Apple Inc. (Petitioner)
`v.
`GUI Global Products, Ltd. (Patent Owner)
`Petitioner Demonstratives
`Case No. IPR2021-00470
`U.S. Patent No. 10,259,020
`
`Before Hon. Sally C. Medley, Sheila F. McShane, Monica S. Ullagaddi
`Administrative Patent Judges
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`APPLE 1119
`Apple v. GUI
`IPR2021-00470
`
`
`v.
`GUI Global Products, Ltd. (Patent Owner)
`Petitioner Demonstratives
`Case No. IPR2021-00470
`U.S. Patent No. 10,259,020
`
`Before Hon. Sally C. Medley, Sheila F. McShane, Monica S. Ullagaddi
`Administrative Patent Judges
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`APPLE 1119
`Apple v. GUI
`IPR2021-00470
`
`
`
`Table of Contents
`
`Issue 1: Bohbot’s Teachings Render Obvious a “Switching Device”
`
`1A: Bohbot’s Headset acts as a Switching Device to Activate/Deactivate Discharging of Power
`
`1B: Bohbot’s Headset acts as a Switching Device to Activate/Deactivate Receipt of Data
`
`1C: Bohbot’s Headset acts as a Switching Device to Activate/Deactivate Microphone Circuitry
`
`1D: Bohbot’s Headset acts as a Switching Device to Activate/Deactivate the Portable Electronic Device
`
`Issue 2: A POSITA Would Have Modified Bohbot Based On Gundlach’s Teachings
`
`Issue 3: A POSITA Would Have Modified Bohbot Based On Diebel’s Teachings
`
`Issue 4: The Dependent Claims Are Obvious
`
`Overview of the Instituted Grounds
`
`3
`
`6
`
`11
`
`16
`
`26
`
`29
`
`39
`
`46
`
`81
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`
`
`Issue 1
`
`Bohbot’s Teachings Render Obvious
`A “Switching Device”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`3
`
`
`
`’020 Patent’s “Switching Device”
`Independent Claim
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Inst. Dec., 6-7;
`APPLE-1001, 21:28-22:2, p.27
`
`4
`
`4
`
`
`
`Bohbot Renders Obvious A “Switching Device”
`
`Petition provides three independent, alternative mappings
`
`1.
`
`2.
`
`3.
`
`
`Bohbot’s headset acts as a switching device to activate/deactivate activate/deactivate
`discharging of power from the primary module’s main power
`discharging of power
`storage device to the headset’s secondary power storage device.
`
`Bohbot’s headset acts as a switching device to activate/deactivate
`activate/deactivate
`receipt and storage of data at the primary module’s data storage
`receipt and storage of data
`unit.
`
`Bohbot’s headset acts as a switching device to activate/deactivate activate/deactivate
`
`
`
`the primary module’s microphone circuitry.the primary module’s microphone circuitry.
`
`Pet., 11-16, 23-26, 27-29; Pet. Reply, 2-7
`
`5
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`
`
`Issue 1A
`
`Bohbot’s Headset acts as a Switching Device to
`Activate/Deactivate Discharging of Power
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`6
`
`6
`
`
`
`Activate/Deactivate Discharging of Power
`
`Dr. Cooperstock’s First Declaration
`
`APPLE-1003, ¶ 43
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`7
`
`
`
`Activate/Deactivate Discharging of Power
`
`Bohbot
`
`APPLE-1004, 6:22-7:3
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`8
`
`
`
`Activate/Deactivate Discharging of Power
`
`Patent Owner’s Response and Sur-reply
`
`PO Sur-reply, 7; POR, 1-2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`9
`
`
`
`Activate/Deactivate Discharging of Power
`Dr. Cooperstock’s Second Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶¶ 12-13
`
`10
`
`10
`
`
`
`Issue 1B
`
`Bohbot’s Headset acts as a Switching Device to
`Activate/Deactivate Receipt and Storage of Data
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
`
`11
`
`
`
`Activate/Deactivate Receipt and Storage of Data
`
`Dr. Cooperstock’s First Declaration
`
`APPLE-1003, ¶ 44
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`12
`
`
`
`Activate/Deactivate Receipt and Storage of Data
`
`Bohbot
`
`APPLE-1004, 7:16-27
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`13
`
`
`
`Activate/Deactivate Receipt and Storage of Data
`
`Patent Owner’s Reply and Sur-reply
`
`PO Sur-reply, 9; POR, 19-20
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`14
`
`
`
`Activate/Deactivate Receipt and Storage of Data
`
`Dr. Cooperstock’s Second Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 15
`
`15
`
`15
`
`
`
`Issue 1C
`
`Bohbot’s Headset acts as a Switching Device to
`Activate/Deactivate Microphone Circuitry
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`16
`
`
`
`Activate/Deactivate Microphone
`
`Dr. Cooperstock’s First Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 48
`
`17
`
`17
`
`
`
`Activate/Deactivate Microphone
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 63
`
`18
`
`18
`
`
`
`Activate/Deactivate Microphone
`
`Bohbot
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1004, 10:20-11:4
`
`19
`
`19
`
`
`
`Activate/Deactivate Microphone
`
`Patent Owner’s Reply and Sur-reply
`
`POR 20-21
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`PO Sur-reply 11-12
`
`20
`
`20
`
`
`
`Activate/Deactivate Microphone
`
`Dr. Cooperstock’s Second Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶ 18
`
`21
`
`21
`
`
`
`Activate/Deactivate Microphone
`
`Patent Owner’s Response
`
`Institution Decision
`
`POR, 3
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Inst. Dec., 19
`
`22
`
`22
`
`
`
`Activate/Deactivate Microphone
`
`Dr. Cooperstock’s First Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 47
`
`23
`
`23
`
`
`
`Activate/Deactivate Microphone
`
`Dr. Cooperstock’s First Declaration
`
`APPLE-1003, ¶ 49
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`24
`
`24
`
`
`
`Activate/Deactivate Microphone
`Dr. Cooperstock’s First Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 50
`
`25
`
`25
`
`
`
`Issue 1D
`
`Bohbot’s Headset Activates/Deactivates the
`Portable Electronic Device
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`26
`
`26
`
`
`
`’020 Patent’s Activate and Deactivate
`
`Independent Claim
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Inst. Dec. 6-7;
`APPLE-1001, 21:28-22:2, p.27
`
`27
`
`27
`
`
`
`Activate and Deactivate
`
`Dr. Cooperstock’s Second Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶¶ 20-21
`
`28
`
`28
`
`
`
`Issue 2
`
`A POSITA Would Have Modified Bohbot
`Based On Gundlach’s Teachings
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`29
`
`29
`
`
`
`’020 Patent “Recessed Areas”
`Independent Claim
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Inst. Dec. 6-7;
`APPLE-1001, 21:28-22:2, p.27
`
`30
`
`30
`
`
`
`A POSITA Would Have Modified Bohbot Based On Gundlach
`
`Dr. Cooperstock’s First Declaration
`
`APPLE-1003, ¶¶ 68, 33
`
`APPLE-1003, ¶ 68
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`31
`
`31
`
`
`
`A POSITA Would Have Modified Bohbot Based On Gundlach
`
`Dr. Cooperstock’s First Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 35
`
`32
`
`32
`
`
`
`A POSITA Would Have Modified Bohbot Based On Gundlach
`
`Patent Owner’s Response
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`“The reasons for Gundlach’s deep recesses are not applicable to Bohbot.”
`
`“Bohbot provides all the attaching means needed or desired, and would have no
`motivation to seek out Gundlach or to add Gundlach’s recess.”
`
`“In circumstances surrounding the use of the headset described by Bohbot, a recess
`becomes a hinderance, not a solution.”
`
`“Gundlach’s deep recesses would be unsuitable for the easy and quick detachment
`needed by Bohbot.”
`
`“A POSITA would not add a recess for the headset to the primary module because it
`would then become difficult to remove the headset with one hand.”
`
`“A POSITA would not want to have to dig a headset out from a recess with one hand
`because it make it more difficult and time consuming to remove the headset from the
`primary module.”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`POR, 14-15
`
`33
`
`33
`
`
`
`GUI: “The reasons for Gundlach’s deep recesses are not applicable to Bohbot.”
`
`Dr. Cooperstock’s Second Declaration
`
`APPLE-1089, ¶ 23
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶ 25
`
`34
`
`34
`
`
`
`GUI: “Bohbot provides all the attaching means needed or desired, and would have
`no motivation to seek out Gundlach or to add Gundlach’s recess,” and
`“a recess becomes a hinderance, not a solution.”
`Dr. Cooperstock’s Second Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶ 28
`
`35
`
`35
`
`
`
`GUI: “Gundlach’s deep recesses would be unsuitable for the easy and quick
`detachment needed by Bohbot,” making it “difficult to remove the headset with one
`hand” and “time consuming to remove the headset from the primary module.”
`Bohbot’s Disclosures Relied Upon By Patent Owner
`
`APPLE-1004, 1:6-12 (cited by POR, 14)
`Dr. Cooperstock’s Second Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶ 26
`
`36
`
`36
`
`
`
`GUI: “Gundlach’s deep recesses would be unsuitable for the easy and quick
`detachment needed by Bohbot,” making it “difficult to remove the headset with one
`hand” and “time consuming to remove the headset from the primary module.”
`Bohbot’s Disclosures Relied Upon By Patent Owner
`
`APPLE-1004, 2:9-13 (cited by POR, 15)
`
`Dr. Cooperstock’s Second Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶ 26
`
`37
`
`37
`
`
`
`GUI: “Gundlach’s deep recesses would be unsuitable for the easy and quick
`detachment needed by Bohbot,” making it “difficult to remove the headset with one
`hand” and “time consuming to remove the headset from the primary module.”
`Dr. Cooperstock’s Second Declaration
`
`Bohbot
`
`APPLE-1089, ¶ 27
`
`APPLE-1004, 3:22-4:5 (cited by APPLE-1089, ¶ 27)
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`38
`
`38
`
`
`
`Issue 3
`
`A POSITA Would Have Modified Bohbot
`Based On Diebel’s Teachings
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`39
`
`39
`
`
`
`’020 Patent’s Activate, Deactivate, or Hibernation
`
`Independent Claim
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Inst. Dec. 6-7;
`APPLE-1001, 21:28-22:2, p.27
`
`40
`
`40
`
`
`
`A POSITA Would Have Modified Bohbot Based On Diebel
`
`Dr. Cooperstock’s First Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 163
`
`41
`
`41
`
`
`
`A POSITA Would Have Modified Bohbot Based On Diebel
`
`Dr. Cooperstock’s First Declaration
`
`APPLE-1003, ¶ 160
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 161
`
`42
`
`42
`
`
`
`A POSITA Would Have Modified Bohbot Based On Diebel
`
`Patent Owner’s Response
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`POR, 58-59
`
`43
`
`43
`
`
`
`A POSITA Would Have Modified Bohbot Based On Diebel
`
`Dr. Cooperstock’s Second Declaration
`
`APPLE-1089, ¶ 33
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`44
`
`44
`
`
`
`A POSITA Would Have Modified Bohbot Based On Diebel
`
`Patent Owner’s Response
`
`Dr. Cooperstock’s Second Declaration
`
`POR, 59
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶ 35
`
`45
`
`45
`
`
`
`Issue 4
`
`The Dependent Claims Are Obvious
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`46
`
`46
`
`
`
`Issue 4A
`
`Claim 6 Is Obvious
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`47
`
`47
`
`
`
`Claim 6 Is Obvious
`
`Claim 6
`
`APPLE-1001, 22:11-13
`
`Dr. Cooperstock’s First Declaration
`
`APPLE-1003, ¶ 87
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`48
`
`48
`
`
`
`Claim 6 Is Obvious
`
`Dr. Cooperstock’s First Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 88
`
`49
`
`49
`
`
`
`Claim 6 Is Obvious
`
`Patent Owner’s Response
`A clamshell case would make it “more difficult to access the headset.”
`
`“A POSITA would appreciate that if using only one hand, as Bohbot intends, it would be easier
`to remove the phone from the bag than to manipulate a clamshell with one hand.”
`
`“This would it make it more difficult and time consuming to remove the headset from the
`primary module.”
`
`“Putting Bohbot’s headset inside a clamshell case defeats” Bohbot’s design goal and intent that
`the detachable headset is “‘designed to be detached by nature, and then repositioned
`frequently on the primary module,’ as one would expect when answering a call.”
`
`“Putting Bohbot’s headset inside a clamshell case defeats” Bohbot’s design goal and intent that
`“Bohbot’s magnetic means of attachment are, on the one hand, such that they make
`attachment and detachment easy for the communication device user and on the other hand,
`they are powerful enough to make an effective attachment possible.”
`
`“One would not be able to utilize the necessary, useful, and desirable features of the headset if
`the case was closed.”
`
`“A user could not conduct a call by bringing the entire device to his ear, as intended by Bohbot.”
`
`“One would have difficulty hearing, or might not hear at all, the speaker/ringer when the
`clamshell was closed” and “could not use the headset, or the speaker.”
`
`POR, 30-31
`
`50
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`50
`
`
`
`Claim 6 Is Obvious
`
`Dr. Cooperstock’s Second Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶ 39
`
`51
`
`51
`
`
`
`Claim 6 Is Obvious
`
`Dr. Cooperstock’s Second Declaration
`
`APPLE-1089, ¶ 40
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`52
`
`52
`
`
`
`Claim 6 Is Obvious
`
`Dr. Cooperstock’s Second Declaration
`
`APPLE-1089, ¶ 41
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`53
`
`53
`
`
`
`Issue 4B
`
`Claim 7 Is Obvious
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`54
`
`54
`
`
`
`Claim 7 Is Obvious
`
`Claim 7
`
`APPLE-1001, 22:14-15
`
`Dr. Cooperstock’s First Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 93
`
`55
`
`55
`
`
`
`Claim 7 Is Obvious
`
`Dr. Cooperstock’s First Declaration
`
`APPLE-1003, ¶ 90
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`56
`
`56
`
`
`
`Claim 7 Is Obvious
`
`Gundlach
`
`APPLE-1003, ¶ 89
`(citing APPLE-1005, FIGS. 18a, 18b)
`
`Corroborated by Stevinson
`
`APPLE-1003, ¶¶ 90-91 (citing APPLE-1007, FIGS. 14E, 14F, 18A)
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`57
`
`57
`
`
`
`Claim 7 Is Obvious
`
`Dr. Cooperstock’s First Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 92
`
`58
`
`58
`
`
`
`Claim 7 Is Obvious
`
`Patent Owner’s Response
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`POR, 33
`
`59
`
`59
`
`
`
`Claim 7 Is Obvious
`
`Dr. Cooperstock’s Second Declaration
`
`APPLE-1098, ¶ 42
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`60
`
`60
`
`
`
`Issue 4C
`
`Claims 4 and 18 Are Obvious
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`61
`
`61
`
`
`
`Claims 4 and 18 Are Obvious
`
`Claim 4
`
`Claim 18
`
`APPLE-1001, 22:7-8
`
`APPLE-1001, 22:41-42
`
`Dr. Cooperstock’s First Declaration
`
`APPLE-1003, ¶ 122
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`62
`
`62
`
`
`
`Claims 4 and 18 Are Obvious
`
`Dr. Cooperstock’s First Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 119
`
`63
`
`63
`
`
`
`Claims 4 and 18 Are Obvious
`
`Patent Owner’s Response
`
`Dr. Cooperstock’s Second Declaration
`
`PO Sur-reply, 38
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶ 44
`
`64
`
`64
`
`
`
`Claims 4 and 18 Are Obvious
`
`Patent Owner’s Response
`
`PO Sur-reply, 39
`Dr. Cooperstock’s Second Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶ 45
`
`65
`
`65
`
`
`
`Issue 4D
`
`Claims 8 and 9 Are Obvious
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`66
`
`66
`
`
`
`Claims 8 and 9 Are Obvious
`
`Claims 8 and 9
`
`Dr. Cooperstock’s First Declaration
`
`APPLE-1001, 22:16-20
`
`APPLE-1003, ¶¶ 135-136
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`67
`
`67
`
`
`
`Claims 8 and 9 Are Obvious
`
`Dr. Cooperstock’s First Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶¶ 133-134
`
`68
`
`68
`
`
`
`Claims 8 and 9 Are Obvious
`
`Patent Owner’s Response
`
`Dr. Cooperstock’s Second Declaration
`
`POR, 44
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶ 49
`
`69
`
`69
`
`
`
`Claims 8 and 9 Are Obvious
`
`Patent Owner’s Response
`
`Dr. Cooperstock’s Second Declaration
`
`POR, 44
`
`APPLE-1089, ¶¶ 48, 50
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`70
`
`70
`
`
`
`Claims 8 and 9 Are Obvious
`
`Dr. Toliyat’s Deposition
`
`APPLE-1088, 90:2-14 (cited by Pet. Reply, 21)
`
`71
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`71
`
`
`
`Issue 4E
`
`Claim 17 Is Obvious
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`72
`
`72
`
`
`
`Claim 17 Is Obvious
`
`Claim 17
`
`APPLE-1001, 22:38-40
`Dr. Cooperstock’s First Declaration
`
`APPLE-1003, ¶ 155
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`73
`
`73
`
`
`
`Claim 17 Is Obvious
`
`Dr. Cooperstock’s First Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1003, ¶ 151
`
`74
`
`74
`
`
`
`Claim 17 Is Obvious
`
`Dr. Cooperstock’s First Declaration
`
`APPLE-1003, ¶ 151
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`75
`
`75
`
`
`
`Claim 17 Is Obvious
`Patent Owner’s Response
`
`Dr. Cooperstock’s Second Declaration
`
`POR, 49, 50
`
`APPLE-1089, ¶¶ 51-52
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`76
`
`76
`
`
`
`Claim 17 Is Obvious
`Patent Owner’s Response
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`POR, 51
`
`77
`
`77
`
`
`
`Claim 17 Is Obvious
`
`Dr. Cooperstock’s Second Declaration
`
`APPLE-1089, ¶ 53
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`78
`
`78
`
`
`
`Claim 17 Is Obvious
`
`Patent Owner’s Response
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`POR, 52-53
`
`79
`
`79
`
`
`
`Claim 17 Is Obvious
`Dr. Cooperstock’s Second Declaration
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`APPLE-1089, ¶ 54
`
`80
`
`80
`
`
`
`Overview of the Instituted Grounds
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`81
`
`81
`
`
`
`Overview of the Instituted Grounds
`
`Ground
`1A
`1B
`1C
`1D
`1E
`1F
`2A
`2B
`2C
`2D
`2E
`2F
`
`Claims
`1-3, 5-7, 10, 16, 19
`2
`4, 18, 19
`8, 9
`10
`17
`1-3, 5-7, 10, 16, 19
`2
`4, 18, 19
`8, 9
`10
`17
`
`Basis
`§103: Bohbot and Gundlach
`§103: Bohbot, Gundlach, and Nishikawa
`§103: Bohbot, Gundlach, and Li
`§103: Bohbot, Gundlach, and Stevinson
`§103: Bohbot, Gundlach, and Rosener
`§103: Bohbot, Gundlach, Stevinson, and Iio
`§103: Bohbot, Gundlach, and Diebel
`§103: Bohbot, Gundlach, Diebel, and Nishikawa
`§103: Bohbot, Gundlach, Diebel, and Li
`§103: Bohbot, Gundlach, Diebel, and Stevinson
`§103: Bohbot, Gundlach, Diebel, and Rosener
`§103: Bohbot, Gundlach, Diebel, Stevinson, and Iio
`Pet. 1-2; see Inst. Dec. 7-8, 41
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`82
`
`82
`
`
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