Oral Presentation On Behalf of
`Gesture Technology Partners, LLC
`Patent Owner
`( S e p t e m b e r 1 4 , 2 0 2 2 )
`
`Apple, Inc., et al. v. Gesture Technology Partners, LLC,
`I P R 2 0 2 1 - 0 0 9 2 3
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`Gesture Technology Partners, LLC
`Patent Owner
`( S e p t e m b e r 1 4 , 2 0 2 2 )
`
`Apple, Inc., et al. v. Gesture Technology Partners, LLC,
`I P R 2 0 2 1 - 0 0 9 2 3
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Petitioner’s Unpatentability Grounds.
`
`2
`
`© 2022, Williams Simons & Landis PLLC
`
`Paper 1, p. 6.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`’924 Patent: “Camera Based Sensing in Handheld, Mobile, Gaming or Other
`Devices”
`
`3
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 1001, Fig. 1A.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Challenged Claims
`
`4
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Asserted Prior-Art Combinations
`
`5
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`1st Combination: Mann PDA (Fig. 1) + Numazaki Compact Portable
`Information Device (Fig. 78).
`
`Ex. 1004, Fig. 1.
`
`Ex. 1005, Fig. 78.
`
`Petition, pp. 8, 15-17, and 39-42.
`PO Resp., pp. 7 and 8
`
`6
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`2nd Combination: Mann Wristwatch (Fig. 3) + Numazaki Wristwatch (Fig.
`79).
`
`Ex. 1004, Fig. 3.
`
`Ex. 1005, Fig. 79.
`
`Petition, pp. 11, 15-17, and 39-42.
`PO Resp., pp. 7 and 8
`7
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Independent Claim 1
`
`8
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Mann/Numazaki Does Not Teach/Suggest Limitation 1(e).
`
`• As the Board recognized, Petitioner does not
`rely on the “second camera” to meet this
`limitation. Paper 10, p. 15.
`• Numazaki does not teach/suggest performing
`a control function based on the output of the
`alleged “first camera.”
`• It would not have been obvious to combine
`Mann and Numazaki.
`
`P.O. Prelim. Resp., pp. 6-15.
`P.O. Resp., pp. 7-25.
`Sur-Reply, pp. 1-12.
`
`9
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Numazaki Does Not Perform a Control Function Based On The Output of a
`Camera.
`
`P.O. Prelim. Resp., pp. 7-9.
`P.O. Resp., pp. 8-10.
`Sur-Reply, pp. 1-2.
`
`10
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 1005, 11:44-56
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Petitioner Concedes that Only the Calculated Difference Image is Analyzed,
`Not the Images Obtained by the Photo-Detection Units.
`
`Paper 1, p. 15.
`
`P.O. Prelim. Resp., pp. 7-9.
`P.O. Resp., pp. 8-10.
`Sur-Reply, pp. 1-2.
`
`11
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 1005, Fig. 2.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`It would not have been obvious to combine Mann and Numazaki.
`
`• Petitioner argued three reasons for why it would have allegedly
`been obvious to combine Mann and Numazaki:
`• Anticipation of success in modifying Mann’s wristwatch.
`• Performing no-touch gestures improves the “covert nature” of Mann’s
`devices.
`• Addressing “downsides” to Mann’s touch-based control.
`• The Board found that the 2nd and 3rd arguments were insufficient to
`establish obviousness. See Paper 10, pp. 20-22.
`
`P.O. Prelim. Resp., pp. 9-15.
`P.O. Resp., pp. 10-23.
`Sur-Reply, pp. 2, 3, 5-12.
`
`12
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`It Would Not Have Been Obvious to Combine Mann and Numazaki: No
`Anticipation of Success.
`
`Paper 1, pp. 20-21.
`
`P.O. Prelim. Resp., pp. 14 and 15.
`P.O. Resp., pp. 21-23.
`
`13
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`A POSITA Would Not Anticipate Success in Combining Mann and Numazaki.
`
`• The combination of Numazaki’s gesture detection hardware and
`Mann’s second camera, into a wristwatch, presents challenging size
`and power requirements and heat dissipation issues.
`
`• 23 years later, the Apple Watch does not include the
`hardware/functionality that Petitioner (Apple) alleges would have
`been a “straightforward replacement” in 1999.
`
`P.O. Resp., pp. 21-23.
`
`14
`
`Paper 1, pp. 20-21.
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Petitioner’s Expert Does Not Rebut Patent Owner’s Opinion that Mann and
`Numazaki Would Present Serious Size, Heat, and Power Issues.
`
`Ex. 1018.
`
`P.O. Resp., pp. 21-23.
`
`15
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 2002, ¶64.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`It Would Not Have Been Obvious to Combine Mann and Numazaki: No-
`Touch Gestures Would Not Improve the “Covert Nature” of Mann.
`
`P.O. Prelim. Resp., pp. 9-11.
`P.O. Resp., pp. 10-15.
`Sur-Reply, pp. 2-4.
`
`16
`
`© 2022, Williams Simons & Landis PLLC
`
`Paper 1, p. 22.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`It Would Not Have Been Obvious to Combine Mann and Numazaki: No-
`Touch Gestures Would Not Improve the “Covert Nature” of Mann.
`
`P.O. Resp., pp. 10-15.
`Sur-Reply, pp. 2-4.
`
`17
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 2002, ¶49.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`The Board Recognized that No-Touch Gestures Would Not Improve the
`“Covert Nature” of Mann.
`
`P.O. Resp., pp. 10-15.
`Sur-Reply, pp. 2-4.
`
`18
`
`© 2022, Williams Simons & Landis PLLC
`
`Paper 10, p. 20.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`It Would Not Have Been Obvious to Combine Mann and Numazaki: The
`Alleged “Downsides” to Mann Do Not Exist.
`
`P.O. Prelim. Resp., pp. 10-14.
`P.O. Resp., pp. 13-18.
`
`19
`
`Paper 1, pp. 22-23.
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Mann Expressly States that Obstructing the Watch Face is not an Issue.
`
`Ex. 1004, p. 18.
`
`P.O. Prelim. Resp., p. 11.
`P.O. Resp., p. 13.
`
`20
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Mann’s “User-Facing Camera” is Physically Separate from the “Display
`Unit,” so Touch-Based Gestures Would Not Dirty the “User-Facing Camera.”
`
`P.O. Prelim. Resp., pp. 10-14.
`P.O. Resp., pp. 13-18.
`
`21
`
`Ex. 1004, Fig. 3 (annotated).
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`The Board Recognized that the Alleged “Downsides” to Mann Do Not Exist.
`
`P.O. Prelim. Resp., pp. 10-14.
`P.O. Resp., pp. 13-18.
`
`22
`
`© 2022, Williams Simons & Landis PLLC
`
`Paper 10, pp. 21-22.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Dependent Claim 2
`
`23
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Petitioner’s Sole Basis to Argue that Mann’s PDA is a Mobile Phone is a
`Generic Reference to “Communications System 176.”
`
`P.O. Resp., pp. 25-29.
`Sur-Reply, pp. 13 and 14.
`
`24
`
`© 2022, Williams Simons & Landis PLLC
`
`Paper 1, p. 43.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`“Communications System 176” Provides a Data Connection to the Internet
`Via Packet Radio, Not Mobile Telephony.
`
`P.O. Resp., pp. 25-29.
`Sur-Reply, pp. 13 and 14.
`
`25
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 1004, p. 15.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Packet Radio Provides a Data Connection to the Internet, Not Mobile
`Telephony.
`
`P.O. Resp., pp. 25-29.
`Sur-Reply, pp. 13 and 14.
`
`26
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 2002, ¶75.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Mann’s PDA Is Not a Mobile Phone.
`
`• Mann discloses no telephone-related functionality for the PDA.
`• Petitioner provides no rebuttal argument in its Reply.
`
`P.O. Resp., pp. 25-29.
`Sur-Reply, pp. 13 and 14.
`
`27
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Petitioner Argues that Mann’s “Wristwatch Videotelephone” is a Mobile
`Phone.
`
`P.O. Resp., pp. 25-29.
`Sur-Reply, pp. 13 and 14.
`
`28
`
`© 2022, Williams Simons & Landis PLLC
`
`Paper 1, p. 42.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Providing a “Mobile Phone” in Mann’s Wristwatch Would be Contrary to the
`Purpose of Mann: Providing a Covert Recording Device.
`• Mann’s wristwatch is designed to “truly look[] like an ordinary wristwatch.”
`Ex. 1004, p. 17.
`• Petitioner acknowledges that “Mann expressly teaches that remaining covert
`and avoiding attention from the subject are goals of [Mann’s] invention.”
`Pet., p. 22
`• Having the wristwatch output the audio of a telephone call would only draw
`attention to both the user and the wristwatch.
`• That is why, unlike a mobile phone, Mann’s wristwatch outputs only text
`from the “remote expert,” not audio. Ex. 1004, p. 13
`
`P.O. Resp., pp. 25-29.
`Sur-Reply, pp. 13 and 14.
`
`29
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`The Watch Face of Mann is Used for Data Entry, Not Making Mobile Phone
`Calls.
`
`P.O. Resp., pp. 25-29.
`Sur-Reply, pp. 13 and 14.
`
`30
`
`© 2022, Williams Simons & Landis PLLC
`
`Ex. 1004, p. 18.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
`
`Thank you.
`
`31
`
`© 2022, Williams Simons & Landis PLLC
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Exhibit 2003
`Apple, Inc., et al. v. GTP, LLC
`IPR2021-00923
`
`
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