`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`GOOGLE LLC,
`
`Petitioner,
`
`v.
`
`NEONODE SMARTPHONE LLC,
`
`Patent Owner.
`
`_________________
`
`Case No. IPR2021-01041
`U.S. Patent No. 8,095,879
`
`____________________
`
`
`SECOND DECLARATION OF JACOB O. WOBBROCK, PH.D.
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`GOOGLE EXHIBIT 1032
`GOOGLE v. NEONODE
`IPR2021-01041
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`Page 1 of 22
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`Declaration of Jacob O. Wobbrock, Ph.D.
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`IPR2021-01041
`U.S. Patent No. 8,095,879
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`TABLE OF CONTENTS
`
`I.
`INTRODUCTION ........................................................................................... 3
`II. QUALIFICATIONS ........................................................................................ 5
`III. MATERIALS CONSIDERED ........................................................................ 5
`IV. LEGAL STANDARDS ................................................................................... 7
`V.
`LEVEL OF ORDINARY SKILL IN THE ART ............................................. 7
`VI. ROBERTSON’S REFERENCE TO A “DESKTOP” IS USED IN ITS
`ORDINARY MEANING TO REFER TO THE USER INTERFACE
`DISPLAYED ON-SCREEN, NOT A PHYSICAL COMPUTER .................. 7
`VII. DR. ROSENBERG IS INCORRECT THAT X WINDOWS WAS
`INCOMPATIBLE WITH MOBILE DEVICES ............................................19
`VIII. CONCLUSION ..............................................................................................22
`
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`2
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`Declaration of Jacob O. Wobbrock, Ph.D.
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`IPR2021-01041
`U.S. Patent No. 8,095,879
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`I.
`
`INTRODUCTION
`I have been retained by Google LLC (“Google”) as an independent
`1.
`
`expert consultant in this proceeding before the United States Patent and Trademark
`
`Office.
`
`2.
`
`I am over 21 years of age and, if I am called upon to do so, I would be
`
`competent to testify as to the matters set forth herein.
`
`3. My compensation is in no way contingent on the nature of my
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`findings, the presentation of my findings in testimony, or the outcome of any
`
`proceeding.
`
`4.
`
`I previously provided a declaration in this proceeding as Ex-1003.
`
`My CV was previously submitted as Ex-1004.
`
`5.
`
`I have been asked to provide this supplemental declaration in response
`
`to a single issue raised in Dr. Rosenberg’s second declaration (Ex-2019): Dr.
`
`Rosenberg’s assertion that the Robertson reference (Ex-1005) is directed to a
`
`desktop computer. E.g., Ex-2019, ¶¶60-63, 66, 68, 116-120, 124. It is not. As is
`
`clearly shown by the language of Robertson itself, contemporaneous computer
`
`dictionaries, and numerous contemporaneous references, the term “desktop” in
`
`Robertson has its ordinary meaning to a person of ordinary skill in the art in the
`
`field of user interface design, which refers to the on-screen desktop user interface
`
`metaphor, not a desktop computer hardware configuration. Hardware
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`configurations are most often referred to using the phrases “desktop computer” or
`
`“desktop PC.” Robertson’s use of the term “desktop,” for example, in the phrases
`
`“a desktop,” “the desktop,” or “desktop objects,” as I explained in my previous
`
`declaration and confirmed below, would have been understood by persons of
`
`ordinary skill in the art to pertain to mobile handheld computer devices, such as
`
`laptop computers and PDAs, because such computer devices also employed the
`
`desktop user interface metaphor.
`
`6. While I disagree with many positions expressed by Dr. Rosenberg in
`
`his second declaration, I have not been asked to opine on those disagreements here.
`
`7.
`
`Robertson uses the term “desktop” in the conventional way of
`
`referring to the well-known desktop user interface metaphor. This is confirmed by
`
`at least two contemporaneous computer dictionary definitions of “desktop.” It is
`
`also confirmed by numerous references to “desktop” for mobile handheld
`
`computer devices, such as the HP 620LX palmtop device and the NEC MobilePro
`
`device, which were small portable touchscreen devices that included a desktop user
`
`interface, such as described in Robertson. Moreover, laptop computers generally
`
`used the same operating systems as desktop-hardware computers, and the ’879
`
`patent describes laptops as mobile handheld computer devices.
`
`8.
`
`As such, it is my opinion that Dr. Rosenberg’s testimony is wrong to
`
`limit Robertson’s use of “desktop” to only refer to desktop hardware
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`configurations (i.e., “desktop PCs” or “desktop computers”) because there is no
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`support for his conclusions in the Robertson reference, the ’879 patent, or
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`contemporaneous documents that I have considered.
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`9.
`
`Throughout this declaration, I refer to specific pages, figures, and/or
`
`line numbers of various exhibits. These citations are illustrative and are not
`
`intended to suggest that they are the only support for the propositions for which
`
`they are cited.
`
`II. QUALIFICATIONS
`10. My qualifications have been provided in my prior declaration.
`
`Ex-1003, ¶¶7-30.
`
`III. MATERIALS CONSIDERED
`In forming my opinions, I have reviewed my prior declaration, the
`11.
`
`following additional documents, and any other document cited in this declaration
`
`or my previous declaration:
`
`Exhibit
`Ex-2019
`Ex-1033
`
`Ex-1034
`
`Description
`Second Declaration of Craig C. Rosenberg
`
`Excerpt from Newton’s Telecom Dictionary (CMP Books 17th ed.
`2001) (definition of “desktop”)
`
`Excerpt from Barron’s Dictionary of Computer and Internet Terms
`(Barron’s Educational Series, Inc. 7th ed. 2000) (definition of
`“desktop”)
`
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`Exhibit
`Ex-1035
`
`Ex-1036
`
`Ex-1037
`
`Ex-1038
`Ex-1039
`
`Ex-1040
`
`Ex-1041
`
`Description
`HP 620LX/660LX Palmtop User Guide (Hewlett Packard 1st ed.
`May 1998)
`
`NEC MobilePro 790 User’s Guide (NEC Computers Inc. March
`2001)
`
`Excerpts from IBM ThinkPad 760E, 760ED, or 769EL User’s Guide
`(International Business Machines Corp. September 1996)
`
`Introducing Microsoft Windows 95 (Microsoft Corp. 1995)
`
`Mohan Rajagopalan et al., Profile-Directed Optimization of Event-
`Based Programs, Proceedings of the ACM SIGPLAN 2002
`Conference on Programming Language Design and Implementation
`(PLDI’02), June 17-19, 2002, pp. 106-116 (ACM 2002)
`
`William R. Hamburgen et al., Itsy: Stretching the Bounds of Mobile
`Computing, Computer, Vol. 34, No. 4, pp. 28-36 (IEEE April 2001)
`
`Noboru Kamijoh et al., Energy trade-offs in the IBM Wristwatch
`computer, Proceedings of the Fifth International Symposium on
`Wearable Computers, October 8-9, 2001, pp. 133-140 (IEEE 2001)
`
`Ex-1042
`
`Excerpts from PowerBook Getting Started (Apple Computer, Inc.
`1994)
`
`
`
`12.
`
`I have also relied on my education, experience, research, training, and
`
`knowledge in the relevant art, and my understanding of any applicable legal
`
`principles described in this declaration.
`
`13. All of the opinions contained in this declaration are based on the
`
`documents I reviewed and my knowledge and professional judgment. My opinions
`
`have also been guided by my understanding of how a person of ordinary skill in the
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`art would have understood the claims of the ’879 patent at the time of the alleged
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`invention. For purposes of this declaration, I have been asked to assume that the
`
`date of the alleged invention is the earliest claimed priority date (in this case, the
`
`filing date of the ’879 patent): December 10, 2002.
`
`14.
`
`I reserve the right to supplement and amend any of my opinions in
`
`this declaration based on documents, testimony, and other information that
`
`becomes available to me after the date of this declaration.
`
`IV. LEGAL STANDARDS
`15. My understanding of the relevant legal standards is set forth in my
`
`previous declaration. Ex-1003, ¶¶35-46.
`
`V. LEVEL OF ORDINARY SKILL IN THE ART
`16. My understanding of the level of ordinary skill in the art is set forth in
`
`my previous declaration. Ex-1003, ¶¶47-51. I have applied the same level of
`
`ordinary skill in considering my opinions in this declaration.
`
`VI. ROBERTSON’S REFERENCE TO A “DESKTOP” IS USED IN ITS
`ORDINARY MEANING TO REFER TO THE USER INTERFACE
`DISPLAYED ON-SCREEN, NOT A PHYSICAL COMPUTER
`I have considered Dr. Rosenberg’s second declaration and, in my
`17.
`
`opinion, he is incorrect to state, or even suggest, that Robertson’s use of “desktop”
`
`refers solely to desktop computer systems, like desktop PCs, rather than mobile
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`handheld computer units, such as laptop computers, PDAs, or other mobile
`
`handheld computer devices.
`
`18. Although Robertson uses the term “desktop” many times, in every
`
`instance it is used to refer to the on-screen user interface, not a physical computer
`
`system. A person of ordinary skill in the art would have understood that
`
`Robertson’s “desktop” references refer to the commonly used desktop metaphor
`
`for graphical user interfaces. For example, Robertson says, “For current window
`
`systems like X [12], this means that the user must perceive the buttons to be at the
`
`same level as windows, icons, and menus on the desktop.” Ex-1005, § 1 (emphasis
`
`added). Windows, icons, and menus were core user interface components of the
`
`desktop user interface metaphor. In this convention, the “desktop” is the on-screen
`
`user interface that displays objects, such as folders, documents, buttons, and icons,
`
`that a user can interact with. Two of the most well-known desktop interfaces in the
`
`1990s and early 2000s included the Microsoft Windows desktop user interface and
`
`the Mac OS desktop user interface, which were implemented on laptop computer
`
`systems and mobile handheld systems, as discussed below. As I explain in my
`
`previous declaration, Robertson does not describe the specific hardware on which
`
`its user interface is implemented. Rather, Robertson describes and relates to user
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`interface techniques, including touch-screen gesture activations (e.g., pen-based
`
`gestures) that a person of ordinary skill in the art would have understood apply to
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`many types of computing devices, including mobile handheld computer units, such
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`as laptop computers, PDAs, and mobile phones. Ex-1003, ¶¶64-68, 80-96.
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`19. As just a few examples, Robertson’s Abstract explains that the paper
`
`describes a “user interface toolkit … to support on-screen buttons … on an X
`
`window system desktop.” Ex-1005, Abstract (emphasis added). In Section 1.1
`
`(page 36), Robertson explains that the “buttons” are “desktop objects” and thus
`
`referred to as “Desktop Buttons.” Ex-1005, § 1.1. These references to “desktop”
`
`must refer to the user interface desktop screen because the buttons displayed are
`
`on-screen, and do not refer to a hardware desktop system or any hardware buttons
`
`at all. Similarly, in Section 2.1, Robertson explains that “the ‘desktop’ is a 3D
`
`Rooms world,” which describes the on-screen user interface because the “3D
`
`Rooms” concept does not refer to a machine, but rather an on-screen user interface
`
`for different types of hardware. Ex-1005, § 2.1. All of Robertson’s other uses of
`
`“desktop” are similar and refer to any on-screen user interface that employs the
`
`desktop user interface metaphor, not a desktop computer system or desktop PC.
`
`20. Robertson’s explanations of his user interface technique being a new
`
`type of on-screen button make clear to a person of ordinary skill in the art that the
`
`“desktop” refers to the X window desktop user interface, which is the on-screen
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`user interface, as shown in each of Robertson’s figures, none of which show
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`particular desktop computer hardware configurations.
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`21. This understanding is confirmed by the ordinary use of “desktop” in
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`human-computer interaction and graphical user interface design, including in two
`
`well-known dictionaries. First, Newton’s Telecom Dictionary from 2001 defines
`
`“Desktop” as:
`
`The computer’s working environment. The screen layout,
`the menu bar, and the program icons associated with the
`machine’s operating environment.
`
`Ex-1033, 202 (exhibit p. 4). Similarly, Barron’s Dictionary of Computer and
`
`Internet Terms from 2000 defines “desktop” as:
`
`[T]he whole computer screen, representing your
`workspace.
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`Ex-1034, 127 (exhibit p. 5). Barron’s goes on to explain that the user can
`
`“manipulate objects (ICONS) with the mouse in much the same way as you work
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`with papers and other objects on your physical desktop.” Ex-1034, 127 (exhibit
`
`p. 5). Indeed, Barron’s Figure 73 shows an example Windows 95 desktop, which is
`
`solely the on-screen user interface. Ex-1034, 128 (exhibit p. 6). A person of
`
`ordinary skill in the art would have understood clearly that the “desktop” is the
`
`user interface screen for various hardware systems, including laptop computers and
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`smaller mobile handheld devices. The fact that these two computer dictionaries
`
`define “desktop” as the on-screen user interface, irrespective of the type of
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`hardware that user interface is being shown on, confirms the person of ordinary
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`skill in the art’s understanding from reading Robertson that the term “desktop”
`
`does not refer to computer hardware, but rather the user interface on various types
`
`of systems.
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`22. The person of ordinary skill in the art’s understanding that Robertson
`
`refers to on-screen desktop user interfaces is further confirmed by numerous small
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`form factor devices that include pen-based touchscreens and that also refer to those
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`on-screen user interfaces as the “desktop.” A few examples include the HP 620LX
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`palmtop device (Ex-1035) and the NEC MobilePro device (Ex-1036).
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`23. The HP 620LX Palmtop PC mobile handheld computer unit is shown
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`below and includes a touchscreen display that is activated by a stylus.
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`Ex-1035, 3 (exhibit p. 13). The HP 620LX uses the Windows CE operating system,
`
`which is “very much like Windows 95 … on a desktop PC.” Ex-1035, 15 (exhibit
`
`p. 25). In particular the “Windows CE screens include familiar elements like the
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`Start button, desktop, taskbar, menu bars, toolbars, and shortcuts,” with an example
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`of the desktop being shown below. Ex-1035, 15 (exhibit p. 25) (emphasis added).
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`Ex-1035, 15 (exhibit p. 25). This disclosure confirms that the common use of
`
`“desktop” in the art to refer to the on-screen user interface, even for small mobile
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`handheld devices, as would have been understood for Robertson. The HP 620LX
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`allows the user to change the “Background of the Windows CE Desktop,” again
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`referring to the on-screen user interface of the HP 620LX, by interacting with the
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`touchscreen, such as tapping the screen or using the sliders. Ex-1035, 21-22
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`(exhibit pp. 31-32). The user can interact with various icons, buttons, and features
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`of the touchscreen showing the desktop display, for example, to open programs
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`such as Microsoft Word on the HP 620LX. Ex-1035, 67 (“Double-tap the Pocket
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`Word or Pocket Excel icon on the desktop” to open Pocket Word or Pocket Excel),
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`63 (“Double-tap the Tasks icon on the desktop”), 148 (same for opening “Inbox”
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`and “Pocket Internet Explorer” on HP 620LX) (exhibit pp. 77, 73, 158). The user
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`can even create “shortcuts” on the HP 620LX “palmtop PC desktop” screen.
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`Ex-1035, 125 (exhibit p. 135). Notably, the HP 620LX also supports gestures on
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`the touchscreen, such as “drag” gestures, to perform actions such as selecting
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`words, setting clocks, or moving appointments. Ex-1035, 9, 11, 57, 71 (exhibit
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`pp. 19, 21, 67, 81). Notably, where the HP 620LX specifically refers to a hardware
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`desktop computer, it uses the term “desktop computer,” which confirms the person
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`of ordinary skill in the art’s understanding of the general term “desktop” as the on-
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`screen user interface of the HP 620LX. Ex-1035, 12 (exhibit p. 22) (emphasis
`
`added).
`
`24. The NEC MobilePro 790 is another mobile “handheld personal
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`computer” that is a mobile handheld computer unit having a touchscreen interface,
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`as shown below.
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`Ex-1036, cover (exhibit p. 1).
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`Ex-1036, 1-4; see also 3-2 to 3-3 (describing touchscreen actions) (exhibit pp. 11,
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`50-51). The NEC MobilePro 790 manual also identifies the on-screen user
`
`interface shown on the touchscreen as the “desktop.” In fact, the NEC MobilePro
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`790 manual describes the “Windows CE Desktop” as “very similar to Windows
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`95” but for the screen of the MoblePro 790 because:
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`Windows CE includes a desktop with built-in pocket
`applications, a taskbar for quick navigation, online
`networking functions, and more. Your desktop provides
`the following icons.
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` My Handheld PC — Opens Windows CE Explorer to
`display all the data on your MobilePro, whether stored
`in RAM or on a storage card in the PC card or
`Compact Flash card slots. My Handheld PC is much
`like the My Computer icon on the Windows 95
`desktop.
`
`*
`* *
` Microsoft Pocket Word — Allows you to create and
`edit documents on your MobilePro.
`
` Microsoft Pocket Excel — Allows you to view or
`draft spreadsheets.
`
` Microsoft Pocket PowerPoint — Lets you quickly and
`easily deliver a professional online presentation.
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`Ex-1036, 3-3 to 3-4 (emphases added) (exhibit pp. 51-52). The applications on the
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`NEC MobilePro, such as the Microsoft Pocket applications, “are available as a
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`desktop icon,” which again confirms the person of ordinary skill in the art’s
`
`understanding that “desktop” conventionally refers to the on-screen user interface,
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`not desktop computer hardware. Ex-1036, 3-4 (exhibit p. 52). Similarly, to access
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`the Windows CE Main Help resource, the user can “[t]ap Start then Help on the
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`MobilePro desktop taskbar” shown on the screen. Ex-1036, 1-23 (exhibit p. 30)
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`(emphasis added); see also Ex-1036, 4-3 (explaining that the user taps buttons and
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`icons to perform actions on the “Windows CE desktop” screen), 4-9 (“Your NEC
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`MobilePro is equipped with a desktop icon labeled MobilePro Settings.” (emphasis
`
`added)), 4-10, 5-5 (explaining that users tap icons on the MobilePro desktop to
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`launch applications), 1-4 (same) (exhibit pp. 59, 65, 66, 82, 11). Like the HP
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`620LX, where a desktop PC is intended rather than the conventional use of
`
`“desktop” as a user interface, the NEC MobilePro manual refers expressly to a
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`“desktop computer.” Ex-1036, 3-7 (exhibit p. 55).
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`25. Like the mobile handheld computer devices described above, it was
`
`also conventional to refer to the user interface shown on laptop computer screens
`
`as the “desktop.” This was especially true for Microsoft Windows devices, like the
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`IBM ThinkPad, which was provided for “mobile computing needs.” Ex-1037, 1,
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`203 (describing moving the mouse pointer “to the desktop” of the display screen
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`and dragging objects in “the Desktop area box” to resize “the desktop” resolution)
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`(exhibit pp. 19, 115). Windows 95, which was installed on laptop computers,
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`clearly identifies the “Windows screen, or desktop,” using that term in the same
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`way as was conventional in the art.
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`Ex-1038, 20, viii; see also xv (Windows 95 can be installed on laptop computers),
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`25 (identifying the “Recycle Bin” on the on-screen “desktop”), 34 (identifying a
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`“shortcut icon on the desktop” screen), 39 (identifying shortcut icons that “appear[]
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`on the desktop” screen) (exhibit pp. 36, 8, 15, 41, 50, 55). Like the various portable
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`handheld devices described above, Windows 95 describes a “desktop background”
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`for the user interface screen, making clear that “desktop” refers to the on-screen
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`user interface, not physical hardware. Ex-1038, 67 (exhibit p. 83). Apple used the
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`same terminology to refer to the on-screen user interface area as “the desktop” of
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`its PowerBook 150 laptop. Ex-1042, 26-27 (identifying and circling screen images
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`as part of the “desktop”), 37 (referring to “the desktop (the background pattern on
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`your screen)”) (exhibit pp. 36-37, 47).
`
`VII. DR. ROSENBERG IS INCORRECT THAT X WINDOWS WAS
`INCOMPATIBLE WITH MOBILE DEVICES
`26. Dr. Rosenberg further implies that X Windows was not usable on
`
`mobile handheld computing devices. As an initial matter, I do not see any
`
`evidentiary support for that position in his declaration. But as a factual matter, he is
`
`wrong. X Windows was used frequently on mobile devices, such as laptops, and
`
`was compatible with many different operating environments that are independent
`
`of device type, such as Unix and LISP, as explained in Robertson.
`
`27. As I explain in my previous declaration, this was well known to
`
`persons of ordinary skill in the art. Ex-1003, ¶¶80-96. It is further confirmed by
`
`numerous references, including Rajagopalan (Ex-1039), Hamburgen (Ex-1040),
`
`and Kamijoh (Ex-1041). Moreover, as I previously explained, a person of ordinary
`
`skill in the art would have understood Robertson’s teachings to apply to many
`
`19
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`GOOGLE EXHIBIT 1032
`GOOGLE v. NEONODE
`IPR2021-01041
`
`Page 19 of 22
`
`
`
`Declaration of Jacob O. Wobbrock, Ph.D.
`
`IPR2021-01041
`U.S. Patent No. 8,095,879
`
`
`types of systems that did not implement X Windows directly, but were well-known
`
`for using touch and gesture-based interfaces. Ex-1003, ¶¶80-96.
`
`28. Rajagopalan describes implementing XFree86, which is a free version
`
`of X Windows, on “laptops.” Ex-1039, § 4.1; Abstract (confirming that X
`
`Windows is “a system for building GUIs [graphical user interfaces]”), § 1 (X
`
`Windows is “a popular system for building GUIs”) (exhibit pp. 3, 4).
`
`29. Hamburgen is an IEEE publication from Compaq, which describes
`
`using X Windows on a small credit card-sized mobile device called Itsy that had a
`
`touchscreen, shown below.
`
`Ex-1040, 33, 28 (exhibit pp. 8, 3). For the software, the Itsy designers selected the
`
`Linux operating system (a derivative of Unix mentioned in Robertson) and applied
`
`X Windows to create the “foreground session” where the user interacts with the
`
`
`
`20
`
`GOOGLE EXHIBIT 1032
`GOOGLE v. NEONODE
`IPR2021-01041
`
`Page 20 of 22
`
`
`
`Declaration of Jacob O. Wobbrock, Ph.D.
`
`IPR2021-01041
`U.S. Patent No. 8,095,879
`
`
`touchscreen display. Ex-1040, 32-33 (exhibit pp. 7-8). The Hamburgen authors
`
`explained that their Itsy device could “concurrently run systems as disparate as X
`
`Windows, Java, and Squeak, as well as full-screen stand-alone applications and
`
`virtual consoles.” Ex-1040, 33 (exhibit p. 8). Like Robertson, Itsy’s “foreground-
`
`session processes receive physical input events, such as button presses or touch-
`
`screen samples,” on the interface, such as with the stylus (pen). Ex-1040, 33
`
`(exhibit p. 8).
`
`30. Kamijoh went even further than Hamburgen in shrinking the size of
`
`its X Windows mobile computer and implemented X Windows (“X11” and “X”
`
`refer to “X Windows,” as Dr. Rosenberg confirmed, Ex-2019, ¶131; see also
`
`Ex-1027) on small wristwatch-sized computer devices having a touchscreen.
`
`Ex-1041, 133, 136, 138, FIG. 2 (referring to the “touch sensitive screen,” “touch
`
`panel,” and “touch screen” input device) (exhibit pp. 3, 6, 8, 4).
`
`31. Thus, contrary to Dr. Rosenberg’s suggestion that X Windows is
`
`implemented only on desktop computers, the above examples show that X
`
`Windows was implemented on increasingly smaller and smaller (down to watch-
`
`sized) touchscreen user interfaces before the ’879 patent’s earliest priority date.
`
`32. These references confirm what I explained in my previous declaration
`
`that a person of ordinary skill in the art would have understood that Robertson’s
`
`teachings, including the disclosure of pen-based gestural inputs, would have
`
`21
`
`GOOGLE EXHIBIT 1032
`GOOGLE v. NEONODE
`IPR2021-01041
`
`Page 21 of 22
`
`
`
`Declaration of Jacob O. Wobbrock, Ph.D.
`
`IPR2021-01041
`U.S. Patent No. 8,095,879
`
`
`applied to many different types of user interface systems, including mobile
`
`handheld computer units, such as laptops, PDAs, and mobile phones.
`
`VIII. CONCLUSION
`In signing this declaration, I understand that the declaration will be
`33.
`
`filed as evidence in a contested case before the Patent Trial and Appeal Board of
`
`the United States Patent and Trademark Office. I acknowledge that I may be
`
`subject to cross-examination in this case and that cross-examination will take place
`
`within the United States. If cross-examination is required of me, I will appear for
`
`cross-examination within the United States during the time allotted for cross-
`
`examination.
`
`34.
`
`I declare that all statements made herein of my knowledge are true,
`
`and that all statements made on information and belief are believed to be true, and
`
`that these statements were made with the knowledge that willful false statements
`
`and the like so made are punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`
`
`Date: July 20, 2022
`
`
`
`
`Jacob O. Wobbrock, Ph.D.
`
`
`
`
`
`22
`
`GOOGLE EXHIBIT 1032
`GOOGLE v. NEONODE
`IPR2021-01041
`
`Page 22 of 22
`
`
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