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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. IPR2021-00822
`U.S. Patent No. 8,624,844
`__________
`
`
`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 1-16 and 18-22 OF U.S. PATENT NO. 8,624,844)
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`Lenovo EX-1010, Page 001
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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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
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`DESCRIPTION
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`1001
`1002
`1003
`1004
`1005
`1006
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`1007
`1008
`1009
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`U.S. Pat. No. 8,624,844 ("the '844 Patent")
`Prosecution History of the '844 Patent
`JP 1994-242853 to Shimura
`Certified English translation of JP 1994-242853 ("Shimura")
`U.S. Pub. No. 2005/0062715 to Tsuji et al. ("Tsuji")
`Windows XP Home Edition: The Missing Manual, 2nd Edition
`("Pogue")
`U.S. Pat. No. 6,724,365 to Escamilla et al. ("Escamilla")
`U.S. Pat. No. 6,396,419 to Yeh ("Yeh")
`U.S. Pub. No. 2007/0013682 to Lin et al. ("Lin")
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`Lenovo EX-1010, Page 002
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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`1011
`1012
`1013
`1014
`1015
`1016
`1017
`1018
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`1019
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`1020
`1021
`1022
`1023
`1024
`1025
`1026
`1027
`1028
`1029
`1030
`1031
`1032
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`Curriculum Vitae of Jean Ward
`Claim Listing
`Family Diagram of Modified Shimura Computers
`U.S. Pub. No. US 2005/0122318 to Tonouchi ("Tonouchi")
`U.S. Pat. No. 7,061,472 ("'472 Schweizer")
`Panasonic-CF-19-laptop_manual (CF-19)
`Dell Latitude XT Tablet
`Hardy, Lenovo ThinkPad X61 Tablet PC Review (2007)
`("Lenovo")
`Clifford & Gomez, Measuring Tilt with Low-g Accelerometers
`(2005) ("Freescale")
`U.S. Pub. No. 2006/0034042 to Hisano et al. ("Hisano")
`JP 2002-258982 to Kiyoyuki
`Certified English translation of JP 2002-258982 ("Kiyoyuki ")
`JP 1996-179851 to Shigeo
`Certified English translation of JP 1996-179851 ("Shigeo")
`DE 1031455A1 to Schweizer
`Certified English translation of DE 1031455A1 ("Schweizer")
`U.S. Pat. No. 6,493,216 to Lin ("Lin")
`U.S. Pat. No. 8,151,105 to Park et al. ("Park")
`Ride, MIT's $100 Laptop (2005) ("MIT")
`U.S. Pat. No. 5,559,670 to Flint et al. ("Flint")
`Panasonic CF-T8 Operating Instructions
`Motion Computing M1400 Tablet PC User Guide
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`1033
`1034
`1035
`1036
`1037
`1038
`1039
`1040
`1041
`1042
`1043
`1044
`1045
`1046
`1047
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`1048
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`1049
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`1050
`1051
`1052
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`Motion Computing M1400 Tablet PC Addendum
`HP Compaq Tablet PC TC1100 QuickSpecs ("Compaq")
`Sony Vaio VGN-UX280P (UX Series MicroPC) Spec Sheet
`U.S. Pub. No. 2006/0082554 to Caine et al. ("Caine")
`U.S. Pat. No. 5,436,954 to Nishiyama et al. ("Nishiyama")
`U.S. Pub. No. 2007/0013674 to Woolley ("Woolley ")
`JP 2001-298514 to Toba
`USPTO English translation of JP 2001-298514 ("USPTO Toba")
`EPO English translation of JP 2001-298514 ("EPO Toba")
`Intentionally left blank
`Intentionally left blank
`Intentionally left blank
`Intentionally left blank
`Intentionally left blank
`ThinkPad X61 Tablet Service and Troubleshooting Guide
`("Lenovo Service Guide")
`Microsoft Computer Dictionary Fifth Edition ("Microsoft Dic-
`tionary")
`Dell Latitude XT Quick Reference Guide ("Dell Quick Refer-
`ence")
`Dell Latitude XT User's Guide ("Dell User's Guide")
`Declaration of Michael Hopkins
`Declaration of Liliana Nunez
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`Lenovo EX-1010, Page 004
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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`I understand that the application leading to U.S. Patent No. 8,624,844
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`3.
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`("the '844 Patent") was filed as U.S. Application No. 12/170,951 on July 10, 2008.
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`This application claims priority to U.S. Provisional Application No. 61/041,365,
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`filed April 1, 2008, which I have been asked to treat as the effective filing or pri-
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`ority date of the '844 Patent (also referred hereafter as the "Critical Date").
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`EX-1011 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, Wa-
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`tertown MA 02472.
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`6.
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`I received an SBEE degree (combined program in Electrical Engineer-
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`ing and Computer Science) from the Massachusetts Institute of Technology as a
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`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
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`of software engineering and relevant hardware for approximately 45 years, pri-
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`marily in 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:
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`also referred to simply as pen computing. Pen computing refers to computing that
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`Lenovo EX-1010, Page 005
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`makes use of a pen, stylus (including a finger), or other touch-sensitive tool, and a
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`tablet or touchscreen. This is contrasted with computing that makes use of devices
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`such as a 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 emula-
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`tion 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 as-
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`pects 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 pio-
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`neering 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
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`time. My contributions included developing novel techniques for gesture and
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`handwriting recognition, new paradigms for pen- and stylus-based user interfaces,
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`two generations of an applicative computer language for gesture and handwriting
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`recognition, and engineering solutions to problems with touchscreens and digitiz-
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`ing tablets.
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`Lenovo EX-1010, Page 006
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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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 trans-
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`parent touchscreen sensors that responded both to finger touches and to touch by a
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`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
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`a number of peer-reviewed articles concerning pen-computing, generative models
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`for handwriting variability, and digitizer/touchscreen technologies and error behav-
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`iors.
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`12. These articles are listed in my CV, EX-1011 to this declaration. I was
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`an invited speaker at an international research conference on handwriting recogni-
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`tion in Montreal, Canada. I also made presentations concerning gesture input for
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`Pencept and its competitors to the Graphical Kernel System (GKS) and Program-
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`mer's Hierarchical Interactive Graphics System (PHIGS) standardization commit-
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`tees for computer graphics systems, and organized and chaired a panel discussion
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`concerning real-world problems of handwriting recognition technology at another
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`academic conference. I was also invited to visit and speak to the research groups in
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`pen computing at a number of major computer technology companies, including
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`IBM in the United States and the AEG-Telefunken Research Center in Germany.
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`Lenovo EX-1010, Page 007
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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`In 1989, I joined the Freestyle development group at Wang Laborato-
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`13.
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`ries as a Software Architect. Freestyle was a direct-manipulation pen-computing
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`system that integrated stylus- and voice-input and annotations. During my tenure
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`there, Wang filed for and later was granted U.S. and international patents for my
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`work on simulating virtual keyboard and mouse input from stylus user input on a
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`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 Corpora-
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`tion, a company formed to develop pen-centric applications for both the new Pen-
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`Point (GO Corporation) and Pen Windows (Microsoft) operating systems. Both of
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`these operating systems ran on pen/tablet computers, and "convertible" tablet com-
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`puters 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 physi-
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`cal orientation of the display e.g. portrait/landscape/inverted This included changes
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`to 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 electron-
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`Lenovo EX-1010, Page 008
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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`ic 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 hard-
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`ware/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 li-
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`brary 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 cur-
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`rently contains well over 9000 references I have read or studied in my fields of in-
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`terest 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
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`Lenovo EX-1010, Page 009
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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`the field, I began posting my bibliography with its annotations online in about the
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`early 1990s, along with some additional material. In more recent years, because of
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`my professional work and because of the relation to many touchscreen applica-
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`tions, the bibliography also includes references related to computer security, cryp-
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`tography, 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
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`to update the bibliography at irregular periods several times a year or more often,
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`as is convenient. The bibliography has been cited in refereed technical papers by
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`others, 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 be-
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`cause of my professional work, my intellectual interest, to keep up to date with de-
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`velopments 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 de-
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`vices that I have acquired over the years. These include equipment from past pro-
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`jects I have worked on, as well as other items I considered of note, including a very
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`early model portable phone with an integrated touch screen and display, a very ear-
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`ly calculator that used a mechanical touchpad for handwritten entry of arithmetic,
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
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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 sys-
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`tem, including "convertible" portable computers of various designs with tab-
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`let/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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`1011. It includes a listing of relevant industry experience, publications, and presen-
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`tations.
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`III. LEGAL STANDARDS AND BACKGROUND
`I am not an attorney. My knowledge of patent law is that of a lay per-
`23.
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`son. Accordingly, I do not offer any legal opinions. I have been informed by coun-
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`sel of several legal standards that govern my analysis, including those discussed
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`below. For example, a proper validity analysis includes resolving the level of ordi-
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`nary skill in the pertinent art, determining the scope and content of the prior art,
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`and ascertaining the differences between the claimed invention and the prior art. I
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`also understand that whether a reference was or was not among the body of refer-
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`ences described as the prior art as of a patent's priority date is a legal question, so I
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`have relied on Petitioner's attorneys to inform me as to whether or not a reference
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`is in the prior art. I address all of these factors in my declaration below.
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`Lenovo EX-1010, Page 011
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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`A.
`24.
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`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
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`Date of the '844 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 de-
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`vices, including the user interface employed and displayed by the operating system
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`and its organization of content and functionality. I understand that the purpose of
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`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 encoun-
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`tered, the solutions to those problems, the problems encountered by the inventor,
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`and the rapidity with which innovations were made. I also considered the sophisti-
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`cation of the technology involved and the educational background and experience
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`of those actively working in the relevant field at the Critical Date. I placed myself
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`back at the Critical Date and considered the technology available at the Critical
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`Date. Based on my experience, I have an understanding of the capabilities, sophis-
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`tication, and ordinary creative abilities of a POSITA in the relevant field. I have
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`supervised, directed, and provided guidance to a number of such persons over the
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`course of my career.
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`Lenovo EX-1010, Page 012
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
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`26. Based on those considerations, the POSITA as of the Critical Date of
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`the '844 Patent would have had at least a Bachelor's degree in Electrical Engineer-
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`ing, Computer Engineering, or Computer Science, plus two to three years of work
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`experience in designing hardware and/or software aspects of user interfaces for
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`portable computing devices; the POSITA would also be familiar with designs of
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`the user interface employed and displayed by the operating system and its organi-
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`zation of content and functionality. Alternatively, the POSITA could have received
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`a graduate degree such as a Master's degree in the same field with at least one year
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`of work experience related to hardware and/or software design aspects of the user
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`interfaces for portable computing devices; the POSITA would also be familiar with
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`designs of the user interface employed and displayed by the operating system and
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`its organization of content and functionality.
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`27.
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`In view of my education and experience, as summarized above and in
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`my curriculum vitae (EX-1011), I meet and exceed this definition of the POSITA,
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`and I did so at the time of the Critical Date.
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`28.
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`In arriving at my opinions and conclusions in this declaration, I have
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`considered the issues from the point of view of a POSITA at the Critical Date, un-
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`less I explicitly state otherwise.
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`B. Claim Construction
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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`29. Lenovo's Counsel has told me that terms should be given the meaning
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`that the term would have to a POSITA in question at the Critical Date in an inter
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`partes review proceeding.
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`30.
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`I understand that the appropriate context in which to read a claim term
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`includes both the specification and the claim language itself. I understand that a pa-
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`tent may include two types of claims, independent claims and dependent claims. I
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`understand that an independent claim stands alone and includes only the limitations
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`it recites. I understand that a dependent claim depends from an independent claim
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`or another dependent claim. I understand that a dependent claim includes all the
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`limitations that it recites in addition to the limitations recited in the claim (or
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`claims) from which it depends.
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`31.
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`In comparing the Challenged Claims to the prior art, I have carefully
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`considered the patent and its prosecution history in light of the understanding of
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`the POSITA at the Critical Date.
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`32.
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`I understand that to determine how the POSITA would have under-
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`stood a claim term, one should look to sources available at the Critical Date that
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`show what the POSITA would have understood claim language to mean. It is my
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`understanding that this may include what is called "intrinsic" evidence as well as
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`"extrinsic" evidence.
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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`I understand that, in construing a claim term, one should primarily re-
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`33.
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`ly on intrinsic patent evidence, which includes the words of the claims themselves,
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`the remainder of the patent specification, and the prosecution history. I understand
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`that extrinsic evidence, which is evidence external to the patent and the prosecution
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`history, may also be useful in interpreting patent claims when the intrinsic evi-
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`dence itself is insufficient. I understand that extrinsic evidence may include princi-
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`ples, concepts, terms, and other resources available to the POSITA at the Critical
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`Date.
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`C. Validity
`I understand that the Petitioner bears the burden of proving the insti-
`34.
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`tuted grounds of invalidity by a preponderance of the evidence. I understand that
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`"preponderance" means "more likely than not." I understand that general and con-
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`clusory assertions, without underlying factual evidence, may not support a conclu-
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`sion 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 evi-
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`dence standard does not support speculation regarding specific facts and is instead
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`focused on whether the evidence more likely than not demonstrates the existence
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`or non-existence of specific material facts. Here, I understand that the Petitioner
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`Lenovo EX-1010, Page 015
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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`has argued that the claims at issue (e.g., Challenged Claims) are rendered obvious
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`by certain prior-art references.
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`36.
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`I have been informed that a reference may qualify as prior art to a pa-
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`tent if the reference was known or used by others in this country, or patented or de-
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`scribed in a printed publication in this or a foreign country, before the invention by
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`the patent holder. I have also been informed that a reference may qualify as prior
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`art to a patent if the invention was patented or described in a printed publication in
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`this or a foreign country or in public use or on sale in this country, more than one
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`year before the effective filing date of the patent. For a printed publication to quali-
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`fy as prior art, I understand that the Petitioner must demonstrate that the publica-
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`tion was disseminated or otherwise sufficiently accessible to the 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 prior-
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`ity date, the subject matter of the claim, considered as a whole, would have been
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`Lenovo EX-1010, Page 016
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
`
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`obvious to a person having ordinary skill in the field of the technology (the "art")
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`to which 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 consid-
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`ered as a whole in analyzing obviousness or non-obviousness. In determining the
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`differences between the prior art and the Challenged Claims, the question under the
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`obviousness inquiry is not whether the differences themselves would have been
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`obvious, but whether the claimed invention as a whole would 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 POSI-
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`TA. For example, I understand that the combination of familiar elements accord-
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`ing to known methods is likely to be obvious when it does no more than yield pre-
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`dictable results.
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`Lenovo EX-1010, Page 017
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
`
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`I have been informed and understand that a prior-art reference inher-
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`42.
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`ently discloses a limitation if the reference must necessarily function in accordance
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`with, or include, the limitation in the context of the patented 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 dif-
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`ferent direction or discourages that combination, recommends steps that would not
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`likely lead to the patent's result, or otherwise indicates that a seemingly inoperative
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`device would be produced.
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`44.
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`I further understand that certain objective indicia can be important ev-
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`idence regarding whether a patent is obvious or nonobvious, including the exist-
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`ence 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
`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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`the art to have a sufficiently definite meaning as the name for structure. I under-
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`Lenovo EX-1010, Page 018
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
`
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`stand that a means-plus-function limitation is construed to cover the corresponding
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`structure, material, or acts described in the specification and 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 by counsel
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`that the specification can express the algorithm in any understandable terms such
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`as a 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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`IV. RELEVANT INFORMATION CONCERNING THE '844 PATENT
`A. Overview of the '844 Patent
`47. The '844 Patent is directed to a "portable computer that is configurable
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`between a plurality of display modes including a laptop mode (in which the porta-
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`ble computer has a conventional laptop appearance) and an easel mode in which
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`the base of the computer and its display component stand vertically forming an in-
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`verted 'V.'" EX-1001, Abstract. The portable computer 100 is configurable into the
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`plurality of display modes (e.g., FIGs. 1, 4, and 26, below, corresponding to a lap-
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`top mode, an easel mode, and a frame mode) based on a hinge assembly (e.g.,
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`FIGs. 7B and 10 below) rotatably coupling the display component 102 to the base
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`104 of the computer 100. EX-1001, Abstract.
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`Lenovo EX-1010, Page 019
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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`Lenovo EX-1010, Page 020
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
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`Lenovo EX-1010, Page 021
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
`
`
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`48. The displayed content of the portable computer of the '844 Patent can
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`be rotated by 180° so that the displayed content is oriented properly for an intended
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`user. EX-1001, 8:7-16, 16:27-50. The 180° rotation of the displayed content may
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`be manual or automated. EX-1001, 16:27-50. For example, in an embodiment
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`where the rotation is automated, the portable computer uses an orientation (or
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`mode) sensor that detects whether the portable computer is in a laptop mode or an
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`easel mode and adjusts the display accordingly. EX-1001, 8:17-20. The orienta-
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`tion (or mode) sensor may be located in the hinge assembly 138 and "may be used
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`to determine a precise relative orientation[, such as an angle,] of the base compo-
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`nent 104 with respect to the display component 102 . . . to determine [a given dis-
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`play mode.]" EX-1001, 8:26-31, 58-61. In some embodiments, the orientation sen-
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`sor may be located in a display component 102 or base 104 and may include an ac-
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`celerometer "whose output is fed to the computer operating system (or to dedicated
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`Lenovo EX-1010, Page 022
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
`
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`logic circuitry) which then triggers a display inversion as appropriate between the
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`two modes." EX-1001, 8:31-34.
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`49. The '844 Patent also discloses "software and/or hardware protection . .
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`. provided for the keyboard to prevent keys from being pressed (or to prevent the
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`portable computer from responding to pressed keys) when the portable computer is
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`in the frame mode." EX-1001, 16:14-17.
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`50. Moreover, the '844 Patent discloses integrated navigation hardware
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`that "allows a user to easily and comfortable [sic] control various features and
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`functions of the portable computer, and to manipulate content displayed on the
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`portable computer." EX-1001, 10:55-58. The navigation hardware may include a
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`scroll wheel, navigation buttons 166, 168, or conventional tools (e.g., touchpad
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`108, track ball, mouse, or other peripherals) to "control, adjust and/or select vari-
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`ous functionality of the portable computer." EX-1001, 10:60-61, 11:2-10, 15-19,
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`22-24, 40-44, 12:17-21. Navigation button 166 may be implemented on a side of
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`the base, and navigation button 168 may be implemented as part of the keyboard
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`106, as illustrated in FIG. 17 of the '844 Patent below.
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`Lenovo EX-1010, Page 023
`IPR2021-00822 (Lenovo Inc. v. LiTL LLC.)
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`
`
`Ward Declaration re Petition for Inter Partes Review of U.S. Patent No. 8,624,844
`(IPR2021-00822)
`
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`51.
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`In one example, navigation hardware is used to control operating pa-
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`rameters of the portable computer and content displayed on the disp
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