IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re Patent of: Mayfield et al.
`U.S. Patent No.:
`10,259,020
`Issue Date:
`April 16, 2019
`Appl. Serial No.: 15/851,952
`Filing Date:
`December 22, 2017
`Title:
`APPARATUS FOR CLEANING VEW SCREENS AND
`LENSES AND METHOD FOR THE USE THEREOF
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`Attorney Docket No.: 50095-0028IP1
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`DECLARATION OF DR. JEREMY COOPERSTOCK
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`1
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`APPLE 1003
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`TABLE OF CONTENTS
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`Attorney Docket No. 50095-0028IP1
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`TABLE OF CONTENTS
`INTRODUCTION .......................................................................................... 5
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`QUALIFICATIONS ....................................................................................... 6
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` MATERIALS CONSIDERED ....................................................................... 8
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` SUMMARY OF CONCLUSIONS ............................................................... 12
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`LEGAL PRINCIPLES .................................................................................. 14
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` Obviousness ............................................................................................. 14
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` PERSON OF ORDINARY SKILL IN THE ART ........................................ 15
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` OVERVIEW OF THE ’020 PATENT .......................................................... 16
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` GROUND 1A—Claims 1-3, 5-7, 10, 16, and 19 are obvious in view of
`Bohbot and Gundlach. ................................................................................... 19
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` Overview of Bohbot ................................................................................. 19
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` Overview of Gundlach ............................................................................. 21
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` The Bohbot-Gundlach Combination ........................................................ 24
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` Analysis of Claims 1-3, 5-7, 10, 16, and 19 ............................................ 28
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` Claim 1 ................................................................................................ 28
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` Claim 2 ................................................................................................ 60
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` Claim 3 ................................................................................................ 64
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` Claim 5 ................................................................................................ 67
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` Claim 6 ................................................................................................ 69
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` Claim 7 ................................................................................................ 72
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` Claim 10 .............................................................................................. 75
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` Claim 16 .............................................................................................. 80
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` Claim 19 .............................................................................................. 82
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` GROUND 1B: Claim 2 is obvious in view of Bohbot, Gundlach, and
`Nishikawa...................................................................................................... 86
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` Overview of Nishikawa ........................................................................... 86
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` The Bohbot-Gundlach-Nishikawa Combination ..................................... 87
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` Analysis of Claim 2 ................................................................................. 88
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` Claim 2 ................................................................................................ 88
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` GROUND 1C: Claims 4, 18, and 19 are obvious in view of Bohbot,
`Gundlach, and Li. .......................................................................................... 89
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` Overview of Li ......................................................................................... 89
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` The Bohbot-Gundlach-Li Combination ................................................... 91
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` Analysis of Claims 4, 18, and 19 ........................................................... 100
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` Claims 4 and 18 ................................................................................ 100
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` Claim 19 ............................................................................................ 102
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` GROUND 1D: Claims 8 and 9 are obvious in view of Bohbot, Gundlach,
`and Stevinson. ............................................................................................. 105
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` Overview of Stevinson ........................................................................... 105
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` The Bohbot-Gundlach-Stevinson Combination ..................................... 108
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` Analysis of Claims 8 and 9 .................................................................... 112
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` GROUND 1E: Claim 10 is obvious in view of Bohbot, Gundlach, and
`Rosener........................................................................................................ 113
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` Overview of Rosener ............................................................................. 113
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` The Bohbot-Gundlach-Rosener Combination ....................................... 114
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` Analysis of Claim 10 ............................................................................. 118
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` GROUND 1F: Claim 17 is obvious in view of Bohbot, Gundlach, Stevinson,
`and Iio. ........................................................................................................ 120
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` Overview of Iio ...................................................................................... 120
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` The Bohbot-Gundlach-Stevinson-Iio Combination ............................... 121
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` Analysis of Claim 17 ............................................................................. 126
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` GROUND 2A: Claims 1-3, 5-7, 10, 16, and 19 are obvious in view of
`Bohbot, Gundlach, and Diebel. ................................................................... 127
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` Overview of Diebel ................................................................................ 128
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` The Bohbot-Gundlach-Diebel Combination .......................................... 129
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` Analysis of 1[f] ...................................................................................... 132
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` GROUND 2B: Claim 2 is obvious in view of Bohbot, Gundlach, Diebel, and
`Nishikawa.................................................................................................... 133
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` GROUND 2C: Claims 4, 18, and 19 are obvious in view of Bohbot,
`Gundlach, Diebel, and Li. ........................................................................... 133
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` GROUND 2D: Claims 8 and 9 are obvious based on Bohbot, Gundlach,
`Diebel and Stevinson. ................................................................................. 134
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` GROUND 2E: Claim 10 is obvious based on Bohbot, Gundlach, Diebel,
`and Rosener ................................................................................................. 134
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` GROUND 2F: Claim 17 is obvious based on Bohbot, Gundlach, Diebel,
`Stevinson, and Iio ........................................................................................ 135
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` CONCLUSION ........................................................................................... 135
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`I, Jeremy Cooperstock, of Montreal, Canada, declare that:
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`INTRODUCTION
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`1.
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`I have been retained by Fish & Richardson, P.C., on behalf of Apple
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`Inc. (“Petitioner”), as an independent expert consultant in this inter partes review
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`(“IPR”) proceeding before the United States Patent and Trademark Office
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`(“PTO”).
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`2.
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`I have been asked by Petitioner’s counsel (“Counsel”) to consider
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`whether certain references teach or suggest the features recited in Claims 1-10 and
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`16-19 of U.S. Patent No. 10,259,020 (“the ’020 patent”). My opinions and the
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`bases for my opinions are set forth below. My opinions are based on my education
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`and experience.
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`3.
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`In writing this Declaration, I have considered the following: my own
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`knowledge and experience, including my teaching and work experience in the
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`above fields; and my experience of working with others involved in those fields.
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`4.
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`I have no financial interest in either party or in the outcome of this
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`proceeding. I am being compensated for my work as an expert on an hourly basis,
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`for all tasks involved. My compensation is not dependent on the outcome of these
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`proceedings or on the content of my opinions.
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` QUALIFICATIONS
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`5.
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`I am a professor in the Department of Electrical and Computer
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`Engineering at McGill University. My curriculum vitae is provided as Appendix A.
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`6.
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`I received my B.Sc. in Electrical Engineering from the University of
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`British Columbia, my M.Sc. in Computer Science from the University of Toronto
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`in 1992, and my Ph.D. in Electrical and Computer Engineering from the University
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`of Toronto in 1996.
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`7.
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`I am a member of the Centre for Intelligent Machines, and a founding
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`member of the Centre for Interdisciplinary Research in Music Media and
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`Technology at McGill University. I also direct the Shared Reality Lab at McGill,
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`which focuses on computer mediation to facilitate high-fidelity human
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`communication and the synthesis of perceptually engaging, multimodal, immersive
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`environments. I led the development of the Intelligent Classroom, the world's first
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`Internet streaming demonstrations of Dolby Digital 5.1, multiple simultaneous
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`streams of uncompressed high-definition video, a high-fidelity orchestra rehearsal
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`simulator, a simulation environment that renders graphic, audio, and vibrotactile
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`effects in response to footsteps, and a mobile game treatment for amblyopia.
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`8. My work on the Ultra-Videoconferencing system was recognized by
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`an award for Most Innovative Use of New Technology from ACM/IEEE
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`Supercomputing and a Distinction Award from the Audio Engineering Society.
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`The research I supervised on the Autour project earned the Hochhausen Research
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`Award from the Canadian National Institute for the Blind and an Impact Award
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`from the Canadian Internet Registry Association, and my Real-Time Emergency
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`Response project won the Gold Prize (brainstorm round) of the Mozilla Ignite
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`Challenge.
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`9.
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`I have worked with IBM at the Haifa Research Center, Israel, and the
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`Watson Research Center in Yorktown Heights, New York, the Sony Computer
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`Science Laboratory in Tokyo, Japan, and was a visiting professor at Bang &
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`Olufsen, Denmark, where I conducted research on telepresence technologies as
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`part of the World Opera Project. I led the theme of Enabling Technologies for a
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`Networks of Centres of Excellence on Graphics, Animation, and New Media
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`(GRAND) and I am an associate editor of the Journal of the AES.
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`10.
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`I have carried out significant research involving network
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`communication protocols, including wireless communication employing IEEE
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`802.11 (WiFi) and IEEE 802.15 (Bluetooth). My experience in these areas includes
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`development of the Adaptive File Distribution Protocol (AFDP, 1995), analysis of
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`the tradeoffs between bandwidth, power demands, and latency for audio streaming
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`over WiFi, Bluetooth, and ultra-wideband protocols (2007), and assessment of the
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`performance and scalability of wireless audio streaming for applications requiring
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`latency-optimized multimedia streaming (2008). I have led all aspects of
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`development and experimentation in the Autour project (2009-2016), for which
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`Bluetooth is typically used as a communication layer for audio between the user’s
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`smartphone and a wireless headset, or, experimentally, to transmit user input
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`acquired from a wireless game controller. I am currently leading a research project
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`(MIMIC), which communicates sensor data between two coupled smartwatches
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`using Bluetooth for local communication between the smartwatches and their
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`peered smartphones, and the public Internet between the smartphones. I am also
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`leading a project that uses both Bluetooth and WiFi communication between
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`smartphones, a GPU-based physics engine, and a microelectronics architecture that
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`renders vibrotactile effects on mobile footwear.
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` MATERIALS CONSIDERED
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`11.
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`I have reviewed the ’020 patent (APPLE-1001) and relevant excerpts
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`of its prosecution history (APPLE-1002). I understand that the ’020 patent was
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`filed on December 22, 2017 with a priority claim dating back to the August 5, 2011
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`filing date of provisional application No. 61/515,752. While I am not opining on
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`whether the ’020 patent is entitled to its priority date, for purposes of this
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`Declaration, I am using August 5, 2011 as the purported priority date (“Critical
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`Date”).
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`12. As part of my independent analysis for this Declaration, I have
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`considered my personal knowledge and experience; the common knowledge of
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`persons of ordinary skill prior to August 5, 2011, and the following publications
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`and materials:
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`• APPLE-1004
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`Certified English Translation of French Patent
`Publication No. FR2912858 to Bohbot (“Bohbot”)
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`• APPLE-1005
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`• APPLE-1006
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`• APPLE-1007
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`• APPLE-1008
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`• APPLE-1009
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`• APPLE-1010
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`• APPLE-1020
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`• APPLE-1024
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`• APPLE-1025
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`• APPLE-1026
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`• APPLE-1027
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`• APPLE-1028
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`U.S. Patent Publication No. 2008/0132293
`(“Gundlach”)
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`Certified English Translation of Chinese Patent
`Publication No. CN201114710Y to Li et al. (“Li”)
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`U.S. Patent Application Publication No.
`2011/0317865 to Stevinson (“Stevinson”)
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`U.S. Patent Application Publication No.
`2003/0005558 to Wong
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`U.S. Patent Application Publication No.
`2009/0014105 to Shattuck
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`U.S. Patent Application Publication No.
`2011/0218502 to Iio et al. (“Iio”)
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`Certified English Translation of European Patent
`Publication No. EP2037661 to Ponticelli et al.
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`U.S. Patent No. 8,086,281 to Rabu et al.
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`U.S. Patent No. 8,737,650 to Pedersen
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`U.S. Patent No. 7,161,578 to Schneider
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`U.S. Patent Application Publication No.
`2004/0227998 to Aoshima et al.
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`U.S. Patent Application Publication No.
`2009/0091708 to Greene
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`U.S. Patent Application Publication No.
`2011/0117851 to Kim
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`U.S. Patent Application Publication No.
`2010/0124040 to Diebel et al.
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`AUDIO/VIDEO REMOTE CONTROL PROFILE
`(Version 1.0 Adopted), Bluetooth Audio Video
`Working Group
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`U.S. Publication No. 2006/0166715
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`U.S. Publication No. 2008/0070501
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`• APPLE-1029
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`• APPLE-1030
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`• APPLE-1034
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`• APPLE-1035
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`• APPLE-1036
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`• APPLE-1037
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`U.S. Pat. No. 7,761,091
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`• APPLE-1038
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`• APPLE-1039
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`Voyager 855 Bluetooth Headset—User
`Guide, Plantronics Sound Innovation
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`Jabra Sport—User Manual, Jabra
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`• APPLE-1042
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`U.S. Pat. No. 7,012,802
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`• APPLE-1043
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`U.S. Publication No. 2008/0167088
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`• APPLE-1044
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`U.S. Publication No. 2008/0157110
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`• APPLE-1045
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`• APPLE-1050
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`Advantages and Weaknesses of LED Application,
`LEDinside,
`https://web.archive.org/web/20121102080414/http
`s://www.ledinside.com/knowledge/2007/12/Advan
`tages_and_weaknesses_of_LED_Application_200
`712
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`U.S. Publication No. 2008/0076489 to Rosener et
`al. (“Rosener”)
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`Next-Generation Stereo Bluetooth Headsets,
`TechHive,
`https://www.techhive.com/article/162341/ste
`reo_bluetooth_headsets.html
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`U.S. Patent Publication No. 2007/0145255 to
`Nishikawa et al. (“Nishikawa”)
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`U.S. Patent Publication No. 2008/0298606 to
`Johnson et al.
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`• APPLE-1051
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`• APPLE-1059
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`• APPLE-1060
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`• APPLE-1062
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`• APPLE-1063
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`• APPLE-1064
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`• APPLE-1065
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`• APPLE-1066
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`• APPLE-1067
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`• APPLE-1068
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`13. Note that my citations to non-patent literature throughout this
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`U.S. Patent No. 7,195,362
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`U.S. Patent No. 8,064,194
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`EP Patent Publication No. 0 517 497
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`U.S. Patent Publication No. 2010/0195860
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`Plugfones.com,
`https://web.archive.org/web/20110820072700/http
`s://www.plugfones.com/
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`CES: Hands On with the Kleer Wireless Earbuds,
`Gadget Lab | WIRED,
`https://web.archive.org/web/20140721204820/http:
`//www.wired.com/2007/01/ces_hands_on_wi/
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`U.S. Patent Publication No. 2006/0111044
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`declaration reference the absolute page number added to the exhibit (as opposed to
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`the original pagination of the document). For patent literature, I’ve used the
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`column/line numbers or paragraph numbers. Note also that all emphasis
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`(bold/italics/underline) in any quoted text has been added.
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`14. Although this declaration refers to selected portions of the cited
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`references for the sake of brevity, it should be understood that these are examples,
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`and that one of ordinary skill in the art would have viewed the references cited
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`herein in their entirety and in combination with other references cited herein or
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`cited within the references themselves. The references used in this declaration,
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`therefore, should be viewed as being incorporated herein in their entireties.
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`15. Counsel has informed me that I should consider these materials
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`through the lens of a person of ordinary skill in the art (“POSITA,” which is
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`discussed further in § VI below) as of the Critical Date, and I have done so. Unless
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`otherwise stated, my testimony below refers to the knowledge of a POSITA as of
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`the Critical Date.
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` SUMMARY OF CONCLUSIONS
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`16. This declaration explains the conclusions that I have formed based on
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`my independent analysis. To summarize those conclusions:
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`• Ground 1A: Claims 1-3, 5-7, 10, 16, and 19 are obvious in view of
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`Bohbot and Gundlach. See Infra, § VIII.
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`• Ground 1B: Claim 2 is obvious in view of Bohbot, Gundlach, and
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`Nishikawa. See Infra, § IX.
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`• Ground 1C: Claims 4, 18, and 19 are obvious in view of Bohbot,
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`Gundlach, and Li. See Infra, § X.
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`• Ground 1D: Claims 8 and 9 are obvious in view of Bohbot,
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`Gundlach, and Stevinson. See Infra, § XI.
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`• Ground 1E: Claim 10 is obvious in view of Bohbot, Gundlach, and
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`Rosener. See Infra, § XII.
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`• Ground 1F: Claim 17 is obvious in view of Bohbot, Gundlach,
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`Stevinson, and Iio. See Infra, § XIII.
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`• Ground 2A: Claims 1-3, 5-7, 10, 16, and 19 are obvious in view of
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`Bohbot, Gundlach, and Diebel. See Infra, § XIV.
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`• Ground 2B: Claim 2 is obvious in view of Bohbot, Gundlach, Diebel,
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`and Nishikawa. See Infra, § XV.
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`• Ground 2C: Claims 4, 18, and 19 are obvious in view of Bohbot,
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`Gundlach, Diebel, and Li. See Infra, § XVI.
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`• Ground 2D: Claims 8 and 9 are obvious in view of Bohbot,
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`Gundlach, Diebel, and Stevinson. See Infra, § XVII.
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`• Ground 2E: Claim 10 is obvious in view of Bohbot, Gundlach,
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`Diebel, and Rosener. See Infra, § XVIII.
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`• Ground 2F: Claim 17 is obvious in view of Bohbot, Gundlach,
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`Diebel, Stevinson, and Iio. See Infra, § XIX.
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` LEGAL PRINCIPLES
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`Attorney Docket No. 50095-0028IP1
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`17.
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`In forming my analysis and conclusions expressed in this Declaration,
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`I have applied the legal principles described in the following paragraphs, which
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`were provided to me by counsel for the Petitioner.
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` Obviousness
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`18.
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`I have been informed that a patent claim is invalid as “obvious” in
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`light of one or more prior art references if it would have been obvious to a person
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`of ordinary skill in the art at the time of the alleged invention (“POSITA”), taking
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`into account (1) the scope and content of the prior art, (2) the differences between
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`the prior art and the claims, (3) the level of ordinary skill in the art, and (4) any so
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`called “secondary considerations” of non-obviousness, which include: (i) “long felt
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`need” for the claimed invention, (ii) commercial success attributable to the claimed
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`invention, (iii) unexpected results of the claimed invention, and (iv) “copying” of
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`the claimed invention by others.
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`19.
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`I have been informed that a claim can be obvious in light of a single
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`prior art reference or multiple prior art references. To be obvious in light of a
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`single prior art reference or multiple prior art references, there must be a reason
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`that would have prompted a POSITA to modify or supplement the single prior art
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`reference, or to combine two or more references, in a manner that provides the
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`elements of the claimed invention. This reason may come from a teaching,
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`suggestion, or motivation to combine, or may come from the reference(s)
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`themselves, the knowledge or “common sense” of a POSITA, or from the nature of
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`the problem to be solved, and this reason may be explicit or implicit from the prior
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`art as a whole. I have been informed that, under the law, the combination of
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`familiar elements according to known methods is likely to be obvious when it does
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`no more than yield predictable results. I also understand it is improper to rely on
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`hindsight in making the obviousness determination.
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` PERSON OF ORDINARY SKILL IN THE ART
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`20. Based on my knowledge and experience in the field and my review of
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`the ’020 patent and its file history, I believe that a POSITA would have had at least
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`a Bachelor’s degree in an academic area emphasizing electrical engineering,
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`mechanical engineering, or a similar discipline, and at least two years of
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`experience in the field working with electronic devices. Superior education could
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`compensate for a deficiency in work experience, and vice-versa.
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` OVERVIEW OF THE ’020 PATENT1
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`21. The ’020 patent traces its lineage back to the disclosures of nine
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`provisional applications filed between August 2011 and June 2012.
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`22. Eight of those provisional applications (yellow, below) are directed to
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`various embodiments of a device for cleaning the view screens of portable
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`electronic devices. Such a device is described in the provisionals and the ’020
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`patent as a “cleaning device.” See e.g., APPLE-1001, 3:49-55.
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`1 I discuss the ’020 patent’s preferred embodiment to provide context for my
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`analysis of the prior art below. I understand that multiple aspects of the preferred
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`embodiment are not recited as claim limitations.
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`23. The remaining provisional application in the ’020 patent’s priority
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`chain (green, above) discloses various embodiments of a “switching device” for
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`activating and deactivating the magnetic switch of a portable electronic device.
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`This “switching device” provisional disclosure is what most closely resembles the
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`claimed subject matter of the ’020 patent. See APPLE-1001, 21:27-30 (“What is
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`claimed is: 1. A system comprising: a portable switching device...).
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`24. The ’020 patent’s SUMMARY references “a switching device for use
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`with a portable electronic device having... at least one switch that can be activated
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`or de-activated.” APPLE-1001, 3:59-65. As one example, the switch of the
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`portable electronic device can be activated/deactivated “by introducing a magnetic
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`Attorney Docket No. 50095-0028IP1
`IPR of US. Patent No. 10,259,020
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`field to the at least one switch” via a magnet in the switching device. Id.
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`25. Figure 24 (below) is a front view of a switching device 2401 and a
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`portable electronic device 2402 discussed in the ’020 patent’s DETAILED
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`DESCRIPTION. APPLE-1001, 17:63-18:21. As shown, the switching device 2401
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`“is selectively coupled to the front of the portable electronic device 2402.” Id.,
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`17:65-66. And consistent with the above-discussed example in the Summary, the
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`electronic device 2402 includes a magnetic switch 2404 activated/deactivated by
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`applying the switching device 2401 either “directly to the magnetic switch or [] to
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`either side of the switch and then slid past it.” Id., 18:3-8; see also 20:4-6 (“The
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`switching devices have a functionality of being able to activ[ate] magnetic
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`switches on devices having such switches.”). In one embodiment,
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`activation/deactivation of the switch causes the device to turn on/off. Id., 17:45-
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`49.
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`18
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`Attorney Docket No. 50095-0028IP1
`IPR of US. Patent No. 10,259,020
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` GROUND 1A—Claims 1-3, 5-7, 10, 16, and 19 are obvious in view of
`Bohbot and Gundlach.
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` Overview of Bohbot
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`26. Bohbot—entitled “MINIATURE COMMUNICATION DEVICE”—
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`describes “a miniature communication device” that “can communicate with a
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`telephone located in a near environment.” APPLE-1004, 1:1-5, 2:25-27, 4:18-21.
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`Bohbot’s “miniature communication device” includes “a primary module” and “a
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`detachable headset.” APPLE-1004, 3:4-9. The detachable headset is “designed to
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`be detached... and then repositioned frequently on the primary module.” APPLE-
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`1004, 3:10-11.
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`19
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`27. FIG. 3 (reproduced below) shows an example of the miniature
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`Attorney Docket No. 50095-0028IP1
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`communication device where “the primary module 30 and the detachable headset
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`31 are separated.” APPLE-1004, 11:12-14. The detachable headset 31 includes a
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`magnet 33a, allowing it to be held in position in the housing 34 of the primary
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`module 30, due to the ferromagnetic material 33b, which is sensitive to the
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`attraction of the magnet 33a, installed at the bottom of the housing 34. APPLE-
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`1004, 11:14-19, 13:20-14:1.
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`miniature communication device
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`primary
`module
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`detachable
`headset
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`housing
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`ferromagnetic
`material
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`blade
`contactors
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`magnet
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`blade
`contactors
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`APPLE-1004, FIG. 3 (annotated)
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`28. The detachable headset 31 also includes a set of blade contactors 35a
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`which, upon contact with a set of blade contactors 35b installed in the housing 34,
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`20
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`establishes a connection between the detachable headset 31 and the primary
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`Attorney Docket No. 50095-0028IP1
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`module 30, so that data and/or electrical load can be exchanged. APPLE-1004,
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`3:14-20, 11:20-25, 13:14-19. In more detail, Bohbot describes “a main power
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`storage device installed in the primary module, and a secondary power storage
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`device installed in the detachable headset.” APPLE-1004, 6:22-25, 14:12-15.
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`“[W]hen the detachable headset is in contact with the primary module,” power is
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`transmitted from the main power storage device of the primary module to the
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`secondary power storage device of the detachable headset via the sets of blade
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`contactors 35a and 35b. APPLE-1004, 6:25-7:1, 14:15-18. “Thus, the headset
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`recharges automatically as soon as it is attached to the [primary module].”
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`APPLE-1004, 7:2-3. Additionally, the primary module includes data storage
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`means that receives data via the sets of blade contactors 35a and 35b “when the
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`detachable [headset] is in contact with the primary module.” APPLE-1004, 7:16-
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`27, 14:19-24.
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` Overview of Gundlach
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`29. Gundlach’s disclosure—entitled “WIRELESS HEADSET”—was
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`inspired by the demand for “wireless technologies” that emerged when the industry
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`sought to eliminate the burden of “managing the wires” on mobile device
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`peripherals. APPLE-1005, [0003]. But wireless peripherals brought about their
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`own problems—e.g., “keeping track of [them] and keeping them charged and
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`21
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`ready to use.” APPLE-1005, [0005]. Gundlach set out to address these problems,
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`and did so by providing “a device that when in [an expanded] configuration...
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`becomes a wireless mono or stereo headset and when in a [collapsed]
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`configuration... may be stored and charged.” APPLE-1005, [0055]. Gundlach’s
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`disclosure includes a variety of embodiments consistent with the theme of an
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`expandable/collapsible wireless headset having a “relatively thin shape [that] may
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`allow the headset to be stored and charged in a portable cradle,” such as “a holder,
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`clip, case or card.” APPLE-1005, [0055-0056].
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`30. Gundlach’s disclosure is expansive on the topic of “storage,” noting
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`broadly at the outset that a wireless headset can be “stored and charged in a
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`portable cradle,” such as “a holder, clip, case or card,” or “stored and charged in a
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`host device such as a... cell phone.” APPLE-1005, [0056], Abstract. Gundlach
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`then goes on to illustrate and describe a variety of exemplary designs with
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`embedded magnets and/or mechanical elements for retaining the wireless headset.
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`See e.g., APPLE-1005, [0068], [0073], [0075], Figures 10a-19b.
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`31. As one example, in Figure 17a (below), “the wireless device 1700
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`may be provided on the host device 1710” such as “a mobile phone,... a portable
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`music player, laptop, etc.” APPLE-1005, [0078]. In Figure 17a, “the host device
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`1710 may define a recess 1746 therein which may receive the wireless device
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`1700.” Id.
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`Attorney Docket No. 50095-0028IP1
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`host device
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`wireless
`headset
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`contoured
`recess
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`APPLE-1005, FIG. 17a (annotated)
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`32. As another example, in Figures 18a-18b (below), the “portable cradle”
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`is a “clamshell case” 1860 that retains the wireless headset 1800 within a
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`contoured recess 1846. APPLE-1005, [0080]. Gundlach’s case 1860 may include
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`“a reserve power supply, such as a reserve battery and charging circuitry.” Id.
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`Gundlach’s case 1860 can provide power and data to the wireless headset. Id.
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`23
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`Attorney Docket No. 50095-0028IP1
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`contoured
`recess
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`APPLE-1005, FIGS. 18a, 18b (annotated)
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` The Bohbot-Gundlach Combination
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`33. As discussed above, Bohbot describes a miniature communication
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`device including a detachable headset that can magnetically couple and electrically
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`connect to a primary module so that data and/or charge can be exchanged.
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`APPLE-1004, 3:4-9, 3:14-20, 11:12-25, 13:14-14:1, FIG. 3. A POSITA
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`considering Bohbot, and noting its limited disclosure on storage of the headset,
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`would have seen a need for elaboration and description of design options to
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`implement the storage functionality. A search for supplemental disclosure on
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`storage would have led the POSITA to Gundlach, a reference addressing this topic
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`in the same context as Bohbot—wireless headsets. Gundlach describes a case or
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`24
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`host device that retains a wireless headset within a contoured recess so that the
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`Attorney Docket No. 50095-0028IP1
`IPR of US. Patent No. 10,259,020
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`headset may be stored and charged. APPLE-1005, [0055], [0080], FIGS. 18a, 18b.
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`A POSITA seeking to implement Bohbot’s device would have turned to
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`Gundlach’s teachings and arrive at a predictable configuration having a primary
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`module with a contoured recess for retaining the detachable headset (shown
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`below), with the detachable headset magnetically coupling and electrically
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`connecting to the primary module when the detachable headset is placed within the
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`contoured recess of the primary module.
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`Bohbot’s miniature communication device
`modified in view of Gundlach
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`primary
`module
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`contoured
`recess
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`detachable
`headset
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`34. Bohbot provides a “miniature communication device” that includes a
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`“primary module” that couples to and charges a “detachable headset.” APPLE-
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`1004, 1:3-5, 2:25-27, 3:4-5, 9:19-21, 6:22-7:1, 7:16-27, 10:20-11:6, 14:12-24, Figs.
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`1a, 1b. Like Bohbot, Gundlach provides “a system for a storing and charging a
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`25
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`wireless device.” APPLE-1005, [0008]. Both Bohbot and Gundlach contemplate
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`Attorney Docket No. 50095-0028IP1
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`that a magnet can be involved in securing a headset to its primary module or
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`cradle. APPLE-1004, 3:24-4:14, 11:12-19; APPLE-10