.S. Patent No. 8,812,993
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`TABLE OF CONTENTS
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`INTRODUCTION .......................................................................................... 1
`I.
`BACKGROUND AND QUALIFICATIONS ................................................ 1
`II.
`INFORMATION CONSIDERED ............................................................... 15
`III.
`IV. RELEVANT LEGAL STANDARDS .......................................................... 18
`A.
`Claim Interpretation ........................................................................... 18
`B.
`Perspective of One of Ordinary Skill in the Art ................................ 18
`C.
`Anticipation ........................................................................................ 19
`
`D. Obviousness ....................................................................................... 19
`SUMMARY OF MY OPINIONS ................................................................ 22
`V.
`VI. THE ’993 PATENT ..................................................................................... 23
`A.
`The ’993 Patent Alleged Invention .................................................... 23
`B.
`The ’993 Patent Prosecution History ................................................. 29
`C.
`Priority Date ....................................................................................... 32
`D.
`Level of Ordinary Skill in the Art ...................................................... 32
`E.
`Claim Construction ............................................................................ 33
`VII. THE PRIOR ART ........................................................................................ 33
`A. Well-known Concepts as of the Critical Date .................................... 33
`1.
`Electronic Devices Comprising Touch-sensitive Display
`Screens and Computer Readable Medium for Storing
`Instructions to Enable a User Interface for said Device .......... 33
`
`2.
`
`User Interfaces Comprising a State Where Tap-
`Activatable Icons Are Absent to Avoid a Cluttered
`Screen ...................................................................................... 36
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`3.
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`4.
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`B.
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`Declaration of Dr. Benjamin B. Bederson
`U.S. Patent No. 8,812,993
`User Interfaces Comprising a State Where A Plurality of
`Tap-Activatable Icons Are Present .......................................... 37
`Transitioning Between States Within a User Interface
`Using a Touch-and-Glide Gesture ........................................... 43
`Prior Art Combinations ...................................................................... 45
`1.
`Hisatomi, Ren, Allard-656, Tanaka, and Kodoma .................. 45
`2.
`Hansen, Gillespie, Allard-656, Tanaka, and Kodama ............. 60
`VIII. DETAILED EXPLANATION OF UNPATENTABILITY ......................... 76
`A.
`Claims 1-3, 7, and 8 are Rendered Obvious by Hisatomi in view
`of the POSA Knowledge and/or Ren ................................................. 76
`1.
`Claim 1 .................................................................................... 76
`2.
`Claim 2: “The computer readable medium of claim 1,
`wherein any state transition elicited by a user gesture that
`begins at a location at which the otherwise-activatable
`graphic is provided, transitions to the tap-present state.” ...... 108
`Claim 3: “The computer readable medium of claim 1,
`wherein the tap-present state does not display the tap-
`activatable icons within a window frame.” ........................... 109
`Claim 7: “The computer readable medium of claim 1,
`wherein the strip is less than a thumb's width wide within
`the display screen” ................................................................. 111
`Claim 8: “The computer readable medium of claim 1,
`wherein the multi-step user gesture comprises (i) the
`object touching the otherwise-activatable graphic, and (ii)
`the object gliding on the display screen away from and
`out of the strip.” ..................................................................... 113
`Claim 4 is Rendered Obvious by Hisatomi in view of POSA
`Knowledge and Allard-656 and/or Ren and Allard-656 .................. 115
`
`B.
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`3.
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`4.
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`5.
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`C.
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`D.
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`E.
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`1.
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`3.
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`Declaration of Dr. Benjamin B. Bederson
`U.S. Patent No. 8,812,993
`Claim 4: “The computer readable medium of claim 1,
`wherein the plurality of pre-designated system functions
`comprises a help function.” ................................................... 115
`Claim 5 is Rendered Obvious by Hisatomi in view of POSA
`Knowledge and Tanaka and/or Ren and Tanaka ............................. 119
`1.
`Claim 5: “The computer readable medium of claim 1,
`wherein the plurality of pre-designated system functions
`comprises a clock function.” ................................................. 119
`Claim 6 is Rendered Obvious by Hisatomi in view of POSA
`Knowledge and Kodoma and/or Ren and Kodoma ......................... 123
`1.
`Claim 6: “The computer readable medium of claim 1,
`wherein the plurality of pre-designated system functions
`comprises an alarm function.” ............................................... 123
`Claims 1-3, 7, and 8 are Rendered Obvious by Hansen in view
`of Gillespie ....................................................................................... 126
`1.
`Claim 1 .................................................................................. 126
`2.
`Claim 2: “The computer readable medium of claim 1,
`wherein any state transition elicited by a user gesture that
`begins at a location at which the otherwise-activatable
`graphic is provided, transitions to the tap-present state.” ...... 140
`Claim 3: “The computer readable medium of claim 1,
`wherein the tap-present state does not display the tap-
`activatable icons within a window frame.” ........................... 142
`Claim 7: “The computer readable medium of claim 1,
`wherein the strip is less than a thumb's width wide within
`the display screen” ................................................................. 144
`Claim 8: “The computer readable medium of claim 1,
`wherein the multi-step user gesture comprises (i) the
`object touching the otherwise-activatable graphic, and (ii)
`the object gliding on the display screen away from and
`out of the strip.” ..................................................................... 145
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`4.
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`5.
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`F.
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`G.
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`Declaration of Dr. Benjamin B. Bederson
`U.S. Patent No. 8,812,993
`Claim 4 is Rendered Obvious by Hansen in view of Gillespie
`and Allard-656 ................................................................................. 146
`1.
`Claim 4: “The computer readable medium of claim 1,
`wherein the plurality of pre-designated system functions
`comprises a help function.” ................................................... 146
`Claim 5 is Rendered Obvious by Hansen in view of Gillespie
`and Tanaka ....................................................................................... 148
`1.
`Claim 5: “The computer readable medium of claim 1,
`wherein the plurality of pre-designated system functions
`comprises a clock function.” ................................................. 148
`Claim 6 is Rendered Obvious by Hansen in view of Gillespie
`and Kodama ..................................................................................... 151
`1.
`Claim 6: “The computer readable medium of claim 1,
`wherein the plurality of pre-designated system functions
`comprises an alarm function.” ............................................... 151
`IX. CONCLUSION .......................................................................................... 155
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`H.
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`Declaration of Dr. Benjamin B. Bederson
`U.S. Patent No. 8,812,993
`I, Dr. Benjamin B. Bederson, declare as follows:
`
`1.
`
`I.
`
`INTRODUCTION
`2.
`I have been retained by Samsung Electronics Co., Ltd., Samsung
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`Electronics America, Inc., and Apple, Inc. (collectively, “Petitioners”) as an
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`independent expert consultant in this inter partes review (“IPR”) proceeding
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`before the United States Patent and Trademark Office (“PTO”).
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`3.
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`I have been asked by Petitioners’ counsel (“Counsel”) to consider
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`whether certain references teach or suggest the features recited in Claims 1-8 of
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`U.S. Patent No. 8,812,993 (“the ’993 Patent”) (EX1001). My opinions and the
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`bases for my opinions are set forth below.
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`4.
`
`I am being compensated at my ordinary and customary consulting rate
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`for my work, which is $600 per hour. My compensation is in no way contingent
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`on the nature of my findings, the presentation of my findings in testimony, or the
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`outcome of this or any other proceeding. I have no other financial interest in this
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`proceeding.
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`II. BACKGROUND AND QUALIFICATIONS
`5.
`All of my opinions stated in this declaration are based on my own
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`personal knowledge and professional judgment. In forming my opinions, I have
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`relied on my knowledge and experience in designing, developing, researching, and
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`teaching the technology referenced in this declaration.
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`I am over 18 years of age and, if I am called upon to do so, I would be
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`6.
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`competent to testify as to the matters set forth herein. I understand that a copy of
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`my current curriculum vitae, which details my education and professional and
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`academic experience, is being submitted as EX1004. The following provides a
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`brief overview of some of my experience that is relevant to the matters set forth in
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`this declaration.
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`7.
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`I am currently Professor Emeritus of Computer Science at the
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`University of Maryland (“UMD”). From 2014 to 2018, I was the Associate
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`Provost of Learning Initiatives and Executive Director of the Teaching and
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`Learning Transformation Center at the UMD. I am a member and previous
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`director of the Human-Computer Interaction Lab (“HCIL”), the oldest and one of
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`the best known Human-Computer Interaction (“HCI”) research groups in the
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`country. I was also co-founder and Chief Scientist of Zumobi, Inc. from 2006 to
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`2014, a Seattle-based startup that is a publisher of content applications and
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`advertising platforms for smartphones. I am also co-founder and co-director of the
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`International Children’s Digital Library (“ICDL”), a web site launched in 2002 that
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`provides the world’s largest collection of freely available online children’s books
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`from around the world with an interface aimed to make it easy for children and
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`adults to search and read children’s books online. I am also cofounder and prior
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`Chief Technology Officer of Hazel Analytics, a data analytics company to improve
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`Declaration of Dr. Benjamin B. Bederson
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`food safety and better public health whose product sends alerts in warranted
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`circumstances. In addition, I have for more than 25 years consulted for numerous
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`companies in the area of user interfaces, including Hillcrest Labs, Lockheed
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`Martin, Logitech, Microsoft, NASA Goddard Space Flight Center, the Palo Alto
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`Research Center, and Sony.
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`8.
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`The devices and methods claimed in the ’993 Patent generally relate
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`to user interface technology for electronic devices. For more than 30 years, I have
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`studied, designed, and worked in the field of computer science and HCI. That
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`includes teaching and research, with research interests in HCI and the software and
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`technology underlying today’s interactive computing systems. This includes the
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`design and implementation of hardware and software systems including the use of
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`capacitive and other sensors, and interactive applications on a range of devices,
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`including embedded systems, controllers, smart phones and PDAs.
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`9.
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`At UMD, I am focused primarily on the area of HCI, a field that
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`relates to the development and understanding of computing systems to serve users’
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`needs. Researchers and practitioners in this field are focused on making
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`universally usable, useful, efficient, and appealing systems to support people in
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`their wide range of activities. My approach is to balance the development of
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`innovative technology that serves people’s practical needs. Example systems
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`following this approach that I have built include Cortex-I (1992 embedded
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`Declaration of Dr. Benjamin B. Bederson
`U.S. Patent No. 8,812,993
`computer vision system that sensed licensed plates with custom motor, camera and
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`controller), Audio Augmented Reality (1995 embedded system for sensing a user’s
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`location and playing audio suited to that location), Fisheye Menus (2000 software
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`for sensing movement within and selection of linear list of items in a menu),
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`PhotoMesa (2001 software for end users to browse personal photos), DateLens
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`(2002 software for end users to use their mobile devices to efficiently access their
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`calendar information), SlideBar (2005 linear sensor to control scrolling),
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`LaunchTile (2005 “home screen” software for mobile devices to allow users to
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`navigate apps in a zoomable environment), SpaceTree (2001 software for end users
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`to efficiently browse very large hierarchies), ICDL (as described above), and
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`StoryKit (a 2009 iPhone app for children to create stories).
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`10. Throughout the 1990s and 2000s, I worked on a range of “zoomable
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`user interfaces,” which are systems that support the multi-scale and spatial
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`organization of and magnification-based navigation among multiple documents or
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`visual objects. I built several different “ZUI” systems over the years, including
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`Pad++, Jazz and Piccolo. In those systems, I used a range of solutions to allow
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`users to control zooming through the information space. The most common
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`approach for systems with three button mice was to use the middle button for
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`zooming in and the right button for zooming out. The user would hold the button
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`down, and the system would smoothly animate zooming in or out – so that the user
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`U.S. Patent No. 8,812,993
`controlled how much the system zoomed based on the duration that the button was
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`pressed.1
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`11.
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`In 1995 and 1996, I supervised graduate student David Rogers and
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`other students in the development of a user interface approach that allowed a user
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`to “toss” an object across long distances on their screen with their mouse.
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`Motivated by increasingly large computer screens, we recognized a need to help
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`users move items long distances without necessarily having to drag the item that
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`entire distance manually. Instead, we calculated the speed and direction that the
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`user dragged an object with their mouse. When a user released the mouse button,
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`if the speed was greater than a threshold, our code calculated the path of where to
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`animate the object based on several factors including the speed and direction of the
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`mouse at the time of mouse button release. The figure below from a paper we
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`wrote in 1996 shows the path of a tossed object. This resulted in David Rogers’s
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`master’s thesis in 1995 and a paper that we submitted to the 1996 Conference on
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`
`
` Benjamin B. Bederson & James D. Hollan, Pad++: A Zooming Graphical
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`Interface for Exploring Alternate Interface Physics, UIST ’94 Proceedings of the
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`7th Annual ACM Symposium on User Interface Software and Technology 17
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`(1994), DOI: http://dx.doi.org/10.1145/192426.192435 (EX1018).
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`Human Factors in Computing Systems (CHI 1996)2.
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`Declaration of Dr. Benjamin B. Bederson
`U.S. Patent No. 8,812,993
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`
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`Exemplar Figure of Tossing3.
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`
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` David Rogers et al., Tossing Objects in a Desktop Environment, submitted to
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` 2
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`Conference on Human Factors in Computing Systems (1996) (EX1019).
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`3 David Rogers et al., Exemplar Figure of Tossing from Tossing Objects in a
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`Desktop Environment, submitted to Conference on Human Factors in Computing
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`Systems (1996) (EX1020).
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`In 1999 and 2000, I worked on a mechanism to address the challenge
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`12.
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`that users faced when selecting one item from a long menu. As I described in a
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`paper entitled “Fisheye Menus” that I published in the 2000 Proceedings of the
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`ACM Symposium on User Interface Software and Technology,4 existing
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`techniques typically involved lengthy and slow scrolling techniques. I created an
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`alternative solution that fit all of the elements onto a single screen thereby
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`completely eliminating the need to scroll. This approach used the concept of
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`“fisheye distortion” to shrink some of the elements, while keeping the elements
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`that are under the cursor to be full size so the user could easily see and select them.
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`This approach as depicted in the figure below and described further at EX1021,
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`was later used in a number of commercial products such as the Apple MacOS
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`Dock.
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` Benjamin B. Bederson, Fisheye Menus, UIST ’00 Proceedings of ACM
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` 4
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`Conference on User Interface Software and Technology 217 (2000), DOI:
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`10.1145/354401.317382 (EX1021).
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`U.S. Patent No. 8,812,993
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`EX1023 at Figure 2.
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`
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`13. Starting in 2000, I supervised graduate student Leslie Chipman who
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`was working on a general solution to improve the user experience of people
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`scrolling long documents on computers. Our solution relied on a passive haptic
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`physical linear input device we called the “Slidebar.” The Slidebar was designed
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`to sit on either side of the keyboard to be used with the non-dominant hand for
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`scanning and rough positioning, and then if the user wanted to switch to reading,
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`the dominant hand could be used for more accurate positioning. With a physical
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`range of motion of approximately two inches, the full range could be accessed by
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`moving just the fingers without moving the entire hand. This took advantage of
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`human proprioception¾the fact that people have excellent ability to know where
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`their body is¾and allowed the user to scroll long documents completely eyes-free.
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`They did not need to look at the device or the screen to, for example, move a
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`mouse pointer to a graphical scroll bar. Instead they could focus on their primary
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`task of reading. This work was published in 2004.5
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`14.
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`In April 2000, I visited Professors Wayne Westerman and John Elias
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`at the University of Delaware and gave a talk entitled “Zoomable User Interfaces
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`and Single Display Groupware.” This resulted in a collaboration with Professor
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`Westerman, graduate student Hilary Browne, and others where we used their
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`FingerWorks capacitive Multi-Touch Surface as the input device for a multi-touch
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`finger painting program for children. The project used this input device to support
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`a computer painting program that allowed children to paint with their fingers by
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`directly touching the sensing surface. In contrast to the mouse input more typically
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`used in this time period, this approach enabled us to create a more natural
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`interaction environment. This work, depicted in the figure below, was published in
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` Leslie E Chipman et al., SlideBar: Analysis of a Linear Input Device, 23
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`Behaviour & Info. Tech. 1 (2004), DOI: 10.1080/01449290310001638487
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`(EX1022).
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`a September 2000 technical report.6
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`
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`EX1023, Figure 1.
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`
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`15. Throughout the 2000’s, I worked on a range of interfaces for mobile
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`devices with a focus on interface design for touch interfaces, including those with
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`capacitive sensors. During this period, it became apparent that some positions on a
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`screen were easier to access than others, especially when used with a single hand.
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`To understand this issue, I led a range of studies that resulted in two papers
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`
`
` Hilary Browne et al., Designing a Collaborative Finger Painting Application for
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` 6
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`Children, HCIL-2000-17, CS-TR-4184, UMIACS-TR-2000-66 (Sept. 2000),
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`available at https://hcil.umd.edu/pub-perm-link/?id=2000-17 (EX1023).
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`published in 20067 and 20078. The following figure summarizes the results of one
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`of the studies, and shows that generally speaking, when using a single hand, the
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`center of the screens were easier for users to touch than the edges of the screen,
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`and that the corners of the screen were the hardest positions to touch.
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`
`
` Pekka Parhi, Amy K. Karlson, and Benjamin B. Bederson. 2006. Target size
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`study for one-handed thumb use on small touchscreen devices. In Proceedings of
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`the 8th Conference on Human-Computer Interaction with Mobile Devices and
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`Services (MobileHCI ’06). Association for Computing Machinery, New York, NY,
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`USA, 203–210. DOI:https://doi.org/10.1145/1152215.1152260 (EX1024).
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`8 Karlson, Amy & Bederson, Benjamin & Contreras-Vidal, José. (2008).
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`Understanding One-Handed Use of Mobile Devices. Handbook of Research on
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`User Interface Design and Evaluation for Mobile Technology. 86-101.
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`DOI:10.4018/978-1-59904-871-0.ch006 (EX1025).
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`Declaration of Dr. Benjamin B. Bederson
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`EX1025 at Table 2.
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`16. This work on touch screen mobile devices led to my creation of
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`Zumobi in 2006, where I was responsible for investigating new software platforms
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`and developing new user interface designs that provide efficient and engaging
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`interfaces to permit end users to access a wide range of content on mobile
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`platforms (including the iPhone and Android-based devices). For example, I
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`U.S. Patent No. 8,812,993
`designed and implemented software called “Ziibii,” a “river” of news for iPhone
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`that used a capacitive sensor for controlling linear movement through news;
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`software called “ZoomCanvas,” a zoomable user interface for several iPhone apps;
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`and iPhone apps including “Inside Xbox” for Microsoft and Snow Report for REI.
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`At the ICDL, I have since 2002 been the technical director responsible for the
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`design and implementation of the web site, www.childrenslibrary.org (originally at
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`www.icdlbooks.org). In particular, I have been closely involved in designing the
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`user interface as well as the software architecture for the web site since its
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`inception in 2002.
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`17. Beginning in the mid-1990s, I have been responsible for the design
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`and implementation of numerous other web sites in addition to the ICDL. For
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`example, I designed and built my own professional web site when I was an
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`Assistant Professor of Computer Science at the University of New Mexico in 1995
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`and have continued to design, write the code for, and update both that site (which I
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`moved to the UMD in 1998, currently at http://www.cs.umd.edu/~bederson/) as
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`well as numerous project web sites, such as Pad++,
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`http://www.cs.umd.edu/hcil/pad++/. I received the Janet Fabri Memorial Award
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`for Outstanding Doctoral Dissertation for my Ph.D. work in robotics and computer
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`vision. I have combined my hardware and software skills throughout my career in
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`HCI research, building various interactive electrical and mechanical systems that
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`U.S. Patent No. 8,812,993
`couple with software to provide an innovative user experience.
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`18. My work has been published extensively in more than 160 technical
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`publications, and I have given about 100 invited talks, including 9 keynote
`
`lectures. I have won a number of awards including the Brian Shackel Award for
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`“outstanding contribution with international impact in the field of HCI” in 2007,
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`and the Social Impact Award in 2010 from the Association for Computing
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`Machinery’s (“ACM”) Special Interest Group on Computer Human Interaction
`
`(“SIGCHI”). ACM is the primary international professional community of
`
`computer scientists, and SIGCHI is the primary international professional HCI
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`community. I have been honored by both professional organizations. I am an
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`“ACM Distinguished Scientist,” which “recognizes those ACM members with at
`
`least 15 years of professional experience and 5 years of continuous Professional
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`Membership who have achieved significant accomplishments or have made a
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`significant impact on the computing field.” I am a member of the “CHI
`
`Academy,” which is described as follows: “The CHI Academy is an honorary
`
`group of individuals who have made substantial contributions to the field of HCI.
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`These are the principal leaders of the field, whose efforts have shaped the
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`disciplines and/or industry, and led the research and/or innovation in human-
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`computer interaction.” The criteria for election to the CHI Academy are: (1)
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`cumulative contributions to the field; (2) impact on the field through development
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`U.S. Patent No. 8,812,993
`of new research directions and/or innovations; and (3) influence on the work of
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`others.
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`19.
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`I have appeared on radio shows numerous times to discuss issues
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`relating to user interface design and people’s use and frustration with common
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`technologies, web sites, and mobile devices. My work has been discussed and I
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`have been quoted by mainstream media around the world over 120 times, including
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`by the New York Times, the Wall Street Journal, the Washington Post, Newsweek,
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`the Seattle Post Intelligencer, the Independent, Le Monde, NPR’s All Things
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`Considered, New Scientist Magazine, and MIT’s Technology Review.
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`20.
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`I have designed, programmed, and publicly deployed dozens of user-
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`facing software products that have cumulatively had millions of users. My work is
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`cited by several major companies, including Amazon, Apple, Facebook, Google,
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`and Microsoft. I am a named inventor on 12 U.S. patents and 18 U.S. patent
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`applications. The patents are generally directed to user interfaces/experience.
`
`21.
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`I received a B.S. degree in Computer Science with a minor in
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`Electrical Engineering in 1986 from the Rensselaer Polytechnic Institute. I
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`received M.S. and Ph.D. degrees in Computer Science in 1989 and 1992, both
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`from New York University.
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`III.
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`INFORMATION CONSIDERED
`22.
`In preparing this declaration, I have considered the materials
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`EX1002
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`Declaration of Dr. Benjamin B. Bederson
`U.S. Patent No. 8,812,993
`discussed in this declaration, including, for example, the ’993 Patent, the
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`references cited by the ’993 Patent, the prosecution histories of the ’993 Patent and
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`the application from which it derives (including the references cited therein),
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`various background articles and materials referenced in this declaration, and the
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`prior art references identified in this declaration. In addition, my opinions are
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`further based on my education, training, experience, and knowledge in the relevant
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`field.
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`Description
`Exhibit No.
`Exhibit 1001 U.S. Patent No. 8,812,993 (“the ’993 patent”)
`Exhibit 1002 Declaration of Ben Bederson
`Exhibit 1003
`File History for U.S. Patent No. 8,812,993
`Exhibit 1004 Ben Bederson CV
`Exhibit 1005 Certified translation of JP Published Patent Application No.
`2002-55750 (“Hisatomi”), published February 20, 2002
`Exhibit 1006 Xiangshi Ren & Shinji Moriyama, “Improving Selection on Pen-
`Based Systems: A Study of Pen-Based Interaction for Selection
`Tasks,” ACM Transactions on Computer-Human Interaction,
`Vol. 7, No. 3, September 2000, pp. 384-416 (“Ren”)
`Exhibit 1007 U.S. Patent No. 5,422,656 to Allard et al. (“Allard-656”)
`Exhibit 1008 U.S. Patent No. 5,249,296 to Tanaka (“Tanaka”)
`Exhibit 1009 U.S. Patent No. 5,615,384 to Allard et al. (“Allard 384”)
`Exhibit 1010 U.S. Patent No. 5,537,608 to Beatty et al. (“Beatty”)
`Exhibit 1011 U.S. Patent No. 5,903,268 to Hirayama (“Hirayama”)
`Exhibit 1012 U.S. Patent No. 5,305,435 to Bronson (“Bronson”)
`Exhibit 1013 U.S. Patent No. 6,133,898 to Ludolph et al. (“Ludolph”)
`Exhibit 1014 Tammara T. A. Combs and Benjamin B. Bederson “Does
`zooming improve image browsing?” Proceedings of the Fourth
`ACM Conference on Digital Libraries (DL ’99), ACM, New
`York, NY, USA, (August 1999) 130-137
`Exhibit 1015 Dean Harris Rubine, “The Automatic Recognition of Gestures,”
`CMU-CS-91-202, December, 1991.
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`EX1002
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`Declaration of Dr. Benjamin B. Bederson
`U.S. Patent No. 8,812,993
`Exhibit 1016 U.S. Patent No. 6,710,791 to Kodama et al. (“Kodama”)
`Exhibit 1017
`IBM Simon Users Manual, 1994
`Exhibit 1018 Benjamin B. Bederson & James D. Hollan, Pad++: A Zooming
`Graphical Interface for Exploring Alternate Interface Physics,
`UIST ’94 Proceedings of the 7th Annual ACM Symposium on
`User Interface Software and Technology 17 (1994), DOI:
`http://dx.doi.org/10.1145/192426.192435
`Exhibit 1019 David Rogers et al., Tossing Objects in a Desktop Environment,
`submitted to Conference on Human Factors in Computing
`Systems (1996)
`Exhibit 1020 David Rogers et al., Exemplar Figure of Tossing from Tossing
`Objects in a Desktop Environment, submitted to Conference on
`Human Factors in Computing Systems (1996)
`Exhibit 1021 Benjamin B. Bederson, Fisheye Menus, UIST ’00 Proceedings of
`ACM Conference on User Interface Software and Technology
`217 (2000), DOI: 10.1145/354401.317382
`Exhibit 1022 Leslie E Chipman et al., SlideBar: Analysis of a Linear Input
`Device, 23 Behaviour & Info. Tech. 1 (2004), DOI:
`10.1080/01449290310001638487
`Exhibit 1023 Hilary Browne et al., Designing a Collaborative Finger Painting
`Application for Children, HCIL-2000-17, CS-TR-4184,
`UMIACS-TR-2000-66 (Sept. 2000), available at
`https://hcil.umd.edu/pub-perm-link/?id=2000-17
`Pekka Parhi, Amy K. Karlson, and Benjamin B. Bederson. 2006.
`Target size study for one-handed thumb use on small touchscreen
`devices. In Proceedings of the 8th Conference on Human-
`Computer Interaction with Mobile Devices and Services
`(MobileHCI ’06). Association for Computing Machinery, New
`York, NY, USA, 203–210.
`DOI:https://doi.org/10.1145/1152215.1152260
`Exhibit 1025 Karlson, Amy & Bederson, Benjamin & Contreras-Vidal, José.
`(2008). Understanding One-Handed Use of Mobile Devices.
`Handbook of Research on User Interface Design and Evaluation
`for Mobile Technology. 86-101. DOI:10.4018/978-1-59904-871-
`0.ch006
`Exhibit 1026 Apple Newton Message Pad Handbook (1993)
`Exhibit 1027 Handbook for Palm m500 Series Handhelds (1998)
`Exhibit 1028 HP Jornada 520 Series Pocket PC User Guide (2001)
`Exhibit 1029 U.S. Patent No. 5,821,930 to Hansen (“Hansen”)
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`Exhibit 1024
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`EX1002
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`Declaration of Dr. Benjamin B. Bederson
`U.S. Patent No. 8,812,993
`Exhibit 1030 U.S. Patent Applicationto Publication No. 2005/0024341
`(“Gillespie”)
`Exhibit 1031 Declaration of Mr. Jacob Munford
`Exhibit 1032 Norman, D. A. (1988). The psychology of everyday things.
`BasicBooks. IBSN: 0-465-06709-3.
`Exhibit 1033 U.S. Publication No. 2001/0043189 to Brisebois (“Brisebois”)
`
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`IV. RELEVANT LEGAL STANDARDS
`23.
`I am not an attorney and offer no legal opinions. For the purposes of
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`this Declaration, I have been informed about certain aspects of the law that are
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`relevant to my analysis, as summarized below.
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`A. Claim Interpretation
`24.
`I have been informed and understand that in an IPR proceeding,
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`claims are to be interpreted according to the Phillips claim construction standard. I
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`have been informed and understand that claim construction is a matter of law and
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`that the final claim constructions for this proceeding will be determined by the
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`Patent Trial and Appeal Board (“PTAB”).
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`B.
`25.
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`Perspective of One of Ordinary Skill in the Art
`I have been informed and understand that a patent is to be understood
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`from the perspective of a hypothetical “person of ordinary skill in the art”
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`(“POSA”). Such an individual is considered to possess normal skills and
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`knowledge in a particular technical field (as opposed to being a genius). I
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`understand that in considering what the claims of a pate