`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`____________________________________________________
`
`SAMSUNG ELECTRONICS CO. LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners,
`
`v.
`
`GUI GLOBAL PRODUCTS, LTD.,
`Patent Owner.
`
`____________________________________________________
`
`Case IPR2021-00335
`Patent 10,259,020 B2
`____________________________________________________
`
`
`DECLARATION OF MARK N. HORENSTEIN, PH.D.
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`Samsung v. GUI Global Products
`IPR2021-00335 GUI Ex. 2004
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`TABLE OF CONTENTS
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`INTRODUCTION AND QUALIFICATION ....................................... 1
`I.
`ASSIGNMENT ..................................................................................... 5
`II.
`Legal Principles ..................................................................................... 6
`A.
`Level of Ordinary Skill in the Art .......................................................10
`B.
`C. Methodology .......................................................................................11
`D.
`Claim Construction..............................................................................11
`III. OVERVIEW OF THE ’020 PATENT ................................................12
`IV. ANALYSIS OF SAMSUNG’S CHALLENGES ...............................18
`A. Kim Does Not Teach or Suggest Samsung’s Fig. A
`Embodiment ........................................................................................18
`Overview of Kim (U.S. Patent Application US 2010/0227642 A1) ...18
`Kim Does Not Teach or Suggest Samsung’s Figure A Embodiment for
`Multiple Reasons .................................................................................29
`Kim’s Fig. 5 Shows How a Dual Display Device Should Be Fashioned
` .............................................................................................................40
`A Gap Causes More Than Just Esthetic Problems. .............................43
`Sandwiching Sub-Device 300 as in Samsung’s Figure A
`Leads to Problems with Displaying Information ................................45
`Samsung’s Proposed Figure A Embodiment Presents Too Many
`Operating Issues That Would Prevent a POSITA From Adoption .....46
`The Challenged Claims Are Not Unpatentable in View of
`Kim ......................................................................................................49
`Kim does not teach or suggest “when coupled, the second
`case functions to protect the first case.” ..............................................49
`
`B.
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`1.
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`IPR2021-00335 GUI Ex. 2004
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`1.
`2.
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`3.
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`4.
`5.
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`6.
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`2.
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`3.
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`4.
`5.
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`C.
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`D.
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`1.
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`2.
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`3.
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`D.
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`1.
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`2.
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`F.
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`Kim does not teach or suggest “a first magnet is disposed within the
`switching device.” ...............................................................................54
`Kim does not teach or suggest “the electronic device comprises at least
`one element selected from the group consisting of beveled edges,
`ridges, recessed areas, grooves, slots, indented shapes, bumps, raised
`shapes, and combinations thereof; configured to correspond to
`complimentary surface elements on the switching device.” ...............59
`Kim combined with Koh does not render claim 1 obvious.................61
`As Required by Claim 7, Kim does not teach or suggest the “Lid is
`Recessed to Configure to the switching Device” ................................64
`Claim 9 and its Dependent Claims are Not Unpatentable in
`View of Kim ........................................................................................67
`Claim 10 is Not Unpatentable in View of the Combined
`Teachings of Kim and Koh. ................................................................70
`A POSITA Would Not Have Been Motivated to Combine Kim and
`Koh. .....................................................................................................70
`The Combination of Kim and Koh Does Not Suggest “When Coupled,
`the Second Case Functions to Protect the First Case” ........................72
`Dr. Kaiei Fails to Explain How Koh’s Earpiece is a “Switching Device”
`or How it “Activates, Deactivates, or Hibernates” Koh’s Storage
`Device Being Imported into the Kim-Koh Combination. ...................79
` Claim 16 is Not Unpatentable in View of the Combined
`Teachings of Kim and Lee ..................................................................80
`A POSITA Would Not Have Been Motivated to Combine Kim and Lee
` .............................................................................................................80
`The Combination of Kim and Lee Does Not Suggest a Magnet
`“Employed in Actuating the Electronic Circuit.” ...............................81
`Claim 17 is Not Unpatentable in View of the Combined
`Teachings of Kim and Lee ..................................................................82
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`Samsung v. GUI Global Products
`IPR2021-00335 GUI Ex. 2004
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`G.
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`Claim 18 is Not Unpatentable in View of the Combined
`Teachings of Kim and Jiang ................................................................83
`V. AMENDMENTS AND MODIFICATIONS ......................................84
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`Samsung v. GUI Global Products
`IPR2021-00335 GUI Ex. 2004
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`I.
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`INTRODUCTION AND QUALIFICATION
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` 1. My name is Mark N. Horenstein. I have been retained by counsel for GUI
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`Global Products, Ltd. (“Gwee” or “Patent Owner”) as a technical expert in this
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`case. I have been asked by counsel for the Patent Owner to provide my opinions
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`with respect to the petition by Samsung Electronics Co. Ltd. and Samsung
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`Electronics America, Inc. (collectively “Samsung” or “Petitioner”) in Inter Partes
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`Review 2021-00338 concerning U.S. Patent No. 10,259,020 (“the ‘020 Patent”). In
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`particular, I have been asked to review and comment upon the opinions in Ex.
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`1002, the “Declaration of Dr. Sayfe Kiaei,” dated December 29, 2020 (“Kiaei
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`Declaration” or “Kiaei”).
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` 2.
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`I am currently Professor Emeritus of Electrical Engineering in the
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`Department of Electrical and Computer Engineering at Boston University. From
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`1979 – 2020, I was a faculty member in that department, holding the rank of Full
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`Professor from 2000 to 2020. I have held various other positions at Boston
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`University, including the Associate Dean for Graduate Programs and Research for
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`the College of Engineering (1999-2007), Associate Chair for Undergraduate
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`Programs for the ECE Department (1990-1998 and 2012-2015), and appointments
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`at the ranks of Associate Professor (1985-2000) and Assistant Professor (1979-
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`1985).
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`IPR2021-00335, GUI Ex. 2004, Page 1
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` 3.
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`I have a Ph.D. in Electrical Engineering from the Massachusetts Institute
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`of Technology (MIT), which I earned in 1978 while working in the Electric Power
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`Systems Engineering Laboratory. I also hold an M.S. degree in Electrical
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`Engineering from the University of California at Berkeley (1975), and an B.S.
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`degree in Electrical Engineering from MIT (1973).
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` 4.
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`I am a Life Fellow of the Institute of Electrical and Electronic Engineers
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`(IEEE) and have been a Registered Professional Engineer (Electrical) in the
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`Commonwealth of Massachusetts. I hold certification from the National
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`Association of Radio and Telecommunications Engineers.
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` 5.
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`I am the author of two textbooks: Microelectronic Circuits and Devices,
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`2nd Ed. (Prentice-Hall 1996) and Design Concepts for Engineers, 5th Ed. (Pearson
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`Education, 2016). I have authored book chapters in two reference books related to
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`applied electromagnetics. I have authored or co-authored over 70 journal articles
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`on a variety of topics in my fields of expertise, and approximately 125 conference
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`papers. I have advised various Ph.D. students performing research in my fields of
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`expertise; these students have gone on to hold positions in industry and academia.
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` 6. My course teaching repertoire over the past 37 years has encompassed
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`about ten different courses, each of which I have taught numerous times to over
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`4000 undergraduate and graduate students. The subject matter of these courses has
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`included circuits, analog and digital electronics, power electronics, electro-
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`IPR2021-00335, GUI Ex. 2004, Page 2
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`magnetics, robotics, and engineering design. I have been named “Teacher of the
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`Year” in Engineering at Boston University four times.
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` 7.
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`I am a named inventor on five U.S. patents. I have also provided technical
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`expertise in the design and analysis of electrical and electronic products, integrated
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`circuits, power supplies, DC/DC converters, and electromagnetic devices.
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` 8.
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`I have extensive experience in the design, analysis, and testing of
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`electrical power products, including DC/DC, AC/DC, and DC/AC converters (at
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`both fixed and modulated outputs), microcontroller-based systems, and linear
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`power supplies of all types. In support of my research in deformable mirror
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`systems, for example, I designed two different analog-multiplexed, high-voltage
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`storage arrays. Similarly, as part of my work in developing self-cleaning solar
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`panels, I have designed switching power supplies that produce low-frequency, 3-
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`phase, 1-kV outputs which in turn are powered by low-voltage DC/DC power
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`converters. As part of my work overall in applied electromagnetics, I have
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`designed DC power controllers for thermal management systems, power amplifier
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`circuits, and analog amplifiers. I also have designed and used transformers of all
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`types, including ferromagnetic, ferrite, and air-core varieties.
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` 9. At Boston University, I was in charge of and taught our department’s
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`course in power electronics, which I developed from the ground up over a period
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`of eight years. In support of this activity, I designed circuits for laboratory
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`experiments in power electronics, including buck and boost converters and
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`controllers, H-bridge DC/AC switching converters, and DC-AC interface circuitry
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`for connecting solar energy systems to the AC power grid.
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` 10. My curriculum vitae (“CV”), which includes a summary of my
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`background, experience, publications, and expert-witness experience, is being
`
`provided at Exhibit 2005 to Gwee’s Response.
`
` 11. I am an engineer by training and profession. The opinions I express in this
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`report involve the application of my engineering knowledge, expertise, and
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`experience to invalidity issues related to the ‘020 Patent. The opinions contained
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`in this report are based on the documents I have reviewed (including Samsung’s
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`Petition and the Exhibits thereto), my experience and background, my knowledge,
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`and my professional judgment.
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` 12. My opinions have also been guided by my appreciation of the level of
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`skill of a person having ordinary skill in the art at the time of the invention date of
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`the ʼ020 Patent. I do not know the exact dates when the inventions as claimed were
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`made, thus for purposes of my opinions I have assumed that Aug. 5, 2011 of U.S.
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`Provisional Application Ser. No. 61/515,752 is the relevant point in time for
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`purposes of invalidity of the claims of the ʼ020 Patent. However, my opinions
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`would be unchanged even if this date was as early as the Nov. 3, 2011 filing date
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`IPR2021-00335, GUI Ex. 2004, Page 4
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`of U.S. Provisional Application Ser. No. 61/555,310, or as late as the Aug. 3, 2012
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`date for the national stage entry of PCT Application No. PCT/US2012/049562.
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` 13. I submit this Declaration based on the information I have reviewed for
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`purposes of this case and my own personal knowledge and experience.
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` 14. In this Declaration, when I write, “for example,” or when I cite an
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`example, I am not limiting my opinion to that example.
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` 15. The opinions expressed in This Declaration are based upon the
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`information made available to me as of the date of submission of this Declaration. I
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`understand that I may be asked to review information produced by either party
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`after the date of this Declaration and to update this Declaration as necessary to
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`reflect any additional analysis and conclusions.
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` 16. I am being compensated for my time on this case at my customary rate of
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`$325 per hour. No part of my compensation is based on the outcome of this case or
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`the substance of my opinions.
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`II.
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`ASSIGNMENT
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` 17. I have been asked to review Samsung’s petition and its supporting
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`exhibits and to offer my opinions as to whether one or more claims of the ‘020
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`Patent would be unpatentable in view of the references cited in the petition and in
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`the Kiaei Declaration. My understanding is that Samsung alleges three grounds for
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`unpatentability:
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`IPR2021-00335, GUI Ex. 2004, Page 5
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`i. Ground 1: Claims 1-9, 11-15, and 19 are alleged to be unpatentable as being
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`obvious under 35 U.S.C. § 103 in view of Kim, US PGPUB 2010/0227642
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`(Ex. 1010);
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`ii. Ground 2: Claim 10 is alleged to be unpatentable under 35 U.S.C. § 103 in
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`view of the combined teachings of Kim and Koh, KR 10-2008-0093178 (Ex.
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`1012); and
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`iii. Ground 3: Claims 16-17 are alleged to be unpatentable as being obvious
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`under 35 U.S.C. § 103 in view of the combined teachings of Kim and Lee,
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`US PGPUB 2010/0298032 (Ex. 1013).
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`iv. Ground 4: Claim 18 is unpatentable under AIA 35 U.S.C. § 103 as being
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`obvious over Kim in view of U.S. Patent 5,946,121 (“Jiang”) (EX1014).
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`Pet. at 1-2.
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`A. Legal Principles
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` 18. Like Dr. Kiaei, I am not an attorney and have not been asked to offer any
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`opinions on the law. I understand, however, that I am obliged to follow existing
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`law and to offer opinions on the ultimate issue of obviousness. I have therefore
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`been asked to apply the following legal principles in my analysis.
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` 19. I have been informed by counsel and understand that in an Inter Partes
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`Review proceeding, the party challenging the patent’s validity must prove by a
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`preponderance of the evidence that the patent claims are unpatentable. I have been
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`IPR2021-00335, GUI Ex. 2004, Page 6
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`further advised that the first step in assessing validity of a patent claim is to
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`properly construe the claim at issue.
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` 20. As noted above, I understand that all of Samsung’s challenges to the
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`patentability of the claims of the ‘020 Patent are based on obviousness under 35
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`U.S.C. § 103. To be patentable under this statute, an invention much be such that it
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`would not have been obvious to a person of ordinary skill in the art (“POSITA”) at
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`the time the invention was made. That is, the differences between the subject
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`matter sought to be patented and the prior art must not be such that the claimed
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`subject matter as a whole would have been obvious to a POSITA at the time the
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`invention was made.
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` 21. I further understand that when determining whether a claimed invention is
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`obvious, one should consider the scope and content of the prior art, the level of
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`ordinary skill in the relevant art, the differences between the claimed invention and
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`the prior art, and whether the claimed invention would have been obvious to one of
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`ordinary skill in the art in light of those differences. I understand that hindsight
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`must not be used when comparing the prior art to the invention for obviousness.
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` 22. I also understand that obviousness may be shown by demonstrating that it
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`would have been obvious to modify what is taught in a single reference to arrive at
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`the patented invention, and/or by showing that it would have been obvious to
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`combine the teachings of more than one reference to arrive at the patented
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`invention. I recognize that in determining whether prior art references would have
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`been combined with one another and/or with other information within the
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`knowledge of one of ordinary skill in the art, multiple approaches and rationales
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`may be considered, including:
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`• Combining prior art elements according to known methods to yield
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`predictable results;
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`• Simple substitution of one known element for another to obtain predictable
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`results;
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`• Use of a known technique to improve similar devices, methods, or products
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`in the same way;
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`• Applying a known technique to a known device, method, or product ready for
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`improvement to yield predictable results;
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`• Applying a technique or approach that would have been “obvious to try”
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`(choosing from a finite number of identified, predictable solutions, with a
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`reasonable expectation of success);
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`• Known work in one field of endeavor that may prompt variations of it for use
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`in either the same field or a different one based on design incentives or other
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`market forces if the variations would have been predictable to one of ordinary
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`skill in the art; or
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`• Some teaching, suggestion, or motivation in the prior art that would have led
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`one of ordinary skill to modify the prior art reference or to combine prior art
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`reference teachings to arrive at the claimed invention.
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` 23. I have been advised by counsel to Gwee that if an independent claim is
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`not obvious over a combination of references, then a claim that depends from the
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`nonobvious independent claim is likewise not obvious in view of those references,
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`because the dependent claim contains all of the limitations of the independent
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`claim plus one or more further limitations.
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` 24. In considering the question of obviousness, I understand that the POSITA
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`is a hypothetical person who is presumed to be aware of all of the pertinent prior
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`art. The POSITA is not an automaton and may be able to combine the teachings of
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`multiple patents or references employing ordinary creativity and common sense,
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`and that familiar items may have obvious uses in another context or beyond their
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`primary purposes. The POSITA faced with a problem is able to apply his or her
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`experience and ability to solve the problem and also look to any available prior art
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`to help solve the problem. I also recognize that it is not necessary to demonstrate a
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`precise teaching directed to the specific subject matter of the challenged claim, for
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`a fact finder can take account of the inferences and creative steps that a POSITA
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`would employ. A patent that merely claims predictable uses of old elements
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`according to their established functions to achieve predictable results may be found
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`IPR2021-00335, GUI Ex. 2004, Page 9
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`invalid as obvious. Hence, an invention may be obvious if a POSITA, facing the
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`wide range of needs created by developments in the field, would have seen an
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`obvious benefit to the solutions tried by the applicant. And, when there is a design
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`need or market pressure to solve a problem, and there are a finite number of
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`identified, predictable solutions, it may have been obvious to a POSITA to try the
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`known options. Also, if a technique has been used to improve one device, and a
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`POSITA would have recognized that it would improve similar devices in the same
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`way, using the technique may have been obvious.
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`B. Level of Ordinary Skill in the Art
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` 25. I understand Dr. Kiaei has testified that in his opinion a POSITA in the
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`relevant time frame would have had a bachelor’s degree in electrical engineering,
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`computer science, or a similar field and one year of experience in consumer
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`electronics product design, or could have also obtained similar knowledge and
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`experience through other means. Ex. 1002 at ¶ 22. I generally agree that for
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`purposes of evaluating claims of the ‘020 Patent, a POSITA would have been
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`someone having either a bachelor’s degree in electrical engineering, computer
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`science, or mechanical engineering with some level of post-baccalaureate
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`electronic device or system design experience, or someone with an equivalent level
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`of experience and training through other means. Dr. Kiaei’s definition of a
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`POSITA is somewhat different than mine, nevertheless my opinions in This
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`Declaration would be the same regardless of whether or not my description or Dr.
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`Kiaei’s description of a POSITA is used.
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` 26. In arriving at my opinions and conclusions in this report, I have
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`considered the invalidity issues from the perspective of this hypothetical person
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`skilled in the art during the relevant time period.
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`C. Methodology
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` 27. In reaching my opinions as expressed herein, I studied and analyzed all of
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`the documents and references cited in the petition and the Kiaei Declaration as
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`presented in this proceeding, as well as in related IPR proceedings: 2021-00336,
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`2021-00337, and 2021-00338. I have also considered the other documents and
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`references cited herein as well as my own extensive experience in industrial and
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`product technology and design, development, manufacturing, marketing, use, and
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`deployment. This experience includes my supervision, training, or direction of
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`persons destined to become POSITAs. I have also had conversations with Mr.
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`Walter Mayfield. one of the named inventors of the ‘020 Patent. Although my
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`qualifications exceed those of a POSITA for the ‘020 Patent, my statements and
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`opinions expressed herein are so expressed from the perspective of a POSITA.
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`D. Claim Construction
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` 28. Except for a general statement from Dr. Kiaei that he gave the claim terms
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`their plain and ordinary meanings, Ex. 1002 at ¶ 72, I did not see any expressed
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`IPR2021-00335, GUI Ex. 2004, Page 11
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`indication in Dr. Kiaei’s Declaration as to how he read and understood the claims,
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`nor did he provide any express construction of the claims offered in the petition.
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`See Pet. at 17-18. For my own part, in reading and understanding the ‘020 Patent
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`and the various references cited in the petition and in the Kiaei Declarations
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`submitted in this and the related IPRs, I also assigned the claim terms their plain
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`and ordinary meanings as a POSITA would have understood them. Where
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`necessary, I looked to intrinsic evidence within the specification before turning to
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`any external sources to determine how a POSITA would have understood the claim
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`terms. Where I believe it is necessary in my analyses below, I highlight instances
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`of the plain and ordinary meaning of claim terms as they would have been
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`understood by a POSITA.
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`III.
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`OVERVIEW OF THE ’020 PATENT
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` 29. The ‘020 Patent is entitled, “Apparatus for cleaning view screens and
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`lenses and method for the use thereof.” The patent application was filed on
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`December 22, 2017 and issued on April 16, 2019. It claims priority through a
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`series of continuations and related filings to U.S. Provisional Application Ser. No.
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`61/515,752, filed on Aug. 5, 2011. I understand that Samsung alleges that the ’752
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`provisional application does not provide an adequate written description of the
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`invention claimed in the ‘020 Patent, and that the ‘020 Patent is entitled to a
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`priority date no earlier than November 3, 2011, Pet. at 7-9. As none of the
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`IPR2021-00335, GUI Ex. 2004, Page 12
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`challenges depend on a difference in priority date between Aug. 5, 2011 and Nov.
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`3, 2011, I have been asked to assume for the purposes of This Declaration that the
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`Nov. 3, 2011 priority date is operative.
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` 30. The ‘021 Patent discloses and claims a switching device in combination
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`with a portable electronic device, with embodiments comprising, for example:
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`In one aspect, the invention is a switching device for use
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`with a portable electronic device having a view screen and at least
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`one switch that can be activated or de-activated by introducing a
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`magnetic field to the at least one switch wherein the switching
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`device has at least one magnet and at least one surface that is non-
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`abrasive to the surface of the view screen.
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`In another aspect, the invention is a switching device for an
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`electronic apparatus that can be activated or deactivated by
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`employing a magnet, the switching device having (i) at least one
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`magnet, (ii) a body surrounding the magnet, and (iii) at least one
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`surface configured to contact any surface of the device, including
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`the view screen; wherein the surface configured to contact the
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`electronic apparatus is non-abrasive to the view screen of the
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`apparatus.
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`IPR2021-00335, GUI Ex. 2004, Page 13
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`In another aspect, the invention is a method of conserving
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`power when using a portable electronic device having a view
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`screen and at least one switch that can activated or de-activated by
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`introducing a magnetic field to the at least one switch wherein the
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`switching device has at least one...
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`Ex. 1001 at 3:66-4:17.
`
` 31. Thus, the ’020 Patent claims a system comprising a portable switching
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`device coupled to a portable electronic device, which system includes a number of
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`elements and features. For example, the two portable devices (switching and
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`electronic) are configured to selectively couple to one another employing magnetic
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`force; the switching device comprises a case (first case), as does the electronic
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`device (second case); the electronic device comprises an electronic circuit that is
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`responsive to the switching device; a magnet (first magnet) is disposed (i.e.,
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`contained) within the electronic device; the electronic device has one or more
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`physical form elements including beveled edges, ridges, recessed areas, grooves,
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`slots, bumps, raised or indented shapes, and combinations thereof which
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`correspond to complementary physical form elements on the switching device; and
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`the portable switching device is configured to activate, deactivate or send into
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`hibernation the electronic device; and when coupled, the second case (the case of
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`the electronic device) protects the first case (the case of the portable switching
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`device). Id. at 21:28 – 22:2. Various features of the portable switching device and
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`the portable electronic device can thus be summarized as follows:
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`Portable switching device:
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`-
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`is configured to selectively couple to portable electronic device employing
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`magnetic force;
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`- has a first case protected by the second case of the portable electronic device
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`when the two are coupled to one another;
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`- has surface elements complementary to at least one beveled edge, recessed
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`area, raised or indented shape, ridge, groove, slot, bump, or combinations
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`thereof of the portable electronic device;
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`-
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`is configured to activate, deactivate, or send into hibernation the portable
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`electronic device.
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`Portable electronic device:
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`-
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`is configured to selectively couple to portable switching device employing
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`magnetic force;
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`- has a second case which protects the first case of the portable switching
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`device when the two are coupled to one another;
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`- has a magnet fully disposed within it;
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`Samsung v. GUI Global Products
`IPR2021-00335, GUI Ex. 2004, Page 15
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`- has at least one beveled edge, recessed area, raised or indented shape,
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`ridge, groove, slot, bump, or combinations thereof that correspond to
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`complementary surface elements of the portable electronic device.
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` 32. I note that when the ’020 Patent recites a magnet “disposed” within the
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`portable electronic device, it should be construed as “contained” therein. This is
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`because that is how a POSITA would understand the ordinary and customary
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`meaning of the term “disposed within” as used in the claims. A POSITA would
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`understand that to be “disposed” within something is to be arranged within it.
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`Additionally, the context of the ‘020 Patent makes clear that the arrangement is
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`such that the magnet is entirely contained within the portable electronic device. Id.
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`at 6:40:43 (“Turning to FIGS. 2A and 2B, a side view of the cleaning component,
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`it can be seen that disposed within the cleaner material (201) is a ferromagnetic or
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`ferrimagnetic substrate (202).”); 18:13-15 (referring to FIG. 25, “Disposed within
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`the switching device is a ferromagnetic or ferrimagnetic substrate (2504).”).
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`Hence, the POSITA would understand the term “disposed within” to mean
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`Samsung v. GUI Global Products
`IPR2021-00335, GUI Ex. 2004, Page 16
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`“entirely contained within.”
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` 33. According to the ‘020 Patent, the switching device and the portable
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`electronic device can be coupled together magnetically. The coupling/decoupling
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`can cause an action to occur and be advantageously used for saving power or
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`battery life. See, for example, id. at 20:4-13. I note that claim 1 recites, “the
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`switching device and the electronic device are configured to selectively couple to
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`each other employing magnetic force.” Id. at 21:32-35. The ‘020 Patent explains
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`this by stating,
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`The switching devices of the application selectively couple with
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`the case or cases of the portable electronic devices. The term
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`"selectively couple" describes the process wherein a switching
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`device of the disclosure is applied to a portable electronic device
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`and adheres to it because of a magnetic force. In one embodiment
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`of the disclosure, there is sufficient magnetic force to allow the
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`switching device to remain in place despite casual movements of
`Samsung v. GUI Global Products
`IPR2021-00335, GUI Ex. 2004, Page 17
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`the portable electronic device, but to still be easily removed by a
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`human operator.
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` 34. Id. at 17:54-62. Accordingly, A POSITA would have understood the term
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`“selectively couple” to mean “adhere.”
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` 35. According to the ‘020 Patent, the portable switching device and the
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`portable electronic device conform to one another physically with complementary
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`surface elements, and each has a corresponding case. The lid of the switching
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`device is configured to conform to the electronic device, and when coupled, the
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`case of the switching device protects the case of the electronic device. See, e.g., id.
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`at 21:32-35.
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`IV.
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`ANALYSIS OF SAMSUNG’S CHALLENGES
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`A. Kim Does Not Teach or Suggest Samsung’s Fig. A Embodiment
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`1.
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`Overview of Kim (U.S. Patent Application US 2010/0227642
`A1)
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` 36. All of Samsung’s alleged grounds for unpatentability rely on Kim, either
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`alone or in combination with Koh or Lee. Pet. at 1-2. To this end, I understand Dr.
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`Kiaei has alleged that Kim, “discloses an embodiment of the mobile terminal in
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`which a watch-type main device comprises a first body 100a connected to a second
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`body 100b by a hinge 100d so that the first and second bodies can be opened or
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`closed with respect to each other, and wherein the mobile terminal further
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`Samsung v. GUI Global Products
`IPR2021-00335, GUI Ex. 2004, Page 18
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`comprises a sub-device 300 detachably coupled to the second body 100b,” Ex.
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`1002 at ¶ 87 (emphasis omitted), and that he believes this disclosure would be
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`understood by a POSITA as represented by a hypothesized “Figure A”
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`embodiment reproduced below. I note that this rendition of the watch device does
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`not actually appear in Kim nor is it described in Kim. Id. Rather, Dr. Kiaei and
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`Samsung have modified the original, conjuring up an unstated fictitious
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`combination of Kim’s Figures 15A and 15B in an effort to support his opinion.
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` 37. It actuality, Kim discloses in Figure 15A one embodiment of a mobile
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`terminal in which a watch-type main device includes a first body 100a connected
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`to a second body 100b by a hinge 100d so that the first and second bodies can be
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`Samsung v. GUI Global Products
`IPR2021-00335, GUI Ex. 2004, Page 19
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`opened or closed with respect to each other. Kim’s Figure 15B shows a sub-device
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`300 that may be detachably coupled on top of the “second body.” EX1010 at [261].
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`Dr. Kiaei presents an unsupported version purportedly from Kim in which a sub-
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`device 300 is detachably coupled to the underside of second body 100b, and
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`sandwiched in between the first body and second body