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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`___________________________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`GUI GLOBAL PRODUCTS, LTD.,
`Patent Owner.
`____________
`
`Case IPR2021-00470
`Patent 10,259,020
`___________________________
`
`DECLARATION OF HAMID TOLIYAT, PH.D. REGARDING APPLE’S
`
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 10,259,020
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`Apple v. GUI Global Products
`IPR2021-00470
`GUI Ex. 2001
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`Table of Contents
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`I.
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`INTRODUCTION ............................................................................................... 1
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`II. QUALIFICATIONS ............................................................................................ 2
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`III. MATERIALS CONSIDERED ......................................................................... 4
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`IV. SUMMARY OF CONCLUSIONS .................................................................. 6
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`V. LEGAL PRINCIPLES ......................................................................................... 8
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`VI. PERSON OF ORDINARY SKILL IN THE ART .........................................12
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`VII. CLAIM CONSTRUCTION ...........................................................................14
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`VIII. `OVERVIEW OF THE ’020 PATENT ..........................................................14
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`IX. GROUND 1A—Claims 1-3, 5-7, 10, 16, and 19 are not obvious in view of
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`Bohbot and Gundlach. .............................................................................................21
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`A. Overview of Bohbot .......................................................................................21
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`B. Overview of Gundlach ...................................................................................29
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`C. Dr. Cooperstock’s reasons for combining Bohbot and Gundlach are, to a
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`POSITA, unfounded and unpersuasive.................................................................41
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`D. Analysis of Claims 1-3, 5-7, 10, 16, and 19 ...................................................44
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`1. Claim 1 ........................................................................................................44
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`2. Claim 2 ...........................................................................................................71
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`3. Claim 3 ...........................................................................................................71
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`4. Claim 5 ........................................................................................................72
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`5. Claim 6 ........................................................................................................72
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`6. Claim 7 ........................................................................................................78
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`7. Claim 10 ......................................................................................................79
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`8. Claim 16 ......................................................................................................80
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`9. Claim 19 ......................................................................................................80
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`X. GROUND 1B: Claim 2 is not obvious in view of Bohbot, Gundlach, and
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`Nishikawa. ................................................................................................................81
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`A. Overview of Nishikawa ..................................................................................81
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`B. The Alleged Bohbot-Gundlach-Nishikawa Combination ..............................81
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`C. Analysis of Claim 2 ........................................................................................81
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`XI. GROUND 1C: Claims 4, 18, and 19 are not obvious in view of Bohbot,
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`Gundlach, and Li. .....................................................................................................82
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`A. Overview of Li ................................................................................................82
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`B. The Alleged Bohbot-Gundlach-Li Combination ............................................83
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`C. Analysis of Claims 4, 18, and 19 ....................................................................83
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`1. Claims 4 and 18 ...........................................................................................83
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`2. Claim 19 .........................................................................................................88
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`XII. GROUND 1D: Claims 8 and 9 are not obvious in view of Bohbot, Gundlach,
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`and Stevinson. ..........................................................................................................89
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`A. Overview of Stevinson ...................................................................................89
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`B. The Alleged Bohbot-Gundlach-Stevinson Combination ...............................92
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`C. Analysis of Claims 8 and 9 .............................................................................92
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`XIII. GROUND 1E: Claim 10 is obvious in view of Bohbot, Gundlach, and
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`Rosener. ....................................................................................................................94
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`A. Overview of Rosener ......................................................................................94
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`C. Analysis of Claim 10 ......................................................................................95
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`XIV. GROUND 1F: Claim 17 is not obvious in view of Bohbot, Gundlach,
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`Stevinson, and Iio. ....................................................................................................96
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`A. Overview of Iio ...............................................................................................96
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`B. The Alleged Bohbot-Gundlach-Stevinson-Iio Combination .......................100
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`B. Analysis of Claim 17 ....................................................................................107
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`XV. GROUND 2A: Claims 1-3, 5-7, 10, 16, and 19 are not obvious in view of
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`Bohbot, Gundlach, and Diebel. ..............................................................................109
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`A. Overview of Diebel ......................................................................................110
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`B. The Alleged Bohbot-Gundlach-Diebel Combination ..................................110
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`C. Analysis of 1[f] .............................................................................................113
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`XVI. GROUND 2B: Claim 2 is not obvious in view of Bohbot, Gundlach,
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`Diebel, and Nishikawa. ..........................................................................................115
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`XVII. GROUND 2C: Claims 4, 18, and 19 are not obvious in view of Bohbot,
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`Gundlach, Diebel, and Li. ......................................................................................116
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`XVIII. GROUND 2D: Claims 8 and 9 are not obvious based on Bohbot, Gundlach,
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`Diebel and Stevinson. ............................................................................................117
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`XIX. GROUND 2E: Claim 10 is not obvious based on Bohbot, Gundlach,
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`Diebel, and Rosener. ...........................................................................................117
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`XX. GROUND 2F: Claim 17 is not obvious based on Bohbot, Gundlach, Diebel,
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`Stevinson, and Iio. ..................................................................................................118
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`XXI. CONCLUSION .........................................................................................118
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`Apple v. GUI Global Products
`IPR2021-00470
`GUI Ex. 2001
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`I, Hamid Toliyat, of College Station, Texas, declare as follows:
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`I.
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`
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`INTRODUCTION
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`I have been retained by Beck Redden LLP on behalf of Patent Owner Gwee
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`Global Products, Inc. (“Gwee”) as an independent expert in the above referenced
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`Inter Partes Review proceeding.
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`
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`I have been asked by counsel for Gwee to address the issues raised in the
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`IPR Petition, including issues raised in its Exhibit APPLE 1003, the Declaration of
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`Dr. Jeremy Cooperstock, including whether the references relied upon by Dr.
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`Cooperstock teach or suggest the claim limitations of Claims 1-10 and 16-19 of the
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`challenged ’020 patent, U.S. Patent No. 10,259,020 (“the ’020 patent”).
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`
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`In writing this Declaration, I have considered matters including my own
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`knowledge and experience, including my teaching and work experience. Although
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`my qualifications exceed those of a POSITA for the challenged patent, my
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`statements and opinions expressed herein are so expressed from the perspective of a
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`POSITA.
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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 time spent on this matter on an hourly
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`basis. My compensation is not dependent on the outcome of these proceedings or
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`the content of my opinions.
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`II. QUALIFICATIONS
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`
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`My background and qualifications are set forth in my curriculum vitae
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`attached as Ex. 2002. In summary,
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`• I have over 35 years of experience in the field of power electronics,
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`microcontrollers, electric motors, motor control, and wireless power transfer.
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`• I received my B.S. from Sharif University of Technology in 1982, M.S.
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`degree from West Virginia University in 1986, and Ph.D. degree from the
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`University of Wisconsin-Madison in 1991, all in electrical engineering.
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`• In March 1994 I joined the Department of Electrical and Computer
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`Engineering at Texas A&M University. I am currently the Raytheon
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`endowed professor of electrical engineering.
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`• I received the Nikola Tesla Field Award for “outstanding contributions to
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`the design, analysis and control of fault-tolerant multiphase electric
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`machines” from IEEE in 2014, the Cyril Veinott Award in
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`Electromechanical Energy Conversion from the IEEE Power Engineering
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`Society in 2004, Patent and Innovation Award from Texas A&M University
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`System Office of Technology Commercialization’s in 2020, 2016 and 2007,
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`TEES Faculty Fellow Award in 2006, Distinguished Teaching Award in
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`2003, E.D. Brockett Professorship Award in 2002, Eugene Webb Faculty
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`Fellow Award in 2000, and Texas A&M Select Young Investigator Award
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`in 1999. I also received the Space Act Award from NASA in 1999, and the
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`Schlumberger Foundation Technical Awards in 2001 and 2000.
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`• I was an Editor of IEEE Transactions on Energy Conversion. I also was
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`Chair of the IEEE-IAS Industrial Power Conversion Systems Department of
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`IEEE-IAS, and am a member of Sigma Xi. I am a fellow of the IEEE, the
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`recipient of the 2008 Industrial Electronics Society Electric Machines
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`Committee Second Best Paper Award as well as the recipient of the IEEE
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`Power Engineering Society Prize Paper Awards in 1996 and 2006, and IEEE
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`Industry Applications Society Transactions Third Prize Paper Award and
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`Second Prize Paper Award in 2006 and 2016, respectively. I was the
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`General Chair of the 2005 IEEE International Electric Machines and Drives
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`Conference in San Antonio, Texas.
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`• My main research interests and experience include power electronics,
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`microcontrollers, analysis and design of electrical machines, variable speed
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`drives for traction and propulsion applications, fault diagnosis of electric
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`machinery, and sensorless variable speed drives.
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`• I have supervised more than 120 graduate students, post docs, and research
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`engineers. I have published over 520 technical papers, presented more than
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`99 invited lectures all over the world, and has 34 issued and pending U.S.
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`patents. My publications are highly cited by colleagues -- more than 27,000
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`times.
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`• I have purposely taught courses in two different areas within my department:
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`power electronics, and electric machinery. I have developed and taught three
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`new courses in the area of electromechanical motion devices. These are:
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`• ECEN 611 General Theory of Electromechanical Motion Devices, 3 credits
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`• ECEN 612 Computer Aided Design of Electromechanical Motion Devices, 4
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`credits
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`• ECEN 442/742 DSP-Based Electromechanical Motion Control, 3 credits
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`• I am also a Professional Engineer in the State of Texas.
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`III. MATERIALS CONSIDERED
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`
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`In writing this Declaration, I have considered matters including my own
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`knowledge and experience, including my teaching and work experience, which
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`includes overseeing POSITAs and persons studying to become POSITAs. I have
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`reviewed Petitioner Apple’s IPR Petition and the substantive Exhibits thereto,
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`namely Exhibits APPLE-1001 – APPLE-1030; APPLE-1034 - APPLE-1039;
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`APPLE-1042 - APPLE-1045; APPLE-1050 - APPLE-1051; APPLE-1059 -
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`APPLE-1060; and APPLE-1062 – APPLE-1068, and also the PTAB’s Institution
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`Decision. I have also reviewed the declaration of Dr. Mark Horenstein submitted in
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`the IPR proceeding involving Samsung’s challenge to this patent. I have also
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`reviewed the Board’s institution decision relative to the challenged patent. I have
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`also reviewed the transcript from Dr. Cooperstock’s deposition. I have also
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`reviewed other materials noted herein.
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`
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`The Cooperstock Declaration notes that the challenged patent was filed on
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`December 22, 2017 with a priority claim dating back to the August 5, 2011 filing
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`date of provisional application No. 61/515,752. For purposes of his Declaration,
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`Dr. Cooperstock uses August 5, 2011 as the priority date for the patent and as the
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`assumed date of invention. I am thus using August 5, 2011 as the priority date for
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`the patent and the date of invention as well.
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`
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`As part of my independent analysis, I have considered my personal
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`knowledge and experience; the knowledge of persons of ordinary skill (“POSITA”)
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`as of the invention date. My opinions are from the viewpoint of POSITA. Unless
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`otherwise stated, my testimony herein refers to the knowledge and capabilities of a
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`POSITA as of this invention date.
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`In this declaration I only address some of the statements, arguments, and
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`contentions of Apple and Dr. Cooperstock, and I only address some of the
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`challenged claim elements. This is being done primarily to focus on what appear to
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`be the main disputed issues. It should not be assumed that I agree with anything not
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`specifically addressed in this Declaration.
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`IV. SUMMARY OF CONCLUSIONS
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`
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`This Declaration states and explains the opinions/conclusions that I have
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`formed using my independent analysis. They are summarized as follows:
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`• Ground 1A: Claims 1-3, 5-7, 10, 16, and 19 are not obvious in view of Bohbot
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`and Gundlach.
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`• Ground 1B: Claim 2 is not obvious in view of Bohbot, Gundlach, and
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`Nishikawa.
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`• Ground 1C: Claims 4, 18, and 19 are not obvious in view of Bohbot,
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`Gundlach, and Li.
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` • Ground 1D: Claims 8 and 9 are not obvious in view of Bohbot, Gundlach, and
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`Stevinson.
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`• Ground 1E: Claim 10 is not obvious in view of Bohbot, Gundlach, and
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`Rosener.
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`• Ground 1F: Claim 17 is not obvious in view of Bohbot, Gundlach, Stevinson,
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`and Iio.
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`• Ground 2A: Claims 1-3, 5-7, 10, 16, and 19 are not obvious in view of Bohbot,
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`Gundlach, and Diebel.
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`• Ground 2B: Claim 2 is not obvious in view of Bohbot, Gundlach, Diebel, and
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`Nishikawa.
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`• Ground 2C: Claims 4, 18, and 19 are not obvious in view of Bohbot,
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`Gundlach, Diebel, and Li.
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`• Ground 2D: Claims 8 and 9 are not obvious in view of Bohbot, Gundlach,
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`Diebel, and Stevinson.
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`• Ground 2E: Claim 10 is not obvious in view of Bohbot, Gundlach, Diebel, and
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`Rosener.
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`• Ground 2F: Claim 17 is not obvious in view of Bohbot, Gundlach, Diebel,
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`Stevinson, and Iio.
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`V.
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`LEGAL PRINCIPLES
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`
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`I am not an attorney and have not been asked to offer any opinions on the
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`law. I understand, however, that I must follow existing law and that I am offering
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`opinions on the ultimate issue of obviousness. I have been provided with
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`information about legal principles by counsel for Gwee, specifically as follows:
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`I have been informed by counsel and understand that in an Inter Partes
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`Review proceeding, the party challenging the patent’s validity must prove by a
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`preponderance of the evidence that the patent claims are unpatentable. I have been
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`further advised that the first step in assessing validity of a patent claim is to
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`properly construe the claim at issue.
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`I have been informed by counsel and understand that Apple’s challenges to
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`the patentability of the claims of the ‘’020 Patent are ultimately based on
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`obviousness under 35 U.S.C. § 103. To be patentable under this statute, an
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`invention much be such that it would not have been obvious to a person of ordinary
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`skill in the art (“POSITA”) at the time the invention was made. That is, the
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`differences between the subject matter sought to be patented and the prior art must
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`not be such that the claimed subject matter as a whole would have been obvious to a
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`POSITA at the time the invention was made.
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`I have been informed by counsel and understand that when determining
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`whether a claimed invention is obvious, one should consider the scope and content
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`of the prior art, the level of ordinary skill in the relevant art, the differences between
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`the claimed invention and the prior art, and whether the claimed invention would
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`have been obvious to one of ordinary skill in the art in light of those differences. I
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`understand that hindsight must not be used when comparing the prior art to the
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`invention for obviousness.
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`I have been informed by counsel and understand that the scope of the prior
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`art includes analogous art, and that two separate tests define the scope of analogous
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`prior art: (1) whether the art is from the same field of endeavor, regardless of the
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`problem addressed and, (2) if the reference is not within the field of the inventor's
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`endeavor, whether the reference still is reasonably pertinent to the particular
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`problem with which the inventor is involved.
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`I have been informed by counsel and understand that obviousness may be
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`shown by demonstrating that it would have been obvious to modify what is taught
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`in a single reference to arrive at the patented invention, and/or by showing that it
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`would have been obvious to combine the teachings of more than one reference to
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`arrive at the patented invention. I recognize that in determining whether prior art
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`references would have been combined with one another and/or with other
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`information within the knowledge of one of ordinary skill in the art, multiple
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`approaches and rationales may be considered, including:
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`• Combining prior art elements according to known methods to yield predictable
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`results;
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`• Simple substitution of one known element for another to obtain predictable
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`results;
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`• Use of a known technique to improve similar devices, methods, or products in
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`the same way;
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`• Applying a known technique to a known device, method, or product ready for
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`improvement to yield predictable results;
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`• Applying a technique or approach that would have been “obvious to try”
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`(choosing from a finite number of identified, predictable solutions, with a
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`reasonable expectation of success);
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`• Known work in one field of endeavor that may prompt variations of it for use
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`in either the same field or a different one based on design incentives or other
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`market forces if the variations would have been predictable to one of ordinary
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`skill in the art; or
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`• Some teaching, suggestion, or motivation in the prior art that would have led
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`one of ordinary skill to modify the prior art reference or to combine prior art
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`reference teachings to arrive at the claimed invention.
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`I have been informed by counsel and understand that if an independent
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`claim is not obvious over a combination of references, then a claim that depends
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`from the nonobvious independent claim is likewise not obvious in view of those
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`references, because the dependent claim contains all of the limitations of the
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`independent claim plus one or more further limitations.
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`In considering the question of obviousness, I have been informed by
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`counsel and understand that the POSITA is a hypothetical person who is presumed
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`to be aware of all of the pertinent prior art. The POSITA is not an automaton and
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`may be able to combine the teachings of multiple patents or references employing
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`ordinary creativity and common sense, and that familiar items may have obvious
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`uses in another context or beyond their primary purposes. The POSITA faced with a
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`problem is able to apply his or her experience and ability to solve the problem and
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`also look to any available prior art to help solve the problem. I also recognize that it
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`is not necessary to demonstrate a precise teaching directed to the specific subject
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`matter of the challenged claim, for a fact finder can take account of the inferences
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`and creative steps that a POSITA would employ. A patent that merely claims
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`predictable uses of old elements according to their established functions to achieve
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`predictable results may be found invalid as obvious. Hence, an invention may be
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`obvious if a POSITA, facing the wide range of needs created by developments in
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`the field, would have seen an obvious benefit to the solutions tried by the applicant.
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`And, when there is a design need or market pressure to solve a problem, and there
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`are a finite number of identified, predictable solutions, it may have been obvious to
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`a POSITA to try the known options. Also, if a technique has been used to improve
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`one device, and a POSITA would have recognized that it would improve similar
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`devices in the same way, using the technique may have been obvious.
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`VI. PERSON OF ORDINARY SKILL IN THE ART
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`Dr. Cooperstock’s Declaration opines that a POSITA would have had
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`would have had at least a bachelor’s degree in an academic area emphasizing
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`electrical engineering, mechanical engineering, or a similar discipline, and at least
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`two years of experience in the field working with electronic devices. He also opines
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`that superior education could compensate for a deficiency in work experience, and
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`vice-versa. Ex. 1003, 20.
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`I note that the use of the phrase “at least” in Dr. Cooperstock’s definition of
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`a POSITA leaves the actual educational and other experience of a POSITA in doubt
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`because it encompasses someone of greater education, training, and skill than a
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`POSITA and could even include an expert in the field. As such, Dr. Cooperstock’s
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`definition of a POSITA is of questionable assistance in understanding the true
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`qualifications of the POSITA and how such a person would understand and employ
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`the teachings of the various references cited in the petition. I concur with, and adopt
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`as my own, the opinion previously expressed by Dr. Horenstein (in the declaration
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`noted above) that for purposes of evaluating claims of the challenged patent, a
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`POSITA would have been someone having either a bachelor’s degree in electrical
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`engineering, computer science, or mechanical engineering with some level of post-
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`baccalaureate electronic device or system design experience, or someone with an
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`equivalent level of experience and training through other means.
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`I agree with Dr. Cooperstock that superior education might be able to
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`compensate for a deficiency in work experience, and vice-versa.
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`Dr. Cooperstock’s definition of a POSITA is somewhat different than mine;
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`however, my opinions in this declaration would be the same regardless of whether
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`or not my description or Dr. Cooperstock’s description of a POSITA is used.
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`VII. CLAIM CONSTRUCTION
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`I do not see any expressed indication in Dr. Cooperstock’s Declaration of
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`any constructions for any claim terms. To the extent that Dr. Cooperstock has
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`implied constructions in his Declaration, they are addressed herein where relevant.
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`From the point of view of a POSITA, and based upon my review of the materials
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`noted herein, primarily the challenged patent and its prosecution history, I also
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`assigned the claim terms their plain and ordinary meanings as a POSITA would
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`have understood them in the context of the ’020 patent, unless otherwise noted
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`herein.
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`VIII. `OVERVIEW OF THE ’020 PATENT
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`Gwee has already provided a relatively brief and straightforward overview
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`of the challenged patent in its preliminary response, which I concur with and adopt
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`as my own, including as follows:
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`The ’020 Patent is entitled “APPARATUS FOR CLEANING VIEW
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`SCREENS AND LENSES AND METHOD FOR THE USE THEREOF.” The
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`presumed invention date is noted above, and the patent issued on April 16, 2019.
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`Notwithstanding the title of the patent, the ’020 claims are directed to
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`systems comprising portable switching devices and portable electronic devices, and
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`the ’020 specification describes, in addition to apparatuses for cleaning view
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`screens, systems comprising portable switching devices and portable electronic
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`devices. Independent claim 1 covers the following (with the elements labeled as
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`designated by Dr. Cooperstock):
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`1[p] A system comprising:
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`1[a] a portable switching device coupled to a portable electronic device;
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`wherein
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`1[b] the switching device and the electronic device are configured to
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`selectively couple to each other employing magnetic force from a first
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`magnet disposed within the switching device;
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`1[c] the switching device comprises a first case;
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`1[d] the electronic device comprises a second case and an electronic circuit
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`that is responsive to the switching device;
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`1[e] the electronic device comprises at least one element selected from the
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`group consisting of beveled edges, ridges, recessed areas, grooves, slots,
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`indented shapes, bumps, raised shapes, and combinations thereof;
`
`configured to correspond to complimentary surface elements on the
`
`switching device;
`
`15
`
`Apple v. GUI Global Products
`IPR2021-00470
`GUI Ex. 2001
`
`
`
`
`
`
`1[f] the portable switching device is configured to activate, deactivate or send
`
`into hibernation the portable electronic device; and
`
`1[g] when coupled, the second case functions to protect the first case.
`
`
`
`The “SUMMARY” references “a switching device for use with a portable
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`electronic device having... at least one switch that can be activated or de-activated.”
`
`Ex. 1001/3:59-65. In one embodiment, the portable electronic device can be
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`activated or deactivated by introducing a magnetic field. Id. Exemplary portable
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`magnetic switching devices in FIGs. 1-26 of the ’020 patent. In certain preferred
`
`embodiments such switching devices may be cleaning devices, but they need not be
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`cleaning devices. Ex. 1001/Abstract (“The cleaning devices may have secondary
`
`applications such as … activating or deactivating a device having a magnetic switch
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`… They may also be manufactured without a cleaning component for use with the
`
`secondary applications.”); Ex. 1001/21:24-26 (“Where such a secondary use has
`
`been disclosed, then such devices, with or without the cleaning material are also
`
`within the scope of the application.”). The disclosed switching devices have
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`functions such as activating, deactivating and hibernating electronic devices such as
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`cell phones, smartphones, tablet computers and laptop computers. For example, the
`
`magnetic switching device 2401 in FIGs. 24 and 25, i.e.,
`
`16
`
`Apple v. GUI Global Products
`IPR2021-00470
`GUI Ex. 2001
`
`
`
`
`
`
`,
`
`comprising magnets 2504 activates, deactivates or hibernates tablet computer 2400.
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`Ex. 1001/17:63-67. Another example is the doll-shaped switching device in Fig.
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`26, which is depicted as a switching device for a version of the iPad. Ex. 1001/5:47-
`
`49.
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`
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`Aspects of disclosed embodiments comprise a switching device selectively
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`coupled to the front of the portable electronic device. Ex. 1001/17:63-67
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`(“switching device (2401) is selectively coupled to the front of the portable
`
`electronic device 2402 outside of the view screen 2403.”).
`
`
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`Aspects of disclosed embodiments comprise a switching device having a
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`magnet element to activate or deactivate a magnetic switch. Ex. 1001/2:65-67. See,
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`17
`
`Apple v. GUI Global Products
`IPR2021-00470
`GUI Ex. 2001
`
`
`
`
`
`
`e.g., a round switching device 100 comprising magnet 102 (Figs 1A and 1B); a
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`square switching device 200 comprising magnet 202 in FIGs. 2A-2C; a switching
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`device 303 comprising a magnetic substrate (Fig. 3); a switching device 402 with a
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`magnet (Fig. 4); a switching device 503/503a with magnets 506 (FIGs. 5A, 5B).
`
`
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`Aspects of disclosed embodiments further comprise a case for an electronic
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`device having a magnetic switch, and in the area of the case over the magnetic
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`switch, a recessed area functions to facilitate a switching device having a magnet
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`moving past the switch in order to activate or deactivate the switch. Ex. 1001/3:125-
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`17. Examples of depicted recesses include indention 302 in Fig. 3:
`
`
`
`Ex. 1001/8:51-55, and recess 904 in Fig. 9.
`
`,
`
`18
`
`Apple v. GUI Global Products
`IPR2021-00470
`GUI Ex. 2001
`
`
`
`
`
`
`
`
`
`
`21/011:39-45. Aspects of disclosed embodiments further comprise
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`switching devices with beveled edges. Ex. 1001/18:53-54. Aspects of disclosed
`
`embodiments further comprise switching devices that may be received into a
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`groove, slot, or other indented geometrical shape to lower the profile of the
`
`switching device to facilitate closing a cover or prevent snagging a cleaning
`
`component. Ex. 1001/8:51-55; 19:2-6.
`
`
`
`Aspects of disclosed embodiments further comprise a switching device
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`including at least one ferromagnetic or ferrimagnetic material within, wherein the
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`ferromagnetic or ferrimagnetic material may function to actuate a power switch or
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`sensor that is capable of being actuated using a magnet. Ex. 1001/8:29-34; 3:54-60.
`
`
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`Aspects of disclosed embodiments further comprise a switching device that
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`activates or deactivates an electronic device by employing a magnet, the switching
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`device having a body surrounding the magnet and at least one surface non-abrasive
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`to the electronic device. Ex. 1001/3:49-55.
`
`19
`
`Apple v. GUI Global Products
`IPR2021-00470
`GUI Ex. 2001
`
`
`
`
`
`
`
`
`Aspects of disclosed embodiments further comprise methods of conserving
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`power when using a portable electronic device having a view screen and a switch
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`that can activated or de-activated by introducing a magnetic field to the switch,
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`wherein the switching device has at least one magnet and at least one surface that is
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`non-abrasive to the surface of the view screen, wherein the method includes using
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`the switching device to turn the portable electronic device off when the portable
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`electronic device is not in actual use and then on when the portable electronic
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`device is needed. Ex. 1001/4:7-17.
`
`
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`Aspects of disclosed embodiments further comprise a switching device
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`putting a tablet into hibernation mode with a single touch to the switching device as
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`compared to the multiple touches required to do the same thing using the touch pad
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`of the tablet. Ex. 1001/20:8-13.
`
`
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`Aspects of disclosed embodiments further comprise a case for an electronic
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`device having a magnetic switch, and in the area of the case over the magnetic
`
`switch, a recessed area (see above regarding recesses) that facilitates a cleaning
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`component having a magnet moving past the switch in order to activate or
`
`deactivate the switch. E
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