Exhibit 13
`
`U.S. Patent No. 8,526,767 (“’767 Patent”)
`
`Invalidity Chart Based On Primary Reference U.S. Patent Application Publication No. 2008/0036743 (“WESTERMAN”)
`
`WESTERMAN qualifies as prior art to U.S. Patent No. 8,526,767 (“’767 Patent”) at least under 35 U.S.C. § 102(a) and anticipates
`and, alone or with other references, renders obvious one or more of claims 1-3, 6, and 11-14. To the extent WESTERMAN does not
`disclose one or more limitations of the claims, it would have been obvious to combine the teachings of WESTERMAN 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. 2009/0284478 (“BALTIERRA”)
`• 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. 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
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`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
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 2
`
`

`

`
`
`Asserted Claims
`
`Claim 1
`
`Exemplary Disclosures
`
`
`
`[1.pre] A touch sensor device
`comprising:
`
`WESTERMAN, 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.
`
`WESTERMAN at Abstract:
`“Methods and systems for implementing gestures with sensing devices are disclosed. More
`particularly, methods and systems related to gesturing with multipoint sensing devices are
`disclosed.”
`
`WESTERMAN at [0025]-[0026]:
`“With touch pads, the movement of the input pointer corresponds to the relative movements of
`the user's finger (or stylus) as the finger is moved along a surface of the touch pad. Touch
`screens, on the other hand, are a type of display screen that has a touch-sensitive transparent
`panel covering the screen. When using a touch screen, a user makes a selection on the display
`screen by pointing directly to GUI objects on the screen (usually with a stylus or finger). In
`general, the touch device recognizes the touch and position of the touch and the computer system
`interprets the touch and thereafter performs an action based on the touch event.
`In order to provide additionally functionality, gestures have been implemented with some of
`these input devices. By way of example, in touch pads, selections may be made when one or
`more taps are detected on the surface of the touch pad.”
`
`WESTERMAN at [0029]:
`“The invention relates, in one embodiment, to an electronic system. The electronic system
`includes a multipoint sensing device that provides a multipoint sensing area for receiving inputs
`from one or more objects. The electronic system also includes a gesture module configured to
`determine a gesture set for a given input arrangement received by the multipoint sensing area of
`the multipoint sensing device, to monitor the given input arrangement for one or more gesture
`events included in the gesture set, and to initiate input actions associated with a gesture event
`
`3
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 3
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`when the gesture event is performed with the input arrangement. The input arrangement may for
`example be an arrangement of fingers and/or other parts of the hand.”
`
`WESTERMAN at [0030]:
`“The invention relates, in another embodiment, to a gestural control method. The method
`includes detecting multiple points within a sensing area at the same time. The method also
`includes determining a chord when one or more points are detected within the sensing area. The
`chord is a specific arrangement of points within the sensing area. The method further includes
`determining a gesture set associating commands to one or more gesture events. The method
`additionally includes monitoring points for gesture events. Moreover, the method includes
`performing command associated with gesture event if a gesture event is recognized.”
`
`WESTERMAN at [0031]:
`“The invention relates, in another embodiment, to a control operation. The control operations
`includes detecting a touch or near touch. The operations also includes determining a gesture set
`for the touch. The gesture set includes one or more gesture events for provoking or initiating a
`command. The operation further includes monitoring the touch for a gesture event. The operation
`additionally includes initiating a command when a gesture event associated with the gesture set
`is performed.”
`
`WESTERMAN at [0032]:
`“The invention relates, in another embodiment, to a gesture operation. The operation includes
`monitoring a touch motion. The operation also includes differentiating the touch motion between
`first and second states. The operation further includes performing a first action if the touch
`motion is associated with first state. The operation additionally includes performing a second
`action if motion is associated with second state.”
`
`WESTERMAN at [0033]:
`“The invention relates, in another embodiment, to a control operation. The control operation
`includes providing a first input device and a second input device that is different than the first
`input device. The first input device includes an object sensing device such as a touch sensing
`
`4
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 4
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`device for providing input events. The operation also includes monitoring the first input device
`for input events. The operation further includes simultaneously monitoring the second input
`device for input events. The operation additionally includes performing input operations in
`accordance with input events associated with first input device. Moreover, the method includes
`simultaneously performing input operations in accordance with input events associated with
`second input device.”
`
`WESTERMAN at [0034]:
`“The invention relates, in another embodiment, to a control operation. The control operation
`provides a list of input functions. The input function have commands and gesture events that are
`linked to the commands. The commands are related to the input function. The operation also
`includes assigning input functions to chords. The operation additionally includes linking an input
`function to a chord when the chord is recognized.”
`
`WESTERMAN at [0037]:
`“The invention relates, in another embodiment, to a gesture operation. The gesture operations
`includes detecting a first finger. The gesture operation also includes determining the state of the
`finger. The state of the finger may for example be moving or stationary. The gesture operation
`further includes detecting one or more additional fingers. For example, a second finger may be
`detected. The gesture operation additionally includes determining the state of the additional
`fingers. The state of the additional fingers may for example be that they are present or not.
`Moreover, the method includes implementing different input modes based on timing of states of
`first and additional fingers relative to one another. The different modes may for example be
`pointing modes, dragging modes and the like.”
`
`WESTERMAN at [0093]-[0095]:
`“Gestures and methods of implementing gestures with sensing devices are disclosed. More
`particularly, gestures and methods of implementing gestures with multipoint sensing devices are
`disclosed. Multipoint sensing devices have a number of advantages over conventional single
`point devices in that they can distinguish more than one object (finger) simultaneously or near
`simultaneously. In most cases, multipoint sensing devices and systems that utilize such devices
`
`5
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 5
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`monitor a surface for a touch or near touch event. When such an event occurs, it can determine
`the distinct area(s) of contact and identify the nature of the events via their geometric features
`and geometric arrangement. Once identified, the touch or near touch events are monitored to
`determine if they correspond to various gestures events.
`A gesture event may be defined as a stylized interaction with the sensing surface mapped to one
`or more specific computing operations. Gesture events may be made through various hand, and
`more particularly digit, motions, taps, pressures, dwells, and/or the like. Because the surface is
`based on multipoint technology, complex gesturing may be performed with any number of digits
`or other contact portions of the hand. In fact, because of this, a large gesture language analogous
`to sign language may be developed. Gesture language (or map) may include for example a set of
`instructions that recognize an arrangement of contacts (e.g., chords), recognizes the occurrence
`of gesture events (e.g., motions), and informs one or more software agents of the gesture events
`and/or what action(s) to take in response to the gesture events.
`…
`A wide range of different gestures can be utilized with multipoint sensing devices. For example,
`a gesture may be a single point or a multipoint gesture; a static or dynamic gesture; a continuous
`or segmented gesture; and/or the like. Single point gestures are those gestures that are performed
`with a single contact point, e.g., the gesture is performed with a single touch as for example from
`a single finger, a palm or a stylus. Multipoint gestures are those gestures that can be performed
`with multiple points, e.g., the gesture is performed with multiple touches as for example from
`multiple fingers, fingers and palms, a finger and a stylus, multiple styli and/or any combination
`thereof. Static gestures may be those gestures that do not substantially include gesture events
`(e.g., chords), and dynamic gestures may be those gestures that do include significant gesture
`events (e.g., motions, taps, etc.). Continuous gestures may be those gestures that are performed
`in a single stroke, and segmented gestures may be those gestures that are performed in a
`sequence of distinct steps or strokes.”
`
`WESTERMAN at [0096]:
`“Multipoint sensing devices can be embodied in various forms including but not limit to standard
`sized touch pads, large extended palm pads, touch screens, touch sensitive housings, etc.
`Furthermore, multipoint sensing devices can be positioned on many form factors including but
`
`6
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 6
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`not limited to tablet computers, laptop computers, desktop computers as well as handheld
`computing devices such as media players, PDAs, cell phones, and the like. The multipoint
`sensing devices may also be found on dedicated input devices such as touch screen monitors,
`keyboards, navigation pads, tablets, mice, and the like.”
`
`WESTERMAN at [0098]-[0111]:
`“FIG. 1 shows illustrative gesture control operation 10, in accordance with one embodiment of
`the present invention. The operation 10 may begin at block 12 where a multi-point sensing
`device is provided. The multi-point sensing device is capable of detecting multiple points of
`contact or near contact at the same time. The multi-point sensing device may for example include
`a multi-touch sensing surface capable of simultaneously sensing multi objects on the its touch
`surface.
`…
`Following block 12, the operation can proceed to block 14 where a determination is made as to
`whether or not a touch or near touch is detected by the multi-point sensing device. If a touch is
`not detected, the operation can wait. If a touch is detected, the operation can proceed to block 16
`where a chord associated with the touch is determined. A chord may be a specific arrangement of
`contacts or near contacts that can be assigned to some input functionality.
`…
`The chord can be widely varied and may depend on many factors including the size of the touch
`surface, whether the touch surface is a touch screen or touch pad, etc. Furthermore, the chords
`may be based on the number of unknown contacts or a specific arrangement of known contacts.
`The chords may be further based on whether the contacts are close together, in a neutral position
`or spread apart. The chords may be further based on whether the contacts are adjacent or offset
`one another. The chords may be further based on the whether they are from left and/or right
`hand.
`Determining the chord may include analyzing the touch (image created by objects touching or
`near touching the touch surface) and recognizing a specific arrangement of contacts. More
`particularly, the determination may include classifying or identifying the contacts via the
`geometric features of each contact as well as the geometric arrangement of contacts, and then
`referring to a database of expected chords (e.g., gesture map).
`
`7
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 7
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`…
`Examples of one hand chords are shown below in Table 1. It should be appreciated that Table 1
`is not an exhaustive list and that it is shown by way of example and not by way of limitation. For
`example, the palm may be counted as a contact and added to any of the combinations shown in
`Table 1 to create more chords. It should be further noted that many more chord combinations can
`be created by combining the list of Table 1 with the same list from the opposite hand. It should
`also be noted that although there are many combinations some chords may not be feasible for
`various reasons including ease of use, ergonomics, intuitiveness, etc.
`Once the chord has been determined, the operation can proceed to block 18 where a gesture set
`associating actions to one or more gesture events is determined. A gesture set may be a map that
`links actions to gesture events. The gesture set may depend on the determined chord, but may
`also depend on other factors including location of the chord, open application, state or mode of
`the application, other touch characteristics, etc. In essence, the chord selects an input channel
`with each channel having a different gesture set associated therewith. In some cases, for
`organizational purposes and ease of use, the channels are associated with a particular input
`functionality such as navigating operations, file operations, edit operations, viewing operations,
`formatting operations, tool operations, web browsing operations, etc. Each of these input
`functionalities can have an associated set of commands that are tied to gesture events.
`The actions may be state commands or manipulative commands.
`…
`A manipulative command is a command that continuously manipulates the selected object.
`Examples of manipulative commands include pointing, tracking, dragging, scrolling, panning,
`zooming, sizing, stretching, paging, volume, etc.
`…
`As noted above, a gesture event can be any stylized physical action that can be performed on or
`above the touch surface. Examples of gesture events may include for example motions, taps,
`pressure changes, dwells, etc. In some cases, the gesture events may be performed by the chord.
`In other case, the gesture events may be performed by a subset of the chord. In other cases, the
`gesture events may be performed by new contacts in addition to or separate from the initial
`chord.
`…
`
`8
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 8
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`In block 20, the touch can be monitored for gesture events, and in block 22 a determination can
`be made as to whether or not gesture events are recognized. Recognizing the gesture events may
`include analyzing the touch characteristics of contacts (contacts associated with the chord and/or
`new contacts), identifying a specific pattern and referring to the gesture set and its list of
`expected gesture events. If the pattern matches an expected gesture event then the pattern may be
`presumed to be the expected gesture event. The touch characteristics may for example include
`first order consideration such as motion, tapping, change in pressure, dwell, and second order
`considerations such as speed (absolute or relative), direction (absolute or relative), orientation
`(absolute or relative), size (absolute or relative), duration (absolute or relative), shape (absolute
`or relative), length (absolute or relative), and/or the like.
`…
`If a gesture event is recognized, the operation can proceed to block 24 where the action(s)
`associated with the gesture events are performed. Block 24 may include referring to the gesture
`set and locating the action(s) associated with the recognized gesture events. Once located, the
`action(s) can be initiated.
`…
`Following block 24, the operation can proceed to block 26 where a determination is made as to
`whether or not a switching event has been performed. A switching event can refer to an event
`that resets the operation or initiates a chord change. The switching event may be implemented in
`a variety of ways. For example, it may be implemented by removing all contacts for a
`predetermined amount of time (e.g., lifting hand off of touch surface). It may also be
`implemented by changing the base chord during the touch (e.g., adding/removing contacts). It
`may also be implemented by adding/removing contacts from the opposite hand (e.g., placing one
`or more fingers down with the opposite hand while the other hand is still touching). It may also
`be implemented by pausing (e.g., if the contacts stay stationary for a preset amount of time). It
`may also be implemented by a key entry or button click from a standard keyboard or mouse. It
`may also be implemented via a gesture event. If a switching event has occurred, the operation
`proceeds back to block 12. If a switching event has not occurred, then the operation proceeds
`back to block 20.”
`
`
`9
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 9
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`WESTERMAN at [0112]-[0116]:
`“FIG. 2 shows illustrative control operation 50, in accordance with one embodiment of the
`present invention. The operation may begin at block 52 where a touch or near touch is detected.
`Following block 52, the operation can proceed to block 54, where a gesture set is determined for
`the touch. The gesture set may depend on many factors including touch characteristics, touch
`location, open application, mode of application, and the like. In most cases, the gesture set is
`based at least in part on the arrangement of contacts at touchdown.
`Following block 54, the operation can proceed to block 56 where the touch is monitored for
`gesture events associated with the gesture set. The gesture set may include one or more gesture
`events for provoking or initiating a command (e.g., commands can be tied or linked to specific
`gesture events).
`Following block 56, the operation can proceed to block 58 where one or more commands are
`initiated when gesture events are performed. For example, a user may slide a specific
`arrangement of fingers to provoke or initiate a scrolling event.
`FIG. 3 shows illustrative control operation 60, in accordance with one embodiment of the present
`invention. The control operation 60 may for example correspond to block 54 in FIG. 2. The
`control operation 60 may begin at block 62 where the initial arrangement of contacts are
`recognized. Thereafter, in block 64, the initial arrangement of contacts can be compared to a
`stored set of arrangement of contacts. For example, the system may refer to a gesture map that
`includes a list of initial arrangement of contacts and gesture sets assigned thereto. If there is a
`match, the operation can proceed to block 66 where the gesture set assigned to the recognized
`initial arrangement of contacts is loaded.”
`
`WESTERMAN at [0117]:
`“FIG. 4 shows illustrative control operation 70, in accordance with one embodiment of the
`present invention. The control operation 70 may begin at block 72 where a touch is detected.
`Thereafter, in block 74, the location of the touch can be determined. Thereafter, in block 76, the
`arrangement of contacts associated with the touch can be determined (e.g., touch pattern).
`Thereafter, in block 78, the active application can be determined. Thereafter, in block 80, the
`current state of the application can be determined (e.g., current mode). Thereafter, in block 82,
`an appropriate gesture set can be set or selected based on one or more of the determined
`
`10
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 10
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`attributes mention above (blocks 74-80). For example, using the determined attributes, a system
`may refer to a stored gesture map that links each of the above mentioned attributes to a particular
`gesture set.”
`
`WESTERMAN at [0118]:
`“FIG. 5 shows illustrative control operation 100, in accordance with one embodiment of the
`present invention. The control operation may begin at block 102 where a determination is made
`as to whether or not a touch is detected. If a touch is detected, the operation can proceed to block
`104 where the arrangement of contacts are recognized. Block 104 may include sub blocks 106
`and 108. In block 106 a determination is made as to whether the contact patches can be precisely
`identified. For example, whether a contact patch may be an index finger or thumb or palm. If
`they cannot be precisely identified, then the operation can proceed to block 108 where the
`number of contact patches are determined. For example, whether there are two contact patches,
`three contact patches, etc. Following block 104, the operation can proceed to block 110 where
`the recognized arrangement of contacts are compared to stored arrangement of contacts in a
`gesture map. If there is no match, then the operation can proceed back to block 102. If there is a
`match, then the operation can proceed to block 112 where after referring to the gesture map, the
`gesture set associated with the initial arrangement of contacts are loaded. Thereafter, in block
`116, the touch can be monitored for gesture events associated with the gesture set. If a gesture
`event is performed, the operation can proceed to block 118 where the command associated with
`the gesture event is performed.”
`
`WESTERMAN at [0119]:
`“FIG. 6 shows illustrative control operation 120, in accordance with one embodiment of the
`present invention. The control operation 120 may begin at block 122 where a touch or near touch
`is detected. Thereafter in block 124 a chord can be determined for the touch. Thereafter, in block
`126, the input functionality associated with chord can be determined.
`…
`Thereafter, in block 128 the gesture set associated with the input functionality can be activated or
`loaded.
`…
`
`11
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 11
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`The gesture event may also include second order parameters that define the first order parameters
`such as speed, direction, shape, timing/duration, length, and/or the like. Thereafter, in block 130,
`actions associated with gesture events can be implemented when gesture events are performed.”
`
`WESTERMAN at [0120]:
`“FIG. 7 shows illustrative gesture operation 140, in accordance with one embodiment of the
`present invention. The operation 140 may begin at block 142 where a touch is detected.
`Following block 144, the operation can proceed to block 144 where an arrangement of contacts
`are recognized. Thereafter, in block 146, the chord associated with the recognized arrangement
`of contacts can be determined. Following block 146, the operation can proceed to block 148
`where the gesture set associated with the chord is loaded. The gesture set contains gesture events
`that can be performed with any arrangement of contacts during the touch. Thereafter, in block
`150, the touch can be monitored for a gesture event performed by any arrangement of contacts. If
`a gesture event has been performed by any arrangement of contacts, the operation can proceed to
`block 152 where the control/command associated with the gesture event is initiated. If a gesture
`event has not been performed, the operation can proceed to block 154 where a determination is
`made as to whether or not a touch is still detected. If a touch is still detected, the operation can
`proceed back to block 150. If a touch is not detected, the operation can proceed back to block
`142. That is, a lift followed by a touch resets the chord and thus the gesture set.”
`
`WESTERMAN at [0122]:
`“FIG. 8 shows illustrative gesture operation 160, in accordance with one embodiment of the
`present invention. The operation 160 may begin at block 162 where a determination is made as
`to whether or not 2 adjacent fingers are detected. If so, the operation can proceed to block 164
`where pointing operations are performed in accordance with motion. If not, the operation can
`proceed to block 166 where a determination is made as to whether or not 3 adjacent fingers are
`detected. If so, the operation can proceed to block 168 where dragging operations are performed
`in accordance with motion. If not, the operation can proceed to block 170 where a determination
`is made as to whether or not a thumb and two adjacent fingers are detected. If so, the operation
`can proceed to block 172 where secondary dragging operations are performed. If not, the
`
`12
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 12
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`operation can proceed to back to block 162. This process can be reset each and every time all the
`fingers are lifted off of the touch surface (e.g., touch is no longer detected).”
`
`WESTERMAN at [0123]:
`“FIG. 9 shows illustrative gesture operation 180, in accordance with one embodiment of the
`present invention. The operation 180 may begin at block 182 where a base chord is determined.
`Thereafter, the operation can perform three different processes either separately or
`simultaneously (parallel blocks 184-188). In block 184, motion can be detected with the base
`chord. Thereafter, in block 190 pointing operations can be performed in accordance with the
`motion. In block 186, a new first digit can be detected. That is, a new first digit not associated
`with the base chord can be detected (in addition to the base chord). Thereafter, in block 192, a
`first command can be initiated each time the new first digit is detected. In some cases, a user can
`perform repetitive commands by continuously tapping the new first digit. In block 188, a new
`second digit can be detected (in addition to the base chord). That is, a new second digit not
`associated with the base chord can be detected. Thereafter, in block 194, a second command can
`be initiated each time the new second digit is detected.”
`
`WESTERMAN at [0126]:
`“FIG. 10 shows illustrative gesture operation 200, in accordance with one embodiment of the
`present invention. The operation 200 may begin at block 202 where a touch is detected.
`Following block 204, the operation can proceed to block 204 where an arrangement of contacts
`are recognized. Thereafter, in block 206, the chord associated with the recognized arrangement
`of contacts can be determined. Following block 206, the operation can proceed to block 208
`where the gesture set associated with the chord is loaded. The gesture set may contain gesture
`events that can be performed with any arrangement of contacts during the touch. Thereafter, in
`block 210, the touch can be monitored for a gesture event performed by any arrangement of
`contacts. If a gesture event has been performed by any arrangement of contacts, the operation
`can proceed to block 212 where the control/command associated with the gesture event is
`initiated. If a gesture event has not been performed, the operation can proceed to block 214
`where a determination is made as to whether the base chord or current arrangement of contacts
`has paused during the touch. If so, the pause can be presumed to be a chord switching event and
`
`13
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2014
`Page 13
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`the operation can proceed back to block 204. If not, the operation can proceed to block 216
`where a determination is made as to whether or not a touch is still detected. If a touch is still
`detected, the operation can proceed back to block 210. If a touch is not detected, the operation
`can proceed back to block 202.”
`
`WESTERMAN at [0128]:
`“FIG. 11 shows illustrative gesture operation 220, in accordance with one embodiment of the
`present invention. The operation 220 may begin at block 222 where a determination is made as
`to whether or not 1 finger is detected. If so, the operation can proceed to block 224 where
`pointing operations are performed in accordance with motion. If not, the operation can proceed
`to block 226 where a determination is made as to whether or not 2 adjacent fingers are detected.
`If so, the operation can proceed to block 228 where dragging operations are performed in
`accordance with motion. In some cases, drag lock/extend may be initiated by clicking and in
`other cases it is initiated by dropping the thumb (two adjacent fingers+thumb). If not, the
`operation can proceed to block 230 where a determination is made as to whether or two non
`adjacent fingers are detected. If so, the operation can proceed to block 232 where secondary
`dragging operations are performed. In some cases, drag lock/extend may be initiated by clicking
`and in other cases it is initiated by dropping the thumb (two non adjacent fingers+thumb). If not,
`the operation can proceed to block 234 where a determination is made as to whether of not 3 or
`four fingers are detected. If so, scrolling can be initiated in accordance with motion (block 236).
`If not the operation can proceed back to block 222. This process can be reset each and every time
`all the fingers are lifted off of the touch surface (e.g., touch is no longer detected) or if the chord
`is paused for a moment.”
`
`WESTERMAN at [0129]:
`“FIG. 12 shows illustrative gesture operation 240, in accordance with one embodiment of the
`present inven