Exhibit 1
`
`U.S. Patent No. 8,526,767 (“’767 Patent”)
`
`Invalidity Chart Based On Primary Reference U.S. Patent Application Publication No. 2009/0284478 (“BALTIERRA”)
`
`BALTIERRA qualifies as prior art to U.S. Patent No. 8,526,767 (“’767 Patent”) at least under 35 U.S.C. § 102(e) and anticipates and,
`alone or with other references, renders obvious one or more of claims 1-3, 6, and 11-14. To the extent BALTIERRA does not disclose
`one or more limitations of the claims, it would have been obvious to combine the teachings of BALTIERRA with the knowledge of
`one of ordinary skill in the art and with one or more of the references below to render the claims at-issue in the ’767 Patent invalid.
`
`• U.S. Patent Application Publication No. 2007/0247435 (“BENKO”)
`• U.S. Patent No. 8,519,965 (“CADY”)
`• U.S. Patent Application Publication No. 2009/0325643 (“HAMADENE”)
`•
`Japanese Laid-Open Patent Application Gazette H09-231004 (“KATOU”)
`• U.S. Patent Application Publication No. 2009/0213084 (“KRAMER”)
`• U.S. Patent Application Publication No. 2010/0020025 (“LEMORT”)
`• U.S. Patent Application Publication No. 2008/0046425 (“PERSKI”)
`•
`International Patent Publication No. WO 00/63874 (“STRINGER”)
`• U.S. Patent Application Publication No. 2007/0176906 (“WARREN”)
`• U.S. Patent Application Publication No. 2008/0036743 (“WESTERMAN”)
`• U.S. Patent Application Publication No. 2009/0225039 (“WILLIAMSON”)
`• U.S. Patent Application Publication No. 2007/0046643 (“HILLIS”) (prior art under at least 35 U.S.C. §102(b))
`• U.S. Patent Application Publication No. 2006/0066582 (“LYON”) (prior art under at least 35 U.S.C. §102(b))
`• U.S. Patent Application Publication No. 2007/0152984 (“ORDING”) (prior art under at least 35 U.S.C. §102(a))
`• U.S. Patent Application Publication No. 2007/0291009 (“WRIGHT”) (prior art under at least 35 U.S.C. §102(a))
`• Admitted Prior Art
`
`The excerpts cited herein are exemplary. For any claim limitation, Samsung may rely on excerpts cited for any other limitation and/or
`additional excerpts not set forth fully herein to the extent necessary to provide a more comprehensive explanation for a reference’s
`disclosure of a limitation. Where an excerpt refers to or discusses a figure or figure items, that figure and any additional descriptions
`of that figure should be understood to be incorporated by reference as if set forth fully herein. Similarly, where an excerpt cites to
`particular text referring to a figure, the citation should be understood to include the figure and related figures as well.
`
`1
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`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 1
`
`

`

`These invalidity contentions are not an admission by Samsung that the accused products or components, including any current or past
`version of these products or components, are covered by, or infringe the asserted claims, particularly when these claims are properly
`construed and applied. These invalidity assertions are also not an admission that Samsung concedes or acquiesces to any claim
`construction(s) implied or suggested by Plaintiff in its Complaint or the associated infringement claim charts. Nor is Samsung
`asserting any claim construction positions through these charts, including whether the preamble is a limitation. Samsung also does not
`concede or acquiesce that any asserted claim satisfies the requirements of 35 U.S.C. §§ 112 or 101 and submits these invalidity
`contentions only to the extent Plaintiff’s assertions may be understood.
`
`
`
`
`
`2
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`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 2
`
`

`

`
`
`Asserted Claims
`
`Claim 1
`
`Exemplary Disclosures
`
`
`
`[1.pre] A touch sensor device
`comprising:
`
`BALTIERRA, alone or in combination with the knowledge of a person of ordinary skill in the
`art, discloses and/or renders obvious the touch sensor device recited in claim 1.
`
`BALTIERRA at Abstract:
`“This document describes tools capable of initiating a function based on one or more tactile
`contacts received through a contact detection device, such as a touch pad. In some embodiments,
`the tools identify tactile contacts in accordance with the tool's input mode. The tools may use the
`input mode to determine what gestures may be identified for the tactile contacts. In some
`embodiments, these tools switch input modes based on a number or characteristic of tactile
`contacts electronically represented in contact data. By so doing, the tools may more accurately
`determine appropriate gestures or provide a broader range of functions based on tactile contacts
`received through a contact detection device.”
`
`BALTIERRA at [0003]:
`“This document describes tools capable of initiating a function based on one or more tactile
`contacts received through a contact detection device, such as a touch pad. In some embodiments,
`the tools identify tactile contacts in accordance with the tool's input mode. The tools may use the
`input mode to determine what gestures may be identified for the tactile contacts. In some
`embodiments, these tools switch input modes based on a number or characteristic of tactile
`contacts electronically represented in contact data. By so doing, the tools may more accurately
`determine appropriate gestures or provide a broader range of functions based on tactile contacts
`received through a contact detection device.”
`
`BALTIERRA at [0011]:
`“More and more, computing systems are sold with contact input devices, such as a touch pad or a
`touch screen. These devices accept user input based on physical contact, such as tactile contact
`for one or more stylus or finger contacts, with one or more contact detectors included in the
`touch pad. Current touch pads, however, are not well suited to many computing tasks and
`
`3
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`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 3
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`applications because they often cannot differentiate between enough different types of physical
`contacts or require users to perform awkward gestures.”
`
`BALTIERRA at [0012]-[0013]:
`“This document describes an identifier module included with a contact detection device to
`identify or recognize an electronic version of one or more tactile contacts represented in contact
`data obtained from contact detectors in the contact detection device. One or more contact state
`machines and a monitoring state machine are included with the identifier module to switch the
`identifier module's input mode, which controls which gestures that the identifier module can
`identify. The contact state machines and/or monitoring state machine may receive and watch the
`contact data for a change in a number of tactile contacts and characteristics of the tactile contacts
`represented in the contact data. In response to a change represented in contact data, each contact
`state machine may determine to change state. The monitoring state machine monitors the state of
`the contact state machine to determine when the contact state machine changes state. The
`monitoring state machine changes the identifier module's input mode in response to the contact
`state machine changing state.
`In at least this way, the monitoring state machine determines what gestures the identifier module
`may identify. If a person contacts the contact detection device with two fingertips, the identifier
`module may identify which gesture is appropriate or intended by a user that made the tactile
`contacts to the contact detection device based on the input mode. Thus, when identifying
`gestures, the identifier module may analyze individual tactile contacts based on the identifier
`module's input mode or sub-mode. By treating individual tactile contacts differently based on the
`input mode or sub-mode, the identifier module can distinguish combinations of tactile contacts.
`This feature permits the identifier module to identify gestures from multiple tactile contacts
`without interfering with the identifier module's ability to identify gestures from a single tactile
`contact.”
`
`BALTIERRA at [0016]:
`“FIG. 1 references a computing system 100 with a multi-input system 102 including an identifier
`module 104 that identifies gestures input by a user and detected by one or more contact detectors
`106 (shown integrated with a display 107) included in a contact detection device 108. Upon
`
`4
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 4
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`identifying the gestures, the identifier module 104 initiates an application 110 to provide the
`function (e.g., zooming) that is mapped to the gestures. Functions include inputting data,
`manipulating data, changing a display (e.g., pan, zoom, and rotate), providing audio, and the
`like.”
`
`BALTIERRA at [0019]-[0020]:
`“In the example environment of FIG. 1, the multi-input system 102 is included in the contact
`detection device 108. As illustrated, the contact detectors 106 are included in the contact
`detection device 108 and are integrated with the display 107 (e.g., a liquid crystal display
`screen). The individual contact detectors may be configured to detect multiple physical, tactile
`contacts, such as a first tactile contact 112 and a second tactile contact 114. Multiple individual
`contact detectors may identify a tactile contact (e.g., a first contact detector detects a first tactile
`contact while a second contact detector detects a second tactile contact). The contact detectors
`106 may be aligned with the pixels in a column/row configuration or otherwise.
`The contact detectors 106 may be configured to detect an x-y position, i.e., a two-dimensional
`position, of the tactile contact. The contact detectors may also detect, for example, duration of
`contact (whether static or moving), contact pressure, contact height, contact width, bounding box
`for multiple contacts, rate of positional change, angular orientation, contact vectors, movement
`of the contact, and other information set forth herein.”
`
`BALTIERRA at [0021]:
`“In some embodiments, an input controller 116 is included in the multi-input system 102 to
`convert the contact detector output (e.g., the electrical signals from the contact detectors) into
`contact data. For instance, the input controller 116 includes appropriate hardware/software for
`converting the contact detector output into contact data that is usable by the multi-input system
`102. In other embodiments, the input controller 116 can be included in the multi-input system
`102, contained in a separate module, or performed by a general purpose processor loaded with
`firmware or software for converting contact detector output into contact data.”
`
`BALTIERRA at [0023]:
`“For example, the identifier module 104 may combine contact data that indicates physical
`
`5
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 5
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`contact with contact detectors included in the contact detection device at x-y positions to identify
`a straight line. If a straight line is mapped to a function, the identifier module 104 initiates the
`function. In response, the application 110 provides the initiated function.”
`
`BALTIERRA at [0025]:
`“The identifier module 104 may also or instead use a library 118 storing a lookup table to
`identify the gestures from the contact data. For example, the identifier module 104 may identify
`the gestures by comparing contact data with sample contact data or parameters included in the
`lookup table to initiate the mapped function.”
`
`BALTIERRA at [0027]-[0028]:
`“The multi-input system 102 switches or controls the identifier module's input mode based on
`the number of tactile contacts represented in the contact data and/or other information, such as
`characteristics of the tactile contacts. By switching identifier module input modes, the multi-
`input system 102 determines what gestures can be identified and thus what functions can be
`initiated. Additionally, by switching input modes, the identifier module may initiate a large
`number of functions in comparison to the number of tactile contacts associated with the
`functions, misidentification can be avoided, and basic tactile contacts can be reused.
`For example, when the identifier module 104 is in single-input mode, the identifier module 104
`is prohibited from identifying more than one tactile contact. In this manner, inadvertent physical
`contact with the contact detectors 106 does not initiate a function.”
`
`BALTIERRA at [0029]:
`“In some cases, such as when multiple tactile contacts are represented in the contact data, the
`identifier module's input mode is based on the number of tactile contacts present in the contact
`data. Thus, the identifier module identifies three tactile contacts when the identifier module's
`input mode is set to identify three tactile contacts.”
`
`BALTIERRA at [0030]:
`“One or more contact state machines 120 and a monitoring state machine 122 may be included in
`the multi-input system 102 to switch or determine the identifier module's input mode. The
`
`6
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 6
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`contact state machines 120 (e.g., multiple instances of the contact state machine, one for each
`tactile contact) may watch the input controller 116 for contact data that indicates a change in the
`number of tactile contacts (e.g., the addition of a tactile contact or removal of a tactile contact)
`represented in the contact data. Each contact state machine 120 may change state in response to
`its tactile contact changing state (as represented in the contact data).”
`
`BALTIERRA at [0031]:
`“In some embodiments, each tactile contact has its own instance of a contact state machine.
`Thus, a first finger may have a first contact state machine and a second finger a second contact
`state machine. In these cases, the monitoring statement machine 122 monitors the state of the
`contact state machines 120 to determine when each contact state machine 120 changes state.
`Each of the contact state machines 120 may change state when the particular tactile contact
`changes state.”
`
`BALTIERRA at [0032]-[0033]:
`“Thus, the monitoring state machine 122 monitors the change in the number of tactile contacts
`by monitoring the state of the contact state machines 120. Upon determining that the contact
`state machines 120 has changed state and the change in the number of tactile contacts, the
`monitoring state machine 122 switches the identifier module's input mode from a previous input
`mode to a current input mode.
`For example, when a user makes a pinching gesture, a user may contact the contact detection
`device 108 with his/her thumb before contacting the contact detection device 108 with his/her
`forefinger. In this scenario, the contact state machine 120 for the thumb changes state when the
`user originally contacts the contact detection device 108 with his/her thumb. The contact state
`machine 120 for the forefinger may change state when the user presses his/her forefinger against
`the contact detection device 108. In response to these state changes and the number of contacts
`change, the monitoring state machine 122 changes the identifier module's input mode.”
`
`BALTIERRA at [0034]:
`“Note also that the contact state machines 120 may differ, in some embodiments. For example, a
`first contact state machine for a first or primary tactile contact (e.g., a forefinger) may be
`
`7
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 7
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`backward compatible with single-finger input modes and scenarios, such as touch widget, flicks,
`and double-tap support. Other state machines may also have this compatibility or they may not.
`Further, contact state machines for non-first or non-primary tactile contacts may have additional
`or different logic, such as logic that relates to a second contact but that would not pertain to a
`first or primary contact (e.g., for gestures where a second finger's actions are determinative for a
`gesture but do not pertain to a first finger's actions). This logic may also be included in a contact
`state machine for a first or primary tactile contact, though such logic may not be used in many
`situations.”
`
`BALTIERRA at [0038]:
`“Turning again to the multi-input system 102, the system may include additional contact and
`monitoring state machines. For example, additional combinations of contact and monitoring state
`machines may be included for watching additional tactile contacts represented in the contact
`data. In these embodiments, the number of contact state machines and monitoring state machines
`in the multi-input system 102 corresponds to the number of tactile contacts that the contact
`detection device 108 can detect.”
`
`BALTIERRA at [0039]:
`“The contact and monitoring state machines may be configured to switch or determine a sub-
`mode for the identifier module 104. For example, when the identifier module 104 is in multi-
`input mode, the monitoring state machine 122 may switch the identifier module 104 between
`sub-modes depending on a characteristic of the tactile contact (e.g., movement) as represented in
`the contact data.”
`
`BALTIERRA at [0040]:
`“The contact state machine 120 (or instances of it) may change its state when one or more of the
`tactile contacts start moving. The monitoring state machine 122 switches the sub-mode of the
`identifier module 104 in response to the contact state machine 120 changing state. For instance,
`the monitoring state machine 122 switches the identifier module 104 from a multi-input static
`sub-mode to a multi-input hybrid sub-mode when one of the tactile contacts moves while the
`other tactile contact remains fixed. In this case, the contact state machine 120 for the second
`
`8
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 8
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`tactile contact changes state in response to the second tactile contact beginning to move. The
`monitoring state machine 122, monitoring the state of the contact state machine 120, switches the
`identifier module 104 to the hybrid sub-mode.”
`
`BALTIERRA at [0042]-[0043]:
`“By changing input modes and sub-modes, the identifier module 104 can treat an individual
`tactile contact as a subset of the group when identifying tactile contacts. In addition, by
`configuring the identifier module in this manner, the multi-input system 102 can identify
`multiple tactile contacts represented in the contact data without impacting single tactile contact
`identification. In other words, by configuring the identifier module 104 to identify tactile
`contacts with respect to a group (based on the identifier module's input mode), misidentification
`may be minimized or avoided and the multi-input system may be backward compatible with
`applications that are not multi-input enabled. In this way, the identifier module's input mode
`determines what number of tactile contacts can be identified within the group. Further, by
`configuring the identifier module in this manner, basic tactile contacts, such a tap or a straight
`line, may be reused between input modes.
`These are not exhaustive. By way of example, the identifier module may initiate an initial
`function and continue that initial or subsequent function until interrupted by another function that
`stops the initial function. For example, the application 110 may continue to pan with inertia after
`a pan gesture until a user triggers a stop function. In another example, the identifier module 104
`causes the rate of the function to increase the longer the function is active (e.g., without being
`stopped). A user may stop the initial function by triggering a stop function. In another example,
`the multi-input system 102 determines the extent of the initiated function based on a
`characteristic of the tactile contact—when the contact data indicates that the tactile contact was
`quick, based on a predefined standard, the mapped function is performed in a rapid manner, also
`based on a predefined standard. Further still, the identifier module 104 may initiate an ancillary
`function in addition to a primary function. For example, while the identifier module 104 initiates
`a zoom function 124, the identifier module may additionally initiate a toolbar, an icon, or some
`other interactive graphical object that is associated with the primary function.”
`
`BALTIERRA at [0049]-[0057]:
`
`9
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 9
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`“Block 200 detects tactile contacts from an object (e.g., a user's finger or stylus) contacting a
`contact detection device and generates output that represents the detected tactile contact(s). Thus,
`the tools generate an output that represents the user's physical interaction (e.g., tactile contact)
`with a tactile contact device (e.g., a touch pad). In one embodiment, the tools detect input from a
`user touching his/her finger to one or more contact detectors included in the contact detection
`device. In some embodiments, the tools detect concurrent tactile contacts.
`Block 202 converts the tactile contacts to contact data based on the output from block 200.
`Contact data comprises information about the tactile contacts, such as a location of the tactile
`contacts, duration of the tactile contacts, movement of the tactile contacts, the force of the tactile
`contacts, and the like. The tools may concurrently convert output based on multiple tactile
`contacts into contact data. In some embodiments, the tools convert multiple tactile contacts into
`contact data as it arrives or by sampling contact detectors.
`Block 204 receives the contact data. Block 206 determines if there is a change of state in the
`tactile contact based on the received contact data. A change in state may occur when a number of
`tactile contacts represented in the contact data changes. In some embodiments, the tools receive
`contact data periodically and/or determine if there is a change in state periodically. In others the
`tools receive and determine state changes constantly. As noted previously, contact data provides
`information about the tactile contacts sufficient for the tools to determine if a change in state has
`occurred.
`For example, if the contact data indicates that one finger is contacting a contact detection device
`and then later that two fingers are contacting the contact detection device, the tools may
`determine that a change in state from one tactile input to two tactile inputs has occurred. This
`contact data may not be dispositive, however. A single finger may be creating tactile contact and
`then two fingers (or other part of a hand) may then be in tactile contact with a contact detection
`device. But the tools may determine that a change in state is not intended or appropriate based on
`other factors. Thus, other information in the contact data may be used, such as actions of the first
`finger before the second finger makes tactile contact, or actions of the two fingers before one of
`them ceases tactile contact. More information on how the tools may make this determination is
`set forth elsewhere herein (e.g., see the description of FIG. 1).
`The tools proceed to block 208 if the state has changed (along the “Yes” path) or to block 210 if
`the state has not changed (along the “No” path).
`
`10
`
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`IPR2021-01254
`Exhibit 2011
`Page 10
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`Block 208 switches the input mode from a previous input mode to a current input mode when
`there is a state change, such as when the number of tactile contacts represented in the contact
`data changes. For example, the tools may switch input modes from a multi-input mode (e.g., two
`contacts, such as two fingers or two stylus or some combination thereof) to a single-input mode
`(e.g., a single contact, such as a touch of a finger or stylus) in response to the contact data
`including a single tactile contact instead of multiple tactile contacts.
`Block 210 maintains the current input mode when no state change is determined.
`Block 212 identifies gestures in accordance with the current input mode. For example, if the
`tools are in multi-input mode, the tools may identify that a user made a pinching gesture based
`on two tactile contacts. The tools may heuristically identify the gestures based on previous tactile
`contacts. In other instances, the tools identify gestures within a predetermined range or tolerance.
`In single-input mode, the tools may ignore or disregard contact data associated with a second
`tactile contact. In this way, the tools ignore inadvertent tactile contacts.
`Block 214 initiates a function that is mapped to the identified gestures. In some cases the tools
`may additionally initiate an auxiliary function as well. For instance, in addition to providing a
`zoom function, the tools initiate an application to display a toolbar that is related to the zooming
`function. In this manner, while the tools initiate the zoom in or zoom out function, a user can
`adjust the toolbar to control the zoom function.”
`
`BALTIERRA at [0059]-[0069]:
`“Block 300 detects tactile contacts and generates output that represents the detected tactile
`contact. The tools generate an output that represents the user's physical interaction (e.g., tactile
`contact) with a contact detection device (e.g., a touch pad or touch screen).
`Block 302 converts the output into contact data. For example, the contact data indicates
`characteristics of the tactile contact, such as whether a tactile contact is moving, the number of
`tactile contacts, how long tactile contact has been detected, and the like.
`Block 304 receives contact data indicating movement of a tactile contact from the contact data.
`The tools determine whether a tactile contact is moving by determining whether an adjacent
`contact detector has generated an output. By using movement as a basis for switching input
`modes, the tools do not initiate certain functions that are or are not associated with movement.
`
`11
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 11
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`For instance, the tools forgo initiating functions mapped to non-moving tactile contacts when the
`input mode is associated with movement.
`Alternatively or additionally, the tools may also receive and base determinations on other types
`of contact data, such tactile contact duration (e.g., time), orientation, contact pressure, and the
`like. For example, when the tools watch for tactile contact duration, the tools can change state if
`a tactile contact remains fixed for a set period time.
`Block 306 determines if a state change has occurred. If it has, the tools proceed to block 308
`along the “Yes” path. If the state has not changed, the tools proceed along the “No” path to block
`310.
`The tools determine that a change of state has occurred in response to a change in the received
`contact data, such as when the contact data indicates that a tactile contact begins to move. Using
`tactile contact movement as a basis for switching input modes may permit efficient identification
`and limit the number of gestures that are available for identification.
`Using movement as a criterion for switching input modes and/or sub-modes permits a user to
`signal his/her intention to initiate another function by commencing movement or stopping the
`tactile contact. Thus, a user can signal his/her intention to switch sub-modes by momentarily
`halting a tactile contact.
`Block 308 switches the tools' mode or sub-mode based on whether a moving tactile contact is
`represented in the contact data. For instance, the tools change sub-modes from a stationary mode
`to moving mode when two tactile contacts start moving. In other embodiments, the tools switch
`sub-modes from a moving sub-mode to a stationary sub-mode when two tactile contacts stop
`moving. The tools may also switch to a hybrid sub-mode when at least one tactile contact is
`moving and at least one tactile contact is static.
`Block 310 maintains the current mode and sub-mode when no change in motion occurs (e.g.,
`whether the tactile contacts are moving or not).
`Block 312 identifies the gestures based on the tools' input mode/sub-mode. For example, when
`the tools are in single-input mode, the tools may only identify a single moving tactile contact
`from the contact data. In another example, the tools do not identify multiple moving tactile
`contacts when in single-input mode.
`Block 314 initiates a function that is mapped to the identified gestures. In one or more
`embodiments, the tools additionally may initiate an auxiliary function (e.g., any of those
`
`12
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`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 12
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`auxiliary functions mentions above).”
`
`BALTIERRA at TABLES 1-2.
`
`BALTIERRA at FIGS. 1-3.
`
`[1.a] a sensor having a sensitive
`area extending in at least one-
`dimension and arranged to
`output sense signals responsive
`to proximity of an object to the
`sensitive area;
`
`BALTIERRA, alone or in combination with the knowledge of a person of ordinary skill in the
`art, discloses and/or renders obvious “a sensor having a sensitive area extending in at least one-
`dimension and arranged to output sense signals responsive to proximity of an object to the
`sensitive area.”
`
`BALTIERRA at Abstract:
`“This document describes tools capable of initiating a function based on one or more tactile
`contacts received through a contact detection device, such as a touch pad. In some embodiments,
`the tools identify tactile contacts in accordance with the tool's input mode. The tools may use the
`input mode to determine what gestures may be identified for the tactile contacts. In some
`embodiments, these tools switch input modes based on a number or characteristic of tactile
`contacts electronically represented in contact data. By so doing, the tools may more accurately
`determine appropriate gestures or provide a broader range of functions based on tactile contacts
`received through a contact detection device.”
`
`BALTIERRA at [0003]:
`“This document describes tools capable of initiating a function based on one or more tactile
`contacts received through a contact detection device, such as a touch pad. In some embodiments,
`the tools identify tactile contacts in accordance with the tool's input mode. The tools may use the
`input mode to determine what gestures may be identified for the tactile contacts. In some
`embodiments, these tools switch input modes based on a number or characteristic of tactile
`contacts electronically represented in contact data. By so doing, the tools may more accurately
`determine appropriate gestures or provide a broader range of functions based on tactile contacts
`received through a contact detection device.”
`
`BALTIERRA at [0012]-[0013]:
`
`13
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2011
`Page 13
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`“This document describes an identifier module included with a contact detection device to
`identify or recognize an electronic version of one or more tactile contacts represented in contact
`data obtained from contact detectors in the contact detection device. One or more contact state
`machines and a monitoring state machine are included with the identifier module to switch the
`identifier module's input mode, which controls which gestures that the identifier module can
`identify. The contact state machines and/or monitoring state machine may receive and watch the
`contact data for a change in a number of tactile contacts and characteristics of the tactile contacts
`represented in the contact data. In response to a change represented in contact data, each contact
`state machine may determine to change state. The monitoring state machine monitors the state of
`the contact state machine to determine when the contact state machine changes state. The
`monitoring state machine changes the identifier module's input mode in response to the contact
`state machine changing state.
`In at least this way, the monitoring state machine determines what gestures the identifier module
`may identify. If a person contacts the contact detection device with two fingertips, the identifier
`module may identify which gesture is appropriate or intended by a user that made the tactile
`contacts to the contact detection device based on the input mode. Thus, when identifying
`gestures, the identifier module may analyze individual tactile contacts based on the identifier
`module's input mode or sub-mode. By treating individual tactile contacts differently based on the
`input mode or sub-mode, the identifier module can distinguish com