SAMSUNG ELECTRONICS CO. LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners
`
`v.
`
`GUI GLOBAL PRODUCTS, LTD.,
`Patent Owner
`
`____________________________________________________
`
`IPR2021-00335, -00336, -00337, -00338
`
`Presentation of Patent Owner GUI Global Products, Ltd.
`
`Hearing Date: April 12, 2022
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`1
`
`
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners
`
`v.
`
`GUI GLOBAL PRODUCTS, LTD.,
`Patent Owner
`
`____________________________________________________
`
`IPR2021-00335, -00336, -00337, -00338
`
`Presentation of Patent Owner GUI Global Products, Ltd.
`
`Hearing Date: April 12, 2022
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`1
`
`
`
`Petitioner’s Figure A, which is adapted from Kim’s watch-type
`embodiment depicted in Fig. 15A , forms the basis for Petitioner’s
`allegations of unpatentability.
`
`Petition, 20-21
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`2
`
`
`
`Kim Does Not Disclose Petitioner’s Fictional Figure A Device
`(Claim 1 of ‘320, ‘077, ‘021 and ‘020 Patents)
`
`Kim teaches coupling sub-device 300 to and atop
`the second body of the watch-type device. ‘320
`POR, 7; EX2004, ¶48.
`
`This arrangement:
` Allows the watch-type device to operate as a dual-display device. EX1010, [0256]; ‘320 POR, 7; EX2004, ¶48
` Allows the cover of the watch-type device to properly open and close via hinge 100d. ‘320 POR, 7; EX2004, ¶48
`Provides an attractive consumer electronic device in terms of its size, form factor, and appearance. ‘320 POR, 7;
`
`EX2004, ¶48
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`3
`
`
`
`Kim Does Not Disclose Petitioner’s Fictional Figure A Device
`
`Kim does not teach mixing physical aspects of separate
`folder-type and watch-type embodiments. The
`“embodiments” referred to in the second (and third)
`sentence of ¶179 are merely the “embodiments for a control
`method” noted in the prior sentence.
`
`EX1010, [0179]
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`4
`
`
`
`A POSITA Would Not be Motivated to Create a Non-Functional, Deeply Flawed and Unsuitable Figure A Device
`
`Petitioner’s expert acknowledges that, when designing a wearable
`device such as a watch-type device, a POSITA would have
`considered such things as its size and weight, its form factor
`(including its shape), the miniaturization of its electronics, and its
`overall appearance. EX2002, 15:11–16:19; 18:13–21:2; 33:18–35:5.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`EX2002, 15:11–16:19
`
`5
`
`
`
`A POSITA Would Not be Motivated to Create a Non-Functional, Deeply Flawed and Unsuitable Figure A Device
`
`Petitioner’s expert acknowledges that, when designing a wearable
`device such as a watch-type device, a POSITA would have
`considered such things as its size and weight, its form factor
`(including its shape), the miniaturization of its electronics, and its
`overall appearance. EX2002, 15:11–16:19; 18:13–21:2; 33:18–
`35:5.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`6
`
`
`
`A POSITA Would Not be Motivated to Create a Non-Functional, Deeply Flawed and Unsuitable Figure A Device
`
`Kim’s watch-type device in Fig. 15C shows the use of an edge holder or slot with a
`guide groove on the second body of the watch-type main device, with a sub-device
`300 being pushed or slotted (or bent to be so pushed or slotted) into that guide
`groove so as to be coupled to the second body. EX1010, [0262].
`
`Only by having the edge holder or slot on the outside (or top side) of the second
`body would one be able to push the sub-device into the guide groove. EX2004, ¶45.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`7
`
`
`
`A POSITA Would Not be Motivated to Create a Non-Functional, Deeply Flawed and Unsuitable Figure A Device
`
`Kim’s watch-type device includes a hinge located such that
`the second body can be connected to one side of the first
`body. ‘320 POR, 14; EX2004, ¶58; EX1010, [0256]
`Petitioner’s Figure A does not permit the cover 100b
`
`to close with sub-device 300 present, because hinge
`100d is positioned at the side of the first body 100a.
`POR 9, 37; EX2004, ¶¶ 51, 72.
` Closing the cover would dislodge sub-device 300
`from coupling members 510, or result in damage to
`hinge 100d. ‘320 POR, 37; EX2004, ¶72
`Such a device would be unattractive, unduly large,
`and ill-suited for its purpose. ‘320 POR, 8; EX2004,
`¶48.
`
`
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`8
`
`
`
`A POSITA Would Not be Motivated to Create a Non-Functional, Deeply Flawed and Unsuitable Figure A Device
`
`Using a sandwiched sub-device would impede the view of the
`display of the first body 100a via the TOLED display of folded
`second body 100b. ‘320 POR, 24-27; EX2004, ¶¶59-62.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`9
`
`
`
`A POSITA Would Not be Motivated to Create a Non-Functional, Deeply Flawed and Unsuitable Figure A Device
`
`Sandwiching sub-device 300 as in Petitioner’s Figure A leads to problems with displaying
`information. POR 29; EX2004, ¶65. If a sub-device 300 was inserted between the first and
`second bodies (100a and 100b), the information displayed on sub-device 300, looking through
`the transparent display of the cover, would end up being displayed upside down to a viewer
`when the cover 100b was closed over the watch (assuming that it could be closed at all). POR
`29; EX2004, ¶65.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`10
`
`
`
`A POSITA Would Not be Motivated to Create a Non-Functional, Deeply Flawed and Unsuitable Figure A Device
`
`Petitioner’s Figure A embodiment would be exceedingly
`difficult for a wearer to use or operate. ‘320 POR, 30;
`EX2004, ¶66.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`11
`
`
`
`A POSITA Would Not be Motivated to Create a Non-Functional, Deeply Flawed and Unsuitable Figure A Device
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`12
`
`
`
`The Hinge Arrangement of Figure 11B is Not a Ground Advanced in the
`Petition and is Not Compatible with Figure 15A (or Petitioner’s Figure A)
`
`Petitioner’s Figure A proposes an unmodified version of Kim’s Fig.
`15A, with the hinge 100d located on a side of the first body 100a.
`
`The hinge arrangement of Figure 11B, suggested in the Reply, is not
`a ground advanced in the Petition and is not compatible with Figure
`15A (or Petitioner’s Figure A) because Kim requires that the hinge
`in Figure 15A be “located such that the second body can be
`connected to one side of the first body,” whereas in Figure 11B “the
`second body 100b is connected on top of the first body 100a.” ‘320
`POR, 14.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`13
`
`
`
`The Hinge Arrangement of Figure 11B is Not a Ground Advanced in the
`Petition and is Not Compatible with Figure 15A (or Petitioner’s Figure A)
`
`Nothing in Kim suggests the Reply’s belated argument relocating the hinge
`so that the second body 100b is connected on top of the first body 100a.
`‘320 POR, 14; EX2004, ¶58.
`
`Making such a change would:
` result in the first and second bodies not properly closing when the
`third body 300 was not present. ‘320 POR, 14; EX2004, ¶58.
` ruin the device’s esthetic appearance; and
` likely allow foreign materials to intrude within the resultant gap
`between the cover 100b and the first body 100a. ‘320 POR, 15;
`EX2004, ¶58.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`14
`
`
`
`The Hinge Arrangement of Figure 11B is Not a Ground Advanced in the
`Petition and is Not Compatible with Figure 15A (or Petitioner’s Figure A)
`
`Modifying hinge 100d leaves a gap, impairing
`the see-through capability of the watch-type
`device. ‘320 POR, 28-29; EX2004, ¶63-64
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`15
`
`
`
`Any Relevant Teachings for the Dual-Display Watch-Type Embodiment Would Have Been Derived from Kim’s Fig. 5
`
`Kim’s guidance concerning dual-display embodiments is in Fig. 5. ‘320
`POR, 24-27; EX2004, ¶¶59-62; EX1010, [0159].
`
`In these arrangements, when a touch on the top display is detected, a
`controller enables an image from a list displayed on the bottom
`display to be selected. ‘320 POR, 25; EX1010 at [0160]-[0164];
`EX2004, ¶60.
`
`Such an operation would not be possible if a sub-device 300 were inserted
`between second body 100b and first body 100a of the watch-type device, as
`depicted in Petitioner’s Figure A. ‘320 POR, 26; EX2004, ¶61.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`16
`
`
`
`Kim’s Fig. 11B and 11E embodiments have a “base” keyboard, whereas
`Kim’s watch-type device depicted in Figs. 15A, 15B and in Petitioner’s
`Figure A employs dual displays. ‘320 POR, 14; EX2004, ¶54.
`
`Unlike the Fig. 15A, 15B watch-type device, where both first and
`second bodies 100a and 100b employ displays--and a wearer may look
`through the TOLED cover 100b to see the underlying display on 100a--
`in the Fig. 11B and 11E folder-type device, no such look-through
`capacity need be accommodated. ‘320 POR, 13; EX2004, ¶54.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`17
`
`
`
`Kim Does Not Disclose or Suggest “When Coupled, the First Case Functions to Protect the Second Case”
`(claim 1 of ‘320, ‘077 and ‘021). Nor Does Kim Disclose or Suggest
`“When Coupled, the Second Case Functions to Protect the First Case” (claim 1 of ‘020)
`
`Petitioner’s Figure A does not permit the cover 100b to
`close with sub-device 300 present, because hinge 100d
`is positioned at the side of the first body 100a. Thus, no
`“protection” of the case of sub device 300 would be
`afforded. ‘320 POR, 37; EX2004, ¶72.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`18
`
`
`
`Kim Does Not Disclose or Suggest “When Coupled, the First Case Functions to Protect the Second Case”
`(claim 1 of ‘320, ‘077 and ‘021). Nor Does Kim Disclose or Suggest
`“When Coupled, the Second Case Functions to Protect the First Case” (claim 1 of ‘020)
`
`As noted above – for Kim’s arrangement in which sub-device 300 is coupled to
`the watch-type mobile device in a state that the first and second bodies are
`coupled, Kim positions the sub-device 300 on the outside (or top side) of the
`second body, as illustrated by Kim’s Fig. 15B. ‘320 POR, 35.
`
`In this arrangement, the case of the watch-type main device does not function
`to protect the case of the sub-device 300. Instead, it is the case of the sub-
`device 300 that overlays and perhaps “protects” the case of the watch-type
`main device.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`19
`
`
`
`Petitioner Has Not Shown that Kim Discloses a “Switching Device”
`(Claim 1 of ‘320, ‘077, ‘021 and ‘020 Patents)
`
`Petitioner’s argument on this issue is as that, “main device 100 may automatically change its operation mode
`or an operation mode of the sub-device.” E.g., ‘320 Pet., 27.
`
`Petitioner merely assumes that effecting an unspecified “change” to the state and/or operation mode of sub-
`device 300 must equate with the main device being a “switching device.”
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`20
`
`
`
`Kim Does Not Render Obvious an Electronic Device with Both Magnets and Raised Shapes Configured to
`Correspond to Complementary Recessed Areas on a Switching Device (Claim 1 of ‘320, ‘077, ‘021 and ‘020 Patents)
`
`It would not have been obvious to a POSITA to use both magnets and hooks/recesses to couple the
`sub-device to the main device. ‘320 POR, 43-47; EX2004, ¶¶81-89. The weaker of the two
`closure methods would be superfluous. ‘320 POR, 44; EX2004, ¶¶83-84.
`
`None of Bergin, Kim or Koh discloses (or suggests) an embodiment with both magnets and hooks.
`
`With Petitioner’s Figure A device, when pressing the sub-device of Figure A against the cover while
`attempting to release the hook out of a recess, the torque exerted on the hinge could cause the hinge
`to break. ‘320 POR, 45; EX2004, ¶86.
`
`With Petitioner’s Figure A device, the magnetic coupling would work against a pressed hook release.
`‘320 POR, 45; EX2004, ¶86.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`21
`
`
`
`Kim Does Not Render Obvious an Electronic Device with Both Magnets and Raised Shapes Configured to
`Correspond to Complementary Recessed Areas on a Switching Device (Claim 1 of ‘320, ‘077, ‘021 and ‘020 Patents)
`
`With Petitioner’s Figure A device, one wrist would be needed to
`wear the watch, and only the user’s other hand would be
`available to push a hook and release it. However, two hands
`would be needed. ‘320 POR, 46; EX2004, ¶87.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`22
`
`
`
`Petitioner Has Not Shown that Kim Discloses or Suggests a Portable Switching Device “Configured to
`Activate, Deactivate, or Send into Hibernation” (Claim 1 of ‘320, ‘077, ‘021 and ‘020 Patents)
`
`Petitioner’s contention that Kim’s disclosure for ‘automatic controlling of a terminal operation (menu display)’ by a ‘bar-type mobile
`terminal,’ is ‘equally applicable’ to watch-type device” is unwarranted. ‘320 POR, 48. The constraint of being wrist mounted means
`that one holds up a watch in a single (portrait) orientation for viewing. ‘320 POR, 48.
`
`Petitioner misapprehends that the display on overlaid sub-device 300 is being impacted by the coupling of device and sub-device shown
`in Figs. 17A-B. ‘320 POR, 48. Instead, under the heading “Automatic Controlling of Terminal Operation,” Kim discloses in Figs. 17A-
`17B the view of a main device menu as seen through a transparent sub-device. ‘320 POR, 48.
`Even if Petitioner’s unwarranted inference was correct that the sub-device display is being shown on Figs. 17A-17B, the only
`
`disclosure by Kim is that the coupling impacts the orientation of the menu display. ‘320 POR, 48; EX1010, ¶¶273-275.
`
`A POSITA would have no motivation to import a vertical/horizontal menu shift from a Kim bar-type device to a watch-type device viewed in a
`consistent orientation on a wrist. ‘320 POR, 49.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`23
`
`
`
`Petitioner Has Not Shown that Kim Discloses or Suggests a Portable Switching Device “Configured to Activate,
`Deactivate, or Send into Hibernation”
`
`As to the ‘320, ‘077 and ‘021, Petitioner fails to explain how the
`main device being turned on or off constitutes activating,
`deactivating or hibernating the sub-device. E.g., ‘320 Petition, p. 42:
`
`Petitioner refers to Kim’s text describing a bar-type mobile main device, not a watch-type main device. EX1010, ¶¶316-319, 417-418, and
`Figs. 27, 42. A POSITA would be motivated for Kim’s watch-type device to be kept active irrespective of its interactions with the disclosed
`sub-device. ‘320 POR, 49; see, e.g., EX1010, ¶259.
`
`As to the ‘320, ‘077 and ‘021, to the extent that Kim’s disclosures for bar-type mobile devices were erroneously deemed applicable to watch-
`type devices, Kim discloses that sub-devices 300 remain active when de-coupled from the main device. ‘320 POR, 50; see, e.g., EX1010,
`¶¶187, 230, 259.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`24
`
`
`
`Kim Does Not Disclose the Electronic Device Plays or Pauses a Remote Device (‘320, ‘077 Claim 1; ‘021, ‘020 Claim 19)
`
`The Petition did not argue this limitation would have been obvious. E.g., ‘320 POR, 50 (see Pet., 44-45):
`
`What the Petition relied upon for this limitation being met had nothing to do with the watch-type
`embodiment from Figs. 15A-D that Petitioner relies upon for its Figure A device. ‘320 POR, 50-51. See
`Pet. 44-55. At best, Kim discloses this functionality being accomplished with different bar-type
`devices depicted in Figs. 29 and 31. ‘320 POR, 51.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`25
`
`
`
`Kim Does Not Render Obvious that the “Lid is Recessed to Configure to the Electronic Device ”
`(‘320, ‘077 Claim 1; ‘021, ‘020 Claim 7)
`
`The Petition alleges that it would have been obvious to incorporate a recess in the “in a manner similar
`to that disclosed in Kim’s Figure 10A.” Pet., 47.
`
`However, with such a Fig. 10A recess, it would be very difficult to decouple the sub-device from the
`main device using the user’s one free hand. ‘320 POR, 52; EX 2004, ¶92:
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`26
`
`
`
`Kim Does Not Render Obvious the Lid Being “Configured to Employ the Second Magnet to Secure the Lid in a Closed
`Position by Magnetically Coupling to the First Case,” (‘320 claim 5), Nor Does it Disclose the Lid Being “Configured
`to Employ the Second Magnet to Secure the Lid in a Closed Position” (‘077 claim 5; ‘021, ‘020 claim 9)
`
`The Petition theory is that a POSITA would apply the teachings of a Fig. 11E
`device to achieve these limitations. E.g., ‘320 Petition, p. 52:
`
`However, neither this device --
`
`-- nor any anything else in Kim teaches or suggests using magnets to
`connect main devices. ‘320 POR, 55. The magnets in Figure 11E are
`used to connect the sub-device to the main device, and the
`sandwiched sub-device would impede the use of a main device
`magnet to secure the lid in a closed position. ‘320 POR, 55.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`27
`
`
`
`Kim Does Not Render Obvious ‘320 Claim 5, ‘077 Claim 5, or ‘021 claim 9
`
`These limitations are not met by Petitioner’s Figure A device
`
`This claim requires “a portable switching device coupled to a
`portable electronic device…when coupled, the first case
`functions to protect the second case” (independent claim
`1)…“wherein the lid is configured to employ the second magnet
`to secure the lid in a closed position …” (dependent claims). See
`‘320 POR, 55-56, Reply 20-21.
`
`These claims are only met when there is all three of (1) coupling,
`(2) the first case functioning to protect the second case, and (3) a
`lid configured to employ the second magnet to secure the lid in a
`closed position… E.g., EX1001, Claims 1, 5; ‘320 POR, 55-56.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`28
`
`
`
`A POSITA Would Not Have Been Motivated to Combine Kim and Koh as Asserted by Petitioner
`(‘320, ‘077 Claim 11; ‘021, ‘020 Claim 10)
`
`Koh’s provides a wearer easy access to a wireless headset. ‘320 POR, 61; EX2004, ¶107. In
`Koh, “T[he display unit [ ] of the wireless headset 100 displays the current time…. and used
`as a wristwatch.” ‘320 POR, 62; EX2004, ¶107; EX1012, ¶47. Koh’s display unit 130 is also
`used for displaying the on/off state of the earpiece as well as its remaining battery capacity.
`‘320 POR, 62; EX2004, ¶108; EX1012, ¶33.
`
`Petitioner’s arrangement sacrifices modularity, defeats Kim’s look through functionality, and
`eliminates the desired dual-display capability of the watch-type device advocated by Kim.
`‘320 POR, 58; EX2004, ¶103. Further, the headset(s) would be exceedingly difficult to use.
`‘320 POR, 63; EX2004, ¶108.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`29
`
`
`
`A POSITA Would Not Have Been Motivated to Combine Kim and Koh as Asserted by Petitioner
`(‘320, ‘077 Claim 11; ‘021, ‘020 Claim 10)
`
`Adding to the difficulty of Petitioner’s proposed configuration, the headsets would be magnetically coupled inside the cover, and
`decoupling would have to be done using only one hand, because one hand would be occupied by wearing the watch. ‘320 POR, 64;
`EX2004, ¶110, 111.
`
`Were the wearer to attempt to decouple the headset from cover 100b, he/she would have to contend with a coupling protrusion with
`a hinge and spring as well as a coupling magnet. ‘320 POR, 65; EX2004, ¶112. See Pet., 62; and see EX1012 at Figs. 2B and 4A,
`and ¶¶39, 42, 47-48. The result would be that, instead of a headset being removed successfully, cover 100b would pull shut. ‘320
`POR, 65; EX2004, ¶112.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`30
`
`
`
`A POSITA Would Not Have Been Motivated to Combine Kim and Koh as Asserted by Petitioner
`(‘320, ‘077 Claim 11; ‘021, ‘020 Claim 10)
`
`The arrangement at right in which the wireless earphones of Koh would be located on the top-side (or outside) of the second
`body of Kim’s watch-type embodiment, is the one that a POSITA would have more likely envisioned, rather than the one
`proposed by Petitioner, because it is the one that is at least more consistent with the teachings of both Kim and Koh. POR,
`60; EX2004, ¶105.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`31
`
`
`
`The Kim-Koh Combination Does Not Disclose (or Suggest) that the “Switching Device” is “Configured to Activate,
`Deactivate, or Send into Hibernation” the Portable Electronic Device ” (Claim 1 of ‘320, ‘077, ‘021 and ‘020 patents)
`
`Petitioners’ rationales for this being obvious are specific to the Kim’s disclosure of main and sub-devices with
`display screens. None of Petitioner’s obviousness rationales apply to the Kim-Koh combination comprising
`embedded sub-devices. See Petition, 57-66.
`
`Koh teaches that the state of Koh’s headset is meant to be seen while coupled to electronic storage until 200 one
`knows the “state” of the headset. ‘320 POR, 67; EX1012, ¶33.
`
`When Koh’s headset is coupled to the storage unit, the headset microphone is electrically connected to the
`external microphone of the electronic device storage unit, so that the headset still works while coupled to the
`unit. ‘320 POR, 67; EX1012, ¶21.
`
`A POSITA borrowing from Koh would desire for headset to remain active so its state could be known, so it
`could make receive calls, and so the headset could still be used while coupled. ‘320 POR, 67.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`32
`
`
`
`The Alleged Kim-Koh Combination Does Not Disclose That “the Electronic Device Pauses or Plays a Remote Device” (‘320 claim 1)
`Nor Does It Disclose That the “Electronic Device Plays, Pauses and/or Changes the Volume of a Remote Device” (‘077 claim 1)
`
`The Petition did not argue that this would have been obvious. Pet., 44-45.
`
`What Petitioner mistakenly relies upon for this limitation being met is Kim’s
`disclosure, ¶¶342-344 and Fig. 31. Pet., 44-45. However, the embodiment disclosed,
`¶¶342-344 has nothing to do with the watch-type embodiment that Petitioner relies
`upon for its Fig. A.
`
`Kim does not disclose that the watch-type device depicted in Figures 15A-D meets
`the “the electronic device pauses or plays a remote device” limitation of claim 1. At
`best, Kim discloses this functionality being accomplished with the bar-type devices
`depicted in Figs. 29 and 31.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`33
`
`
`
`A POSITA Would Not Have Been Motivated to Combine Kim and Lee to Use a Hall Effect Sensor to Actuate
`an Electronic Circuit (‘320, ‘077 claim 9; ‘021, ‘020 claims 16, 17)
`
`A POSITA would not have been motivated to combine the teachings of Kim and Lee (EX1013), specifically to
`use a Hall effect sensor (as taught by Lee) in a watch-type device (as taught by Kim).
`
`The bodies in Lee are always hingedly coupled in a bi-fold configuration. ‘320 POR, 71; EX2004, ¶116. Thus,
`Lee does not provide any teaching or motivation for using a Hall effect sensor and a magnet to detect the
`coupling status of two bodies.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`34
`
`
`
`Kim and Jiang Do Not Render Obvious the Switching Device Additionally Comprising a Laser
`(‘021, ‘020 claim 18)
`
`A POSITA would not have found it obvious to modify Kim by including Jiang’s VCSEL light source for IrDA
`communication. ‘021 POR, 74; 021 EX2004, ¶121.
`
`Kim does not teach having a short-range communications module for its watch-type embodiment. With a watch
`already on the hand, an IrDA remote control would be unnecessary and superfluous. ‘021 POR, 74; ‘021 EX2004,
`¶121.
`
`Line-of-site communication with a watch-type device is not feasible because the hand would invariably be in
`motion. ‘021 POR, 74; ‘021 EX2004, ¶121.
`
`Ex. 2006
`
`Patent Owner’s Demonstratives – Not Evidence
`
`35
`
`
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