UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.,
`Petitioners
`v.
`GUI Global Products, Ltd., D/B/A Gwee,
`Patent Owner
`
`Case IPR2021-00336
`U.S. Patent No. 10,259,021
`
`DECLARATION OF DR. SAYFE KIAEI IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 10,259,021
`
`Ex. 1002
`Page 001 of 182
`
`

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`IPR2021-00336
`U.S. Patent No. 10,259,021
`
`Table of Contents
`INTRODUCTION ........................................................................................... 1
`I.
`BACKGROUND AND QUALIFICATIONS ................................................. 2
`II.
`III. MATERIALS REVIEWED ............................................................................. 7
`IV.
`LEVEL OF ORDINARY SKILL IN THE ART ............................................10
`V.
`RELEVANT LEGAL STANDARDS ...........................................................11
`VI. OVERVIEW OF THE ’021 PATENT ...........................................................14
`VII. OVERVIEW OF THE PRIOR ART .............................................................19
`A.
`Kim ......................................................................................................19
`B.
`Koh ......................................................................................................39
`C.
`Lee .......................................................................................................43
`D.
`Jiang ....................................................................................................46
`VIII. CLAIM CONSTRUCTION ...........................................................................48
`IX.
`THE PRIOR ART DISCLOSES OR SUGGESTS ALL OF THE
`FEATURES OF THE CHALLENGED CLAIMS .........................................49
`A.
`Grounds Challenging Claims 1-19 of the ’021 Patent ........................49
`B.
`Kim Discloses or Suggests All of the Features of
`Claims 1-9, 11-15, and 19 ...................................................................49
`1.
`Claim 1 ......................................................................................50
`2.
`Claim 2 ....................................................................................112
`3.
`Claim 3 ....................................................................................115
`4.
`Claim 4 ....................................................................................116
`5.
`Claim 5 ....................................................................................118
`
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`Claim 6 ....................................................................................119
`6.
`Claim 7 ....................................................................................128
`7.
`Claim 8 ....................................................................................132
`8.
`Claim 9 ....................................................................................132
`9.
`10. Claim 11 ..................................................................................140
`11. Claim 12 ..................................................................................142
`12. Claim 13 ..................................................................................144
`13. Claim 14 ..................................................................................144
`14. Claim 15 ..................................................................................145
`15. Claim 19 ..................................................................................145
`Kim and Koh Disclose or Suggest All of the Features
`of Claim 10 ........................................................................................145
`1.
`Claim 10 ..................................................................................146
`Kim and Lee Disclose or Suggest All of the Features of
`Claims 16 and 17 ...............................................................................161
`1.
`Claim 16 ..................................................................................161
`2.
`Claim 17 ..................................................................................169
`Kim and Jiang Disclose or Suggest All of the Features
`of Claim 18 ........................................................................................170
`1.
`Claim 18 ..................................................................................171
`CONCLUSION ............................................................................................179
`
`D.
`
`C.
`
`E.
`
`X.
`
`ii
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`Ex. 1002
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`IPR2021-00336
`U.S. Patent No. 10,259,021
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`I, Sayfe Kiaei, declare as follows:
`
`I.
`
`INTRODUCTION
`
`1.
`
`I have been retained by Samsung Electronics Co., Ltd. and Samsung
`
`Electronics America, Inc. (“Samsung” or “Petitioners”) as an independent expert
`
`consultant in this proceeding before the United States Patent and Trademark Office
`
`(“PTO”).
`
`2.
`
`I am being compensated at a rate of $610/hour for my services in this
`
`proceeding, which is my regular and customary rate.
`
`3.
`
`My compensation is in no way contingent on the nature of my findings,
`
`the presentation of my findings in testimony, or the outcome of this or any other
`
`proceeding. I have no other interest in this proceeding.
`
`4.
`
`I have been asked to consider whether certain references disclose or
`
`suggest the features recited in the claims of U.S. Patent No. 10,259,021 (“the ’021
`
`patent”) (Ex. 1001).1 My opinions are set forth below.
`
`1 Where appropriate, I refer to exhibits I understand will be attached to the petition
`
`for inter partes review of the ’021 patent (the “Petition”).
`
`1
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`II.
`
`BACKGROUND AND QUALIFICATIONS
`
`5.
`
`I am an independent consultant. All of my opinions stated in this
`
`declaration are based on my own personal knowledge and professional judgment. In
`
`forming my opinions, I have relied on my education, experience, and knowledge
`
`regarding electrical engineering, computer science, and consumer electronics
`
`product design.
`
`6.
`
`I am over 18 years of age and, if I am called upon to do so, I would be
`
`competent to testify as to the matters set forth herein. A copy of my current
`
`curriculum vitae, which details my education and professional and academic
`
`experience, is included as Ex. 1003 in this proceeding. The following provides an
`
`overview of some of my experience that is relevant to the matters set forth in this
`
`declaration.
`
`7.
`
`Since 2001, I have held the position of Motorola Endowed Chair
`
`Professor in Analog and Radio Frequency Integrated Circuitry at the School of
`
`Electrical, Computer, and Energy Engineering at Arizona State University (“Arizona
`
`State”) in Tempe, Arizona. I am also the Director of the National Science
`
`Foundation Center, Connection One. Connection One is a research center focused
`
`on developing wireless communication system and networking technologies.
`
`2
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`8.
`
`I received my doctorate in Electrical and Computer Engineering from
`
`Washington State University in 1987. I have several patents and over 100 journal
`
`and international conference publications. I have graduated over 70 MS and PhD
`
`students working under my supervision on their thesis, and many of them are
`
`professors in academia or have senior positions in industry. My research is funded
`
`by various sources, including industry, such as Motorola Inc., Intel Inc., Broadcom,
`
`Qualcomm, Raytheon, General Dynamics, and Texas Instruments; and federal
`
`agencies, such as NSF, USAID, DARPA, JPL, and NASA.
`
`9.
`
`From 1987 to 1993, I was an assistant/associate professor at Oregon
`
`State University (“Oregon State”). From 1997 to 2002, I was also an adjunct
`
`professor at the University of Texas (“UT”) at Austin, while I worked full time at
`
`Motorola in Austin. From 2002 to present, I have been a professor at Arizona State
`
`University (“Arizona State”). At Oregon State, UT, and Arizona State, I taught
`
`courses
`
`in
`
`the areas of communication systems; wireline and wireless
`
`communication systems; radio frequency (“RF”) systems and circuits; radio-
`
`frequency identification (“RFID”); magnetic and electronic sensors; analog circuits;
`
`digital integrated circuits, including HDL, Verilog, and VHDL; digital signal
`
`processing; and related areas. At Arizona State, I developed a new course on the
`
`design of wireless and RF transceivers (EEE524) and wireless transceiver design
`
`3
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`(EEE598). These courses cover transceiver architecture, wireless and sensor
`
`electronics, 1G through 4G wireless systems, and wireless transceivers (for example,
`
`Bluetooth transceivers).
`
`10.
`
`I have been involved in research, teaching, and developing products in
`
`the areas of wireline systems, cellular systems, radio frequency integrated circuits
`
`(“RFIC”), analog and digital
`
`integrated circuits,
`
`sensors, electronics,
`
`communications, digital signal processing, and related areas for the last 30 years. I
`
`have worked in industry and academia on the first generation of mobile phones, as
`
`well as second generation (2G) and third generation (3G) mobile phone technologies
`
`including GSM, EDGE, IS-95, 1X CDMA, UMTS, and Wide band CDMA. I have
`
`also worked on other wireless data communication technologies including
`
`Bluetooth, the Global Positioning System (GPS), RFID, magnetic and electronic
`
`sensors, wireless local area networks (LAN) (or Wi-Fi), and related areas.
`
`11.
`
`From 1993 to 2001, I worked at Motorola Wireless Integrated
`
`Technology Center and Motorola Analog/Digital Design groups. This group was
`
`responsible for the design and development of communication systems, architecture,
`
`digital signal processing (DSP, and analog, and RF integrated circuits. The products
`
`included first generation wireless phones (1G - AMPS, Digital AMPS), second
`
`generation wireless phones (2G - GSM, EDGE, GPRS), and third generation
`
`4
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`Ex. 1002
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`wireless phones (3G - CDMA, WCDMA, UMTS, CDMA2000). The products
`
`included the Razr, iDEN, other Motorola flip phones, Talkabout radios, and
`
`CopperGold DSL MODEMS. I was responsible for the development of wireless
`
`system, cellular system, RF integrated circuits, Bluetooth, and GPS. I also worked
`
`on the development of CopperGold Motorola Digital Subscriber Lines (DSL)
`
`transceivers. The CopperGold system included ADSL, VDSL, and DSL.lite, with
`
`full legacy compatible system. The integrated solution contained integrated on-chip
`
`OFDM, FFT, custom fixed-point Motorola DSP, ADC and DAC, and over 50
`
`input/output ports for communication, including ATM, ISDM, IrDA, and other
`
`ports. I was also involved with the IrDA system design, including specification, link
`
`budget, circuit blocks, optical and electrical requirements, and protocol. While I was
`
`at Motorola, I represented Motorola in ITU, ETSI and IEEE standard setting bodies.
`
`I was also involved in the Bluetooth SIG on behalf of Motorola, and also represented
`
`Motorola before the FCC related to the GPS-E911 mandate.
`
`12.
`
`I have also been a consultant on various projects with Intel (designing
`
`2G and 3G mobile telephone transceivers), Texas Instrument (developing 3G
`
`cellular and Bluetooth technologies), Sony Wireless (developing GPS technologies),
`
`Tektronix (designing wireless systems), and various other consultancies.
`
`5
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`13. During my work in industry, I designed and contributed to the design
`
`of many radio transceivers for commercial products, including designs for 1G to 3G
`
`cellular systems, 2-way radio, Bluetooth, GPS, and other transceiver systems. Many
`
`of my designs are still in use today in products manufactured by the companies I
`
`have worked for, including Motorola, Intel, and Sony.
`
`14.
`
`I am an IEEE Fellow, which is the highest level of IEEE membership
`
`awarded by the IEEE directors to recognize a high level of demonstrated
`
`extraordinary accomplishments. The IEEE Fellow Award is a special recognition
`
`for members with extraordinary accomplishments in the IEEE technical fields. To
`
`ensure that the recognition is extraordinary, the total number of recipients each year
`
`cannot exceed 0.1% of the total higher grade membership. The IEEE is the Institute
`
`of Electrical and Electronics Engineers, the world’s largest association of technical
`
`professionals whose objectives include the educational and technical advancement
`
`of electrical and electronic engineering, telecommunications, computer engineering,
`
`and related disciplines.
`
`15.
`
`I am a member of the IEEE Circuits and Systems Society, IEEE Solid
`
`State Circuits Society, IEEE Signal Processing Society, and IEEE Communication
`
`Society. I am also a member of the IEEE RF and Microwave committees, IEEE
`
`Low Power Symposium Committee, and IEEE Fellow Selection Committee. I was
`
`6
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`one of the key organizers establishing the IEEE Radio Frequency Integrated Circuits
`
`(RFIC) symposium in 1995, and I have been on the executive and technical
`
`committees of RFIC for the last 16 years. The RFIC Symposium is now the premier
`
`international symposium in the world where the latest RF circuits and components
`
`are presented. I have been involved in several international conferences in the areas
`
`of RF, Communication, Signal Processing, and IC design.
`
`16.
`
`I have received several awards including the Carter Best Teacher
`
`Award, the IEEE Darlington Award (which is given for the best technical paper on
`
`circuits and systems in the IEEE Circuits and Systems Society), and the Motorola
`
`10X Rapid Design Cycle Reduction Award.
`
`III. MATERIALS REVIEWED
`
`17.
`
`The opinions contained in this declaration are based on the documents
`
`I reviewed, my professional judgment, as well as my education, experience, and
`
`knowledge regarding electrical engineering, computer science, and consumer
`
`electronics product design.
`
`18.
`
`In forming my opinions expressed in this declaration, I reviewed the
`
`following materials:
`
` the ’021 patent (Ex. 1001);
`
` the file history of the ’021 patent (Ex. 1004);
`
`7
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` the File History of U.S. Provisional Application No. 61/515,752 (Ex. 1005);
`
` U.S. Patent Application Publication 2010/0227642 to Kim et al. (“Kim”) (Ex.
`
`1010);
`
` Korean Patent Publication 10-2008-0093178 to Koh et al. (“Koh”) (Ex.
`
`1012)2;
`
` U.S. Patent Application Publication 2010/0298032 to Lee et al. (”Lee”) (Ex.
`
`1013);
`
` U.S. Patent No. 5,946,121 to Jiang et al. (“Jiang”) (Ex. 1014);
`
` U.S. Patent Application Publication No. 2008/0166005 to Terlizzi et al.
`
`(“Terlizzi”) (Ex. 1015);
`
` U.S. Patent Application Publication No. 2006/0152576 to Kiessling et al.
`
`(“Kiessling”) (Ex. 1016);
`
`2 I understand Ex. 1012 is a compilation comprising the English-language translation
`
`of Kim (Ex. 1012, 1-15), and its Korean language version (id., 16-30), and an
`
`affidavit required by 37 C.F.R. § 42.63(b) (in the form of a declaration as permitted
`
`by 37 C.F.R. § 42.2) (id., 31).
`
`8
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` U.S. Patent Application Publication No. 2003/0164895 to Viinikanoja et al.
`
`(“Viinikanoja”) (Ex. 1017);
`
` International Patent Publication No. WO 2010/142290 to Birger et al.
`
`(“Birger”) (Ex. 1018);
`
` U.S. Patent No. 6,809,774 to Yamazaki et al. (“Yamazaki”) (Ex. 1019);
`
` U.S. Patent No. 7,251,197 to Yoshida et al. (“Yoshida”) (Ex. 1020);
`
` U.S. Patent Application Publication 2011/0211297 to Griffin et al. (“Griffin”)
`
`(Ex. 1021);
`
` U.S. Patent Application Publication 2006/0071746 to Lylyharju (“Lylyharju”)
`
`(Ex. 1022);
`
` A Dictionary of Chemistry (5th ed. 2004) (Ex. 1023);
`
`and any other materials I refer to in this declaration in support of my opinions.
`
`19. All of the opinions contained in this declaration are based on the
`
`documents I reviewed and my knowledge and professional judgment. My opinions
`
`have also been guided by my appreciation of how a person of ordinary skill in the
`
`art would have understood the claims and the specification of the ’021 patent at the
`
`time of the alleged invention, which I have been asked to initially consider as no
`
`earlier than November 3, 2011 (the filing date of U.S. Provisional Patent Application
`
`61/555,310). My opinions reflect how one of ordinary skill in the art would have
`
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`understood the ’021 patent, the prior art to the patent, and the state of the art at the
`
`time of the alleged invention.
`
`20. Based on my experience and expertise, it is my opinion that certain
`
`references disclose and/or suggest, alone or in combination, all the features recited
`
`in claims 1-19 (“challenged claims”) of the ’021 patent, as I discuss in detail below.
`
`IV. LEVEL OF ORDINARY SKILL IN THE ART
`
`21.
`
`I have been informed and understand that, in the context of an invalidity
`
`analysis, a person having ordinary skill in the art is a hypothetical person who looks
`
`to prior art at the time of the invention. I further understand that the factors that may
`
`be considered in determining the level of ordinary skill include: (1) the problems
`
`encountered in the art; (2) the prior art solutions to the problems encountered in the
`
`art; (3) the rapidity of innovation; (4) the sophistication of the technology; and (5)
`
`the education level of active workers in the field. I understand that these factors
`
`need not all be considered for the analysis and that one or more of these factors may
`
`control.
`
`22.
`
`I was asked to provide my opinion on the level of one of ordinary skill
`
`in the art with respect to the alleged invention of the ’021 patent as of November 3,
`
`2011. Based on my consideration of the factors above, I believe a person of ordinary
`
`skill in the art would have had at least a bachelor’s degree in electrical engineering,
`
`10
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`computer science, or a similar field and one year of experience in consumer
`
`electronics product design. More education can supplement practical experience and
`
`vice versa.
`
`23. As of November 3, 2011, I met, and in fact exceeded, the qualifications
`
`of a person of ordinary skill in the art. To be clear, all of my opinions in this
`
`declaration are from the perspective of one of ordinary skill in the art as I have
`
`defined it here during the relevant timeframe.
`
`V.
`
`RELEVANT LEGAL STANDARDS
`
`24.
`
`I am not an attorney and offer no legal opinions, but in the course of
`
`my work, I have had experience studying and analyzing patents and patent claims
`
`from the perspective of a person skilled in the art.
`
`25.
`
`For the purposes of this declaration, I have been informed about certain
`
`aspects of the law that are relevant to forming my opinions. My understanding of
`
`the law is as follows:
`
`26.
`
`Petitioners’ counsel has informed me that for the prior art to inherently
`
`disclose a claimed limitation, the prior art need not expressly disclose the limitation,
`
`so long as the claimed limitation necessarily flows from a disclosure in the prior art.
`
`27.
`
`Petitioners’ counsel has informed me that a patent claim can be
`
`considered to have been obvious to a person of ordinary skill in the art at the time
`
`11
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`the application was filed in view of the prior art. This means that, even if all of the
`
`requirements of a claim are not found in a single prior art reference, the claim is not
`
`patentable if the differences between the subject matter in the prior art and the
`
`subject matter in the claim would have been obvious to a person of ordinary skill in
`
`the art at the relevant time, which I have been informed in this case is November 3,
`
`2011.
`
`28.
`
`Petitioners’ counsel has informed me that a determination of whether a
`
`claim would have been obvious should be based upon several factors, including,
`
`among others:
`
`the level of ordinary skill in the art at the time the application was filed;
`
`the scope and content of the prior art; and
`
`what differences, if any, existed between the claimed invention and the
`
`
`
`
`
`
`
`prior art.
`
`29.
`
`Petitioners’ counsel has informed me that a single prior art reference
`
`can render a patent claim obvious if any differences between that reference and the
`
`claims would have been obvious to a person of ordinary skill in the art.
`
`Alternatively, the teachings of two or more references may be combined in the same
`
`way as disclosed in the claims, if such a combination would have been obvious to
`
`one having ordinary skill in the art. In determining whether a combination based on
`
`12
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`either a single reference or multiple references would have been obvious, it is
`
`appropriate to consider, among other factors:
`
`
`
`whether the teachings of the prior art references disclose known
`
`concepts combined in familiar ways, and when combined, would yield predictable
`
`results;
`
`
`
`whether a person of ordinary skill in the art could implement a
`
`predictable variation, and would see the benefit of doing so;
`
`
`
`whether the claimed elements represent one of a limited number of
`
`known design choices, and would have a reasonable expectation of success by those
`
`skilled in the art;
`
`
`
`whether a person of ordinary skill would have recognized a reason to
`
`combine known elements in the manner described in the claim;
`
`
`
`whether there is some teaching or suggestion in the prior art to make
`
`the modification or combination of elements claimed in the patent; and
`
`
`
`whether the innovation applies a known technique that had been used
`
`to improve a similar device or method in a similar way.
`
`30.
`
`Petitioners’ counsel has informed me that one of ordinary skill in the
`
`art has ordinary creativity and is not an automaton. Petitioners’ counsel has also
`
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`informed me that in considering obviousness, it is important not to determine
`
`obviousness using the benefit of hindsight derived from the patent being considered.
`
`VI. OVERVIEW OF THE ’021 PATENT
`
`31.
`
`The ’021 patent, titled “Apparatus for Cleaning View Screens and
`
`Lenses and Method for the Use Thereof,” is generally directed to “[a] lens and/or a
`
`view screen of an electronic device having at least one case [that] can be cleaned by
`
`wiping the view screen with a cleaning component wherein the cleaning component
`
`is configured to selectively couple to the at least one case or some other substrate
`
`using a magnetic attractive force.” Ex. 1001, Abstract.
`
`32. According to the ’021 patent, “[c]leaning lenses has long been an issue
`
`for the users of devices employing them.” Id., 1:38-39. The ’021 patent explains
`
`that “[c]leaning the view screen of a portable electronic device can be problematic”
`
`and “[c]arrying appropriate cleaning materials is sometimes a problem.” Id., 1:59-
`
`66. For at least these reasons, the ’021 patent states the following:
`
`It would be desirable in the art of manufacturing portable
`electronic devices to incorporate into such devices the cleaning
`apparatus. It would also be desirable in the art of providing
`accessories for portable electronic devices to provide a cleaning
`component that can be carried on an electronic device case.
`
`Id., 2:3-8.
`
`14
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`33.
`
`To address these alleged problems, the ’021 patent describes several
`
`embodiments such as, for example, “a method of cleaning a view screen of an
`
`electronic device” (id., 2:12-18), “a cleaning component for use on an electronic
`
`device view screen” (id., 2:19-23), and “a switching device for use with a portable
`
`electronic device having a view screen” (id., 3:64-4:11).
`
`34.
`
`The majority of the ’021 patent describes methods of cleaning and
`
`aspects of a cleaning device. However, the ’021 patent also provides that:
`
`In addition to their cleaning functionality, the cleaning
`components of the application have a functionality of being able
`to activ[ate] magnetic switches on devices having such switches.
`This is particularly useful in saving battery life as it does not
`require the cover of such devices to be closed (the normal mode
`for activation of such switches). In the use of tablet devices
`having a magnetic switch, the cleaning components are
`particularly useful as the tablet can be put into hibernation mode
`with a single touch to the cleaning component as compared to the
`multiple touches required to do the same thing using the touch
`pad of the tablet.
`
`Id., 11:59-12:2. In one embodiment, the cleaning device may also have “additional
`
`functionality such as a remote control, laser pointer or the like.” Id., 16:30-40. Such
`
`functionality may also include, “pointing devices,” “remote functionality,” “flash
`
`drive,” “earplugs,” “credit card reader, microphone, and the like.” Id., 16:48-58.
`
`15
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`U.S. Patent No. 10,259,021
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`Despite this disclosure, the ’021 patent also provides that the cleaning device “may
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`or may not include cleaning capabilities but will include a rare earth magnet or
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`magnets.” Id., 16:40-42.
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`35.
`
`The ’021 patent further discloses the following:
`
`One embodiment of the invention is a switching device for use
`a portable electronic device having a view screen, a switch for
`turning the portable device off and on that can be activated or
`deactivated by the application of a magnetic field and at least one
`case. The term portable electronic device means such devices
`having a view screen including, but not limited to, tablet
`computers, laptop computers, portable DVD players, and the
`like.
`
`Id., 17:54-61 (emphasis added). This embodiment is depicted in FIG. 24 of the ’021
`
`patent, which I have provided below:
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`Id., FIG. 24, 18:5-17.
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`36.
`
`The ’021 patent also provides that “the switching device (2401) is
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`selectively coupled to the front of the portable electronic device 2402 outside of the
`
`view screen 2403.” Id., 18:7-11. A side view of the switching device 2401 is shown
`
`below:
`
`Id., FIG. 25, 18:19-31. The ’021 patent discloses that:
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`In this embodiment, the bottom of the switching device is in
`contact with portable electronic device and is composed of a
`material that is not abrasive to the portable electronic device
`generally and the view screen in particular. Except for this
`limitation, the switching devices may be prepared with any
`material known to be useful to those of ordinary skill in the art
`for such applications.
`
`Id., 18:25-31.
`
`37.
`
`The ’021 patent further discloses that:
`
`The switching devices have a functionality of being able to
`active[ate] magnetic switches on devices having such switches.
`This is particularly useful in saving battery life as it does not
`require the cover of such devices to be closed (the normal mode
`for activation of such switches). In the use of tablet devices
`having a magnetic switch, the switching devices are particularly
`useful as the tablet can be put into hibernation mode with a single
`touch to the switching device as compared to the multiple
`touches required to do the same thing using the touch pad of the
`tablet.
`
`Id., 20:14-23.
`
`38.
`
`In addition to the disclosure of the ’021 patent, I have also reviewed the
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`file history of the ’021 patent (Ex. 1004) and U.S. Provisional Patent Application
`
`No. 61/515,752 (“the ’752 provisional application”) (Ex. 1005), which I understand
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`is referenced in the ’021 patent. The ’752 provisional application does not disclose
`
`a switching device or a portable switching device, as recited in the’021 patent. See
`
`generally Ex. 1005.
`
`VII. OVERVIEW OF THE PRIOR ART
`
`A.
`
`39.
`
`Kim
`
`The devices disclosed in Kim enable a user to activate and deactivate
`
`an electronic device with a separate switching device, and aim to achieve that
`
`purpose using the same features claimed in the ’021 patent.
`
`40. Kim is directed to a mobile terminal comprising a main device and sub-
`
`device(s) that are detachably coupled to the main device. Ex. 1010, Abstract. For
`
`example, Kim discloses:
`
`A mobile terminal [that] includes a sub-device that is attached
`thereto or detached therefrom, to remotely control the operation
`and state of the terminal. The mobile terminal includes: a sub-
`device having an input/output unit and attached to or detached
`from the terminal; and a controller configured to receive a user
`input via a certain communication path from the sub-device
`when the sub-device is separated, and control elements and
`applications of the terminal according to the user input.
`
`Id. Kim discloses that examples of “terminals” include “mobile terminals as well as
`
`stationary terminals, such as mobile phones, user equipment, smart phones, DTV,
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`computers, digital broadcast terminals, personal digital assistants, portable
`
`multimedia players (PMP) and/or navigators.” Id., ¶69; see also id., ¶70 (“A further
`
`description may be provided with regard to a mobile terminal, although such
`
`teachings may apply equally to other types of terminals.”). A person of skill in the
`
`art would have understood that at least mobile phones, smart phones, personal digital
`
`assistants, portable multimedia players (PMP) and/or navigators were “mobile
`
`terminals.”
`
`41. Kim describes the structure and functionality of the mobile terminal in
`
`a number of interrelated embodiments. Kim expressly notes that its embodiments
`
`can be combined together:
`
`Embodiments for a control method in the mobile terminal 100
`may now be described with reference to the accompanying
`drawings. Embodiments may be used singly and/or by being
`combined together. Embodiments may be implemented more
`easily when the display 151 includes the touchscreen.
`
`Id. ¶179.
`
`42.
`
`Initially, Kim discusses various features that are common to the mobile
`
`terminals. Id., ¶¶71-122. For example, Kim states that “FIG. 1 is a block diagram
`
`of a mobile terminal” that includes “a wireless communication unit 110, an
`
`audio/video (A/V) input unit 120, a user input unit 130, a sensing unit 140, an output
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`unit 150, a memory 160, an interface unit 170, a controller 180 and a power supply
`
`190.” Id., ¶72. Kim explains, however, that the mobile terminal can include “more
`
`or less” components than shown in Figure 1. Id. ¶71. I have reproduced Figure 1 of
`
`Kim below:
`
`Id., FIG. 1. Kim provides detailed descriptions of each of these “units.” See id.,
`
`¶¶73-119 (describing the various units and modules in the mobile terminal). For
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`example, Kim describes the A/V unit 120 as including a camera:
`
`The audio/video (A/V) input unit 120 may provide audio or video
`signal input to the mobile terminal 100. The A/V input unit 120
`may include a camera 121 and a microphone 122. The camera
`121 may receive and process image frames of still pictures and/or
`video.
`
`Id., ¶84. Kim describes the sensing unit 140 detecting an open/close status (or state)
`
`of the mobile terminal 100:
`
`The sensing unit 140 may provide status measurements of
`various aspects of the mobile terminal 100. For example, the
`sensing unit 140 may detect an open/close status (or state) of the
`mobile terminal 100, a relative positioning of components (e.g.,
`a display and a keypad) of the mobile terminal 100, a change of
`position of the mobile terminal 100 or a component of the mobile
`terminal 100, a presence or absence of user contact with t