Oral Presentation On Behalf of
`Gesture Technology Partners, LLC
`Patent Owner
`( S e p t e m b e r 1 3 , 2 0 2 2 )
`
`Apple, Inc., et al. v. Gesture Technology Partners, LLC,
`I P R 2 0 2 1 - 0 0 9 2 2
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`Gesture Technology Partners, LLC
`Patent Owner
`( S e p t e m b e r 1 3 , 2 0 2 2 )
`
`Apple, Inc., et al. v. Gesture Technology Partners, LLC,
`I P R 2 0 2 1 - 0 0 9 2 2
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Petitioner’s Unpatentability Grounds.
`
`2
`
`© 2022, Williams Simons & Landis PLLC
`
`Paper 1 at 5.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`’079 Patent: “More Useful Man Machine Interfaces and Applications”
`
`3
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 1001, Fig. 2.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Challenged Claims
`
`4
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Challenged Claims
`
`5
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Challenged Claims
`
`6
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Independent Claims 1, 11, and 21
`
`7
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Numazaki Does Not Teach/Suggest Limitation 1[b].
`
`•
`
`•
`
`Petitioner improperly relies on the disclosure
`of Figure 2 as being incorporated into the
`eighth embodiment depicted in Figure 74.
`Petitioner improperly attempts to rewrite the
`language of Numazaki.
`
`P.O. Resp., pp. 8-13.
`Sur-Reply, pp. 1-5.
`
`8
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Numazaki Uses Different Terms to Describe the “Photo-Detection Sensor
`Unit” in Figure 74 and the “Reflected Light Extraction Unit” in Figure 2.
`
`Ex. 1003, Fig. 74.
`
`Ex. 1003, Fig. 2.
`
`P.O. Resp., pp. 8-13.
`Sur-Reply, pp. 1-5.
`
`9
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Petitioner’s Attempt to Rewrite Numazaki is Nonsensical.
`
`• Under Petitioner’s logic, each “unit” in
`Numazaki that includes a sensor should
`include the word “sensor” in its name, but
`Numazaki does not.
`Petitioner argues “photo-detection units 109
`and 110 are sensors,” but neither includes the
`word “sensor” in its name.
`
`•
`
`Paper 17, p. 8
`
`Paper 17, p. 10.
`
`Sur-Reply, pp. 1-3.
`
`10
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Numazaki Does Not Teach/Suggest Limitations 1[b], 11[b], and 21[a].
`
`• Numazaki does not disclose a camera.
`• Numazaki does not disclose obtaining an
`image.
`• Even if “reflected light extraction unit 102” is
`a camera, it is not included in the eighth
`embodiment of Numazaki.
`
`11
`
`© 2022, Williams Simons & Landis PLLC
`
`P.O. Resp., pp. 8-13 and 16-18.
`Sur-Reply, pp. 1-5.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Petitioner’s Sole Support Does Not Disclose a Camera Obtaining an Image.
`
`P.O. Resp., pp. 8-13 and 16-19.
`
`12
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 1003, 50:25-43.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Numazaki Does Not Teach/Suggest Limitations 1[b], 11[b], and 21[c].
`
`•
`
`• Claim requires that:
`•
`The “camera” obtain an image of a human body
`part using light from a light source that
`illuminates the object.
`The processor determines the gesture based on the
`camera output.
`• Neither alleged “camera” in Numazaki meets
`the claim language:
`•
`Photo-detection unit 109 – Output not used to
`determine gesture.
`Photo-detection unit 110 – Does not observe
`gestures illuminated by a light source.
`
`•
`
`P.O. Prelim. Resp., pp. 6-8, 12-14, 16, and 17.
`P.O. Resp., pp. 8-13 and 16-19.
`Sur-Reply, pp. 3-5.
`
`13
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Petitioner Alleges that Photo-Detection Unit 109 and Photo-Detection Unit
`110 Are “Cameras.”
`
`P.O. Prelim. Resp., pp. 6-8.
`P.O. Resp., pp. 10-13.
`Sur-Reply, pp. 3-5.
`
`14
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 1003, Fig. 2.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`The Output of Photo-Detection Unit 109 is Not Used to Determine a Gesture.
`
`Ex. 1003, 11:53-56.
`
`Ex. 1003, 10:57-66.
`
`P.O. Resp., pp. 10-13.
`Sur-Reply, pp. 3-5.
`
`15
`
`Ex. 1003, Fig. 2.
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Lighting Unit 101 is Off When Photo-Detection Unit 110 is Active.
`
`Ex. 1003, 11:26-32.
`
`P.O. Prelim. Resp., pp. 6-8.
`P.O. Resp., pp. 11-13.
`Sur-Reply, pp. 3-5.
`
`16
`
`Ex. 1003, Fig. 2.
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Dependent Claims 3, 15, and 23
`
`17
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Numazaki/Numazaki ’863 Does Not Teach/Suggest Dependent Claims 3, 15,
`and 23.
`
`•
`
`• Claims require that the plurality (not just a
`single LED) illuminate the gesture.
`Petitioner concedes that Numazaki does not
`teach/suggest a plurality of LEDs.
`• The LEDs in Numazaki ’863’s range finder
`are sequentially driven, one at a time.
`
`P.O. Resp., pp. 6-8 and 20-22.
`Sur-Reply, pp. 9-11.
`
`18
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`The Plain Language of the Claims Requires That the Plurality of LEDs
`Illuminate the Gesture.
`
`• The “light source” includes a plurality of
`LEDs, so the plurality of LEDs must
`illuminate the gesture.
`• Claim 2 requires only “a light emitting
`diode” (i.e., one or more LEDs), unlike claim
`3.
`
`P.O. Resp., pp. 6-8 and 20-22.
`Sur-Reply, pp. 9-11.
`
`19
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Illuminating the Gesture with the Plurality of LEDs Increases the Accuracy of
`Gesture Recognition, Consistent with the Specification.
`
`Ex. 1001, 3:1-3.
`
`P.O. Resp., pp. 6-8 and 20-22.
`Sur-Reply, pp. 9-11.
`
`20
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 2002, ¶41.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`The Petition Argues That it Would Have Been Obvious to Modify Numazaki
`with the Rangefinder “LED Array” in Numazaki ’863.
`
`P.O. Resp., pp. 6-8 and 20-22.
`Sur-Reply, pp. 9-11.
`
`21
`
`© 2022, Williams Simons & Landis PLLC
`
`Paper 1, p. 40.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`The LEDs in Numazaki ’863’s Rangefinder “LED Array” Are Sequentially
`Driven, One at a Time.
`
`Ex. 1005, 16:45-53.
`
`P.O. Resp., pp. 6-8 and 20-22.
`Sur-Reply, pp. 9-11.
`
`22
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 1005, Fig. 4.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Dependent Claims 7, 17, and 27
`
`23
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Numazaki Does Not Teach/Suggest Dependent Claims 7, 17, and 27.
`
`• Claims require a target positioned on the user.
`• Numazaki expressly teaches away from a
`target positioned on the user.
`
`P.O. Prelim. Resp., pp. 10, 11, 15, 16, 18, and 19.
`P.O. Resp., pp. 13-20.
`Sur-Reply, pp. 6-9.
`
`24
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Prior Art Does Not Render a Claim Obvious When it Teaches Away.
`
`•
`
`•
`
`“A reference may be said to teach away when a person of ordinary skill, upon reading the
`reference, would be discouraged from following the path set out in the reference, or would
`be led in a direction divergent from the path that was taken by the applicant.”
`Galderma Labs., L.P. v. Tolmar, Inc., 737 F.3d 731, 738 (Fed. Cir. 2013).
`
`“[I]f [the first reference] did in fact teach away from [the second reference], then that
`finding alone can defeat [Defendant’s] obviousness claim.”
`Winner Intern. Royalty Corp. v. Wang, 202 F.3d 1340, 1349-50 (Fed. Cir. 2000).
`
`P.O. Prelim. Resp., p. 10.
`P.O. Resp., pp. 13 and 14.
`Sur-Reply, pp. 6, 7, and 8.
`
`25
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Numazaki Expressly Teaches Away From a Target Positioned on the User.
`
`P.O. Prelim. Resp., pp. 10, 11, 15, 16, 18, and 19.
`P.O. Resp., pp. 13-20.
`Sur-Reply, pp. 6-9.
`
`26
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 1004, 3:26-39.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
`
`Thank you.
`
`27
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00922
`
`
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