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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
`LENOVO (UNITED STATES) INC.
`Petitioner
`v.
`LITL LLC
`Patent Owner
`__________
`IPR Case No. IPR2021-00786
`U.S. Patent No. 9,880,715
`__________
`
`
`DECLARATION OF JEAN RENARD WARD IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. § 311 ET SEQ. AND 37 C.F.R. § 42.100 ET SEQ.
`(CLAIMS 1-20 OF U.S. PATENT NO. 9,880,715)
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`Lenovo EX-1007, Page 001
`IPR2021-00786 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
`(IPR2021-00786)
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`INTRODUCTION
`1. My name is Jean Renard Ward. I have been retained as a technical
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`I.
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`expert on behalf of Lenovo (United States) Inc. to provide assistance in the above-
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`captioned matter. I understand that Lenovo (United States) Inc. is the Petitioner in
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`this proceeding. I have no financial interest in or affiliation with the Petitioner or
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`the Patent Owner, which I understand is LiTL LLC. My compensation does not
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`depend upon the outcome of, or the specifics of my testimony, in this inter partes
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`review proceeding or any litigation proceedings.
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`2.
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`I have reviewed each of the following documents, regarding which I
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`am informed that some are also identified in the Petition.
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`EXHIBIT
`1001
`
`DESCRIPTION
`U.S. Pat. No. 9,880,715 ("the '715 Patent")
`
`1002
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`1003
`
`1004
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`1005
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`1006
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`1008
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`1009
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`1010
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`Prosecution History of the '715 Patent
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`JP 1994-242856 to Shimura
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`Certified English translation of JP 1994-242856 ("Shimura")
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`U.S. Pub. No. 2005/0062715 to Tsuji et al. ("Tsuji")
`
`Windows XP Home Edition: The Missing Manual (2nd
`Edition)("Pogue")
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`Curriculum Vitae of Jean Renard Ward
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`Claim Listing
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`U.S. Pub. No. 2008/0059888 to Dunko ("Dunko")
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`ii
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`Lenovo EX-1007, Page 002
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`1011
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`1012
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`1013
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`1014
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`1015
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`1016
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`1017
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`1018
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`1019
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`1020
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`1021
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`1022
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`1023
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`1024
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`1025
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`1026
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`1027
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`1028
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`1029
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`1030
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`U.S. Pub. No. 2006/0034042 to Hisano et al. ("Hisano")
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`U.S. Pub. No. 2005/0122318 to Tonouchi et al. ("Tonouchi")
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`JP 2002-258982 to Kiyoyuki
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`Certified English translation of JP 2002-258982 ("Kiyoyuki")
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`JP 1996-179851 to Shigeo
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`Certified English translation of JP 1996-179851 ("Shigeo")
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`DE 1031455A1 to Schweizer
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`Certified English translation of DE 1031455A1 ("Schweizer")
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`Clifford & Gomez, Measuring Tilt with Low-g Accelerometers
`(2005) ("Freescale")
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`U.S. Pat. No. 6,493,216 to Lin ("Lin")
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`U.S. Pat. No. 8,151,105 to Park et al. ("Park")
`
`Ride, MIT's $100 Laptop (2005) ("MIT")
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`U.S. Pat. No. 6,882,335 to Saarinen ("Saarinen")
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`Panasonic CF-19 Operating Instructions ("CF-19")
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`Panasonic CF-T8 Operating Instructions
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`Hardy, Lenovo ThinkPad X61 Tablet PC Review (2007)
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`Lenovo ThinkPad X61 Tablet Service and Troubleshooting
`Guide
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`Dell Latitude XT Tablet
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`Motion Computing M1400 Tablet PC User Guide
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`Motion Computing M1400 Tablet PC Addendum
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`iii
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`1031
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`1032
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`1033
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`1034
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`1035
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`1036
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`1037
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`1038
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`HP Compaq Tablet PC TC1100 QuickSpecs ("Compaq")
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`Sony Vaio VGN-UX280P (UX Series MicroPC) Spec Sheet
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`Declaration of Michael J. Hopkins
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`Declaration of Liliana Nunez
`
`WaybackMachine Archive of https://www.windows-help-
`central.com/show-desktop-icon-in-xp-missing.html.
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`Excerpts of Windows XP Hacks & Mods: For Dummies
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`Excerpts of Windows XP in a Nutshell (2nd Edition)
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`U.S. Pat. No. 5,559,670 (“Flint”)
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`iv
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
`(IPR2021-00786)
`
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`I understand that the application leading to U.S. Patent No. 9,880,715
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`3.
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`("the '715 Patent") was filed as U.S. Application No. 14/680,422 on April 7, 2015. I
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`also understand that this application claims priority to U.S. Provisional Application
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`No. 61/041,365, filed April 1, 2008, which I have been asked to treat as the
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`effective filing or priority date of the '715 Patent (also referred hereafter as the
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`"Critical Date").
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`EX-1008 is a copy of my current curriculum vitae ("CV").
`4.
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`5.
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`I provide consulting services doing business as Rueters-Ward Services
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`(http://ruetersward.com/). My place of business is located at 33 Forest Street,
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`Watertown MA 02472.
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`6.
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`I received an SBEE degree (combined program in Electrical
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`Engineering and Computer Science) from the Massachusetts Institute of Technology
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`as a member of the class of 1973.
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`7.
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`I am a practicing engineer. For a number of years, I have primarily
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`been doing consulting projects and contract development work under the business
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`name of Rueters-Ward Services. I have worked professionally in the general field of
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`software engineering and relevant hardware for approximately 45 years, primarily in
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`pen/touch computing, applications of public-key cryptography, and web
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`development. Many of my major projects have concerned pen/touch computing: also
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`referred to simply as pen computing. Pen computing refers to computing that makes
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`use of a pen, stylus (including a finger), or other touch-sensitive tool, and a tablet or
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`touchscreen. This is contrasted with computing that makes use of devices such as a
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`physical keyboard or physical mouse.
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`8.
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`During and immediately after my university studies, from 1973 to
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`1977, I worked at Data General Corporation on compilers and source-level
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`emulation tools for a number of programming languages.
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`9.
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`For the next approximately 17 years, I worked primarily on many
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`aspects of pen computing, both software and hardware, at a number of development
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`companies. From 1977 to 1987, I was heavily involved in the development of base
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`technology (handwriting recognition algorithms, operating firmware, user-interface
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`techniques and applications, physical display configurations, and hardware tablet
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`sensors) and three generations of pen-computing products of Pencept Inc., a
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`pioneering commercial company for pen-computing technology that I co-founded.
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`Pencept filed for and was granted a number of patents for my work during that time.
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`My contributions included developing novel techniques for gesture and handwriting
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`recognition, new paradigms for pen- and stylus-based user interfaces, two
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`generations of an applicative computer language for gesture and handwriting
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`recognition, and engineering solutions to problems with touchscreens and digitizing
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`tablets.
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`(IPR2021-00786)
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`10. While at Pencept, I participated in the re-engineering of off-the-shelf
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`commercial tablets that detected touch from an electronic stylus; the engineering
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`evaluation of off-the-shelf tablet technologies, including at least one having
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`transparent touchscreen sensors that responded both to finger touches and to touch
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`by a specialized stylus; and the design of a custom electronic tablet responsive to an
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`electromagnetic stylus.
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`11. During that time and in the years following, I authored or co-authored a
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`number of peer-reviewed articles concerning pen-computing, generative models for
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`handwriting variability, and digitizer/touchscreen technologies and error behaviors.
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`12. These articles are listed in my CV, EX-1008 to this declaration. I was
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`an invited speaker at an international research conference on handwriting
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`recognition in Montreal, Canada. I also made presentations concerning gesture input
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`for Pencept and its competitors to the Graphical Kernel System (GKS) and
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`Programmer's Hierarchical Interactive Graphics System (PHIGS) standardization
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`committees for computer graphics systems, and organized and chaired a panel
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`discussion concerning real-world problems of handwriting recognition technology at
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`another academic conference. I was also invited to visit and speak to the research
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`groups in pen computing at a number of major computer technology companies,
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`including IBM in the United States and the AEG-Telefunken Research Center in
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`Germany.
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
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`In 1989, I joined the Freestyle development group at Wang
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`13.
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`Laboratories as a Software Architect. Freestyle was a direct-manipulation pen-
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`computing system that integrated stylus- and voice-input and annotations. During
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`my tenure there, Wang filed for and later was granted U.S. and international patents
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`for my work on simulating virtual keyboard and mouse input from stylus user input
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`on a touch-sensitive tablet portable computer. In addition, I was the lead engineer for
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`Wang on a joint hardware project for a low-power, touchscreen technology using a
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`capacitive stylus for a line of highly-portable handheld computers.
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`14.
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`In 1991, at the end of Freestyle development, I joined Slate
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`Corporation, a company formed to develop pen-centric applications for both the new
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`Pen-Point (GO Corporation) and Pen Windows (Microsoft) operating systems. Both
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`of these operating systems ran on pen/tablet computers, and "convertible" tablet
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`computers that could be converted between laptop and tablet modes. In addition to
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`supporting tablet and laptop modes, the operating systems and the applications
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`supported rotation and inversion of the system display images to match the physical
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`orientation of the display e.g. portrait/landscape/inverted. This included changes to
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`the user interface presented to the user according to the display mode.
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`15. During that time, I was Slate's representative and the co-chair of a
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`number of meetings involving GO Corporation, Microsoft, and other companies
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`concerning the JOT cross-platform storage-level standard for compressed electronic
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`ink data, and was the primary author of the first draft for that standard. I made
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`presentations regarding the history of pen computing to technical groups interested
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`in the topic. I also conducted tutorials on touchscreen/pen interfaces and
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`hardware/software technology at two annual meetings of the Society for Information
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`Display, the leading engineering society for display technologies.
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`16. From approximately 1993 onward, my professional work has been
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`primarily as an independent developer and consultant in the areas of pen/touch
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`computing, applications of public-key cryptography and computer security.
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`17. Since the late 1980s, I have maintained and updated an extensive
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`library of references relating to pen-computing, touchscreens, and related technical
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`subjects. I have continually published a working annotated bibliography of these
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`references on the internet for more than 20 years. The annotated bibliography
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`currently contains well over 9000 references I have read or studied in my fields of
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`interest or encountered during my professional career. A number of the references
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`cited in this declaration, I took from my files of the references in the bibliography.
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`My annotated bibliography can be accessed here:
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`http://www.ruetersward.com/biblio.html
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`18. When the Internet became available, it was frequent that technical
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`professionals in computer-related fields began publishing their technical materials
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`on the Internet as a service to each other. As a service to those with an interest in the
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`-5-
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`(IPR2021-00786)
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`field, I began posting my bibliography with its annotations online in about the early
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`1990s, along with some additional material. In more recent years, because of my
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`professional work and because of the relation to many touchscreen applications, the
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`bibliography also includes references related to computer security, cryptography,
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`and DRM digital rights management.
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`19. The bibliography is available on my professional web site at
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`www.ruetersward.com, and on a number of mirrors. It has been my usual practice to
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`update the bibliography at irregular periods several times a year or more often, as is
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`convenient. The bibliography has been cited in refereed technical papers by others,
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`by the USPTO, and in academic degree theses such as at M.I.T.
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`20.
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`I obtained copies of many of the publications and references in the
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`course of the projects I have worked on throughout my career, others through my
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`independent reading and study. I have read the references in my bibliography
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`because of my professional work, my intellectual interest, to keep up to date with
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`developments in the field, and/or to record the history of the field.
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`21.
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`I also have a personal collection of touch screen and touch tablet
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`devices that I have acquired over the years. These include equipment from past
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`projects I have worked on, as well as other items I considered of note, including a
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`very early model portable phone with an integrated touch screen and display, a very
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`early calculator that used a mechanical touchpad for handwritten entry of arithmetic,
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`at least one model of a very early PDA with an integrated touch screen and display
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`with handwriting recognition, and various models from the early 1990's of portable
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`touchscreen computers running one or another complete touchscreen operating
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`system, including "convertible" portable computers of various designs with
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`tablet/laptop configurations and modes.
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`22. A copy of my curriculum vitae with descriptions of my education,
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`professional achievements, and qualifications is attached to this declaration as EX-
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`1008. It includes a listing of relevant industry experience, publications, and
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`presentations.
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`III. LEGAL STANDARDS AND BACKGROUND
`I am not an attorney. My knowledge of patent law is that of a lay
`23.
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`person. Accordingly, I do not offer any legal opinions. I have been informed by
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`counsel of several legal standards that govern my analysis, including those
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`discussed below. For example, a proper validity analysis includes resolving the
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`level of ordinary skill in the pertinent art, determining the scope and content of the
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`prior art, and ascertaining the differences between the claimed invention and the
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`prior art. I also understand that whether a reference was or was not among the body
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`of references described as the prior art as of a patent's priority date is a legal
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`question, so I have relied on Petitioner's attorneys to inform me as to whether or
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`-7-
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
`(IPR2021-00786)
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`not a reference is in the prior art. I address all of these factors in my declaration
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`below.
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`A.
`24.
`
`Person of Ordinary Skill in the Art
`I have been advised that the claims of a patent are reviewed from the
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`perspective of a hypothetical person of ordinary skill in the art as of the Critical
`
`Date of the '715 Patent ("POSITA"). The "art" is the field of technology to which a
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`patent is related, which, in this case, is user interfaces for portable computing
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`devices, including the user interface employed and displayed by the operating
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`system and its organization of content and functionality. I understand that the
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`purpose of using the viewpoint of the POSITA is for objectivity.
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`25. To determine the characteristics of the POSITA, I have considered the
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`prior art and the various approaches in the prior art, the types of problems
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`encountered, the solutions to those problems, the problems encountered by the
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`inventor, and the rapidity with which innovations were made. I also considered the
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`sophistication of the technology involved and the educational background and
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`experience of those actively working in the relevant field at the Critical Date. I
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`placed myself back at the Critical Date and considered the technology available at
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`the Critical Date. Based on my experience, I have an understanding of the
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`capabilities, sophistication, and ordinary creative abilities of a POSITA in the
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`relevant field. I have supervised, directed, and provided guidance to a number of
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`such persons over the course of my career.
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`26. Based on those considerations, the POSITA as of the Critical Date of
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`the '715 Patent would have had at least a Bachelor's degree in Electrical
`
`Engineering, Computer Engineering, or Computer Science, plus two to three years
`
`of work experience in designing hardware and/or software aspects of user
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`interfaces for portable computing devices the POSITA would also be familiar with
`
`designs of the user interface employed and displayed by the operating system and
`
`its organization of content and functionality Alternatively, the POSITA could have
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`received a graduate degree such as a Master's degree in the same field with at least
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`one year of work experience related to hardware and/or software design aspects of
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`the user interfaces for portable computing devices the POSITA would also be
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`familiar with designs of the user interface employed and displayed by the operating
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`system and its organization of content and functionality .
`
`27.
`
`In view of my education and experience, as summarized above and in
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`my curriculum vitae (EX-1008), I meet and exceed this definition of the POSITA,
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`and I did so at the time of the Critical Date.
`
`28.
`
`In arriving at my opinions and conclusions in this declaration, I have
`
`considered the issues from the point of view of a POSITA at the Critical Date
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`unless I explicitly state otherwise.
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`(IPR2021-00786)
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`B. Claim Construction
`29. Lenovo's Counsel has told me that terms should be given the meaning
`
`
`
`that the term would have to a POSITA in question at the Critical Date in an inter
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`partes review proceeding.
`
`30.
`
`I understand that the appropriate context in which to read a claim term
`
`includes both the specification and the claim language itself. I understand that a
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`patent may include two types of claims, independent claims and dependent claims.
`
`I understand that an independent claim stands alone and includes only the
`
`limitations it recites. I understand that a dependent claim depends from an
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`independent claim or another dependent claim. I understand that a dependent claim
`
`includes all the limitations that it recites in addition to the limitations recited in the
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`claim (or claims) from which it depends.
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`31.
`
`In comparing the Challenged Claim to the prior art, I have carefully
`
`considered the patent and its prosecution history in light of the understanding of
`
`the POSITA at the Critical Date.
`
`32.
`
`I understand that to determine how the POSITA would have
`
`understood a claim term, one should look to sources available at the Critical Date
`
`that show what the POSITA would have understood claim language to mean. It is
`
`my understanding that this may include what is called "intrinsic" evidence as well
`
`as "extrinsic" evidence.
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`I understand that, in construing a claim term, one should primarily
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`33.
`
`rely on intrinsic patent evidence, which includes the words of the claims
`
`themselves, the remainder of the patent specification, and the prosecution history. I
`
`understand that extrinsic evidence, which is evidence external to the patent and the
`
`prosecution history, may also be useful in interpreting patent claims when the
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`intrinsic evidence itself is insufficient. I understand that extrinsic evidence may
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`include principles, concepts, terms, and other resources available to the POSITA at
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`the Critical Date.
`
`C. Validity
`I understand that the Petitioner bears the burden of proving the
`34.
`
`instituted grounds of invalidity by a preponderance of the evidence. I understand
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`that "preponderance" means "more likely than not." I understand that general and
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`conclusory assertions, without underlying factual evidence, may not support a
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`conclusion that something is "more likely than not."
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`35. Rather, the "preponderance of the evidence" standard requires that a
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`reasonable finder of fact be convinced that the existence of a specific material fact
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`is more probable than the non-existence of that fact. The preponderance of the
`
`evidence standard does not support speculation regarding specific facts and is
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`instead focused on whether the evidence more likely than not demonstrates the
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`existence or non-existence of specific material facts. Here, I understand that the
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
`(IPR2021-00786)
`
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`Petitioner has argued that the claims at issue (e.g., Challenged Claims) are
`
`rendered obvious by certain prior-art references.
`
`36.
`
`I have been informed that a reference may qualify as prior art to a
`
`patent if the reference was known or used by others in this country, or patented or
`
`described in a printed publication in this or a foreign country, before the invention
`
`by the patent holder. I have also been informed that a reference may qualify as
`
`prior art to a patent if the invention was patented or described in a printed
`
`publication in this or a foreign country or in public use or on sale in this country,
`
`more than one year before the effective filing date of the patent. For a printed
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`publication to qualify as prior art, I understand that the Petitioner must demonstrate
`
`that the publication was disseminated or otherwise sufficiently accessible to the
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`public.
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`37.
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`I have further been informed that a reference may qualify as prior art
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`to a patent if the invention was described in a published application for a patent
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`filed in the United States before the invention by the applicant of the challenged
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`patent.
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`D. Obviousness
`I understand that a patent claim may be found unpatentable as obvious
`38.
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`if the Petitioner establishes by a preponderance of the evidence that, as of the priority
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`date, the subject matter of the claim, considered as a whole, would have been obvious
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
`(IPR2021-00786)
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`to a person having ordinary skill in the field of the technology (the "art") to which
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`the claimed subject matter belongs.
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`39.
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`I understand that the analysis of whether a claim is obvious depends
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`upon a number of factual inquiries, for example, (1) the scope and content of the
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`prior art; (2) the differences between the claimed subject matter and the prior art;
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`(3) the level of ordinary skill in the art; and (4) objective evidence of non-
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`obviousness.
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`40.
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`I have also been informed that the claimed invention must be
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`considered as a whole in analyzing obviousness or non-obviousness. In
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`determining the differences between the prior art and the Challenged Claim, the
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`question under the obviousness inquiry is not whether the differences themselves
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`would have been obvious, but whether the claimed invention as a whole would
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`have been obvious.
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`41. On this point, I understand that it might be appropriate to consider
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`whether there is evidence of a "teaching, suggestion, or motivation" to combine the
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`teachings in the prior art, the nature of the problem, or the knowledge of a
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`POSITA. For example, I understand that the combination of familiar elements
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`according to known methods is likely to be obvious when it does no more than
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`yield predictable results.
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`Lenovo EX-1007, Page 017
`IPR2021-00786 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
`(IPR2021-00786)
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`I have been informed and understand that a prior-art reference
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`42.
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`inherently discloses a limitation if the reference must necessarily function in
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`accordance with, or include, the limitation in the context of the patented
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`technology.
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`43.
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`I understand that one indicator of non-obviousness is when prior art
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`"teaches away" from combining certain known elements. For example, a prior art
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`reference teaches away from the patent's particular combination if it leads in a
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`different direction or discourages that combination, recommends steps that would
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`not likely lead to the patent's result, or otherwise indicates that a seemingly
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`inoperative device would be produced.
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`44.
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`I further understand that certain objective indicia can be important
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`evidence regarding whether a patent is obvious or nonobvious, including the
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`existence of a long-felt but unsolved need, unexpected results, commercial success,
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`copying, and industry acceptance or praise.
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`E. Means-Plus-Function Limitation
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`I understand that the presence of the word "means" in a claim element
`
`45.
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`creates a rebuttable presumption that the limitation should be construed as a
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`means-plus-function limitation. I have been informed that the essential inquiry for
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`a mean-plus function limitation is not the presence or absence of the word "means"
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`but whether the words of the claim are understood by persons of ordinary skill in
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`Lenovo EX-1007, Page 018
`IPR2021-00786 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
`(IPR2021-00786)
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`the art to have a sufficiently definite meaning as the name for structure. I
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`understand that a means-plus-function limitation is construed to cover the
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`corresponding structure, material, or acts described in the specification and
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`equivalents thereof.
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`46.
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`In the situation where means-plus-function claims are directed to
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`computer-implemented functionality, the specification is required to disclose an
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`algorithm corresponding to the claimed function. I have been informed that the
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`specification can express the algorithm in any understandable terms such as a
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`mathematical formula, in prose, or as a flow chart, or in any other manner that
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`provides sufficient structure.
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`47. As discussed below in ¶¶120-146, there are limitations listed below
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`that are construed using a mean-plus-function interpretation because the claim
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`language would not be understood by persons of ordinary skill in the art to have a
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`sufficiently definite meaning as the name for structure. The language in the
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`specification identifying the structure, material, or acts corresponding to each of
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`these limitations in the claim is described in greater detail below in ¶¶120-146.
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`IV. RELEVANT INFORMATION CONCERNING THE '715 PATENT
`A. Overview of the '715 Patent
`48. The '715 Patent is directed to a computer that "permit[s] the user to
`
`transition the device from one configuration to another during its use" and includes
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`Lenovo EX-1007, Page 019
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
`(IPR2021-00786)
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`"a graphical user interface that organizes interface elements into views of computer
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`content for presentation to [the] user." EX-1001, Abstract. The plurality of
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`computer system configurations include a laptop mode (e.g., FIG 1 below) where a
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`display component 102 is pivotably coupled to a base 104 that includes a keyboard
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`106. EX-1001, 19:12-31.
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`49.
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`In laptop mode, the keyboard is accessible to the user.
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`50. Other computer system configurations include an easel mode (FIG. 4
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`below) and a frame mode (FIG. 26 below). EX-1001, 19:51-52, 24:37-41.
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`Lenovo EX-1007, Page 020
`IPR2021-00786 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
`(IPR2021-00786)
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`Lenovo EX-1007, Page 021
`IPR2021-00786 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
`(IPR2021-00786)
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`In the easel and frame modes, the keyboard is "concealed and not
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`51.
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`easily accessible" to the user. EX-1001, 24:61-62. For example, in the easel
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`mode, the keyboard is "on the other side" of the portable computer from the
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`"display screen", and in the frame mode, "the keyboard [is] 'face down' on the
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`surface." EX-1001, 19:61-64, 24:37-41. In modes for which it is undesirable for
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`keys to be pressed, "software and/or hardware protection may be provided for the
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`keyboard to prevent keys from being pressed (or to prevent the portable computer
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`from responding to pressed keys)." EX-1001, 24:49-53. At the Critical Date,
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`portable computers configurable into a plurality of display modes, including the
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`laptop, easel, and frame modes, were known in the art.
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`52. The displayed content of the portable computer of the '715 Patent can
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`be rotated by 90° or 180° so that the displayed content is oriented properly for an
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`intended user. EX-1001, 20:10-15, 24:63-25:20. The 90° or 180° rotation of the
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`displayed content may be manual or automated. EX-1001, 24:63-25:20. For
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`example, in an embodiment where the rotation is automated, the portable computer
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`uses an orientation (or mode) sensor that detects whether the portable computer is
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`in a laptop mode or an easel mode and adjusts the display accordingly. EX-1001,
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`20:20-24. The orientation (or mode) sensor may be located in a hinge assembly
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`and "may be used to determine a precise relative orientation[, such as an angle,] of
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`the base component 104 with respect to the display component 102 … to determine
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`Lenovo EX-1007, Page 022
`IPR2021-00786 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 9,880,715
`(IPR2021-00786)
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`[a given display mode.]" EX-1001, 20:30-35, 70:2-6, 25-30. In some
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`embodiments, the orientation sensor may be located in a display component 102 or
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`base 104 and may include an accelerometer "whose output is fed to the computer
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`operating system (or to dedicated logic circuitry) which then triggers a display
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`inversion as appropriate." EX-1001, 20:24-26, 35-38.
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`53. The portable computer of the '715 Patent may further include a
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`processor. EX-1001, 68:14-15. "Such a processor usually executes an operating
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`system which may be, for example, the Windows-based operating systems," such
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`as "Windows XP." EX-1001, 69:13-17. "The processor and operating system
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`together define a computer platform for which application programs … are
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`written." EX-1001, 69:26-28.
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`54.
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`In addition, the '715 Patent discloses a "graphical user interface [GUI]
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`that … provides a clear overview of the entire computing environment and
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`searching capability within the environment." EX-1001, 20:62-66. The '715
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`Patent describes various views, including a "ho
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