Paper No. 53
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`Trials@uspto.gov
`571-272-7822 Entered: January 4, 2023
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`UNIFIED PATENTS, LLC,
`Petitioner,
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`v.
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`MEMORYWEB, LLC,
`Patent Owner.
`____________
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`IPR2021-01413
`Patent10,621,228 B2
`____________
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`PUBLIC
`Record of Oral Hearing
`Held: December 16, 2022
`
`
`BEFORE: LYNNE H. BROWNE, NORMAN H. BEAMER, and
`KEVIN C. TROCK, Administrative Patent Judges
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`Trials@uspto.gov
`571-272-7822 Entered: January 4, 2023
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`UNIFIED PATENTS, LLC,
`Petitioner,
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`v.
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`MEMORYWEB, LLC,
`Patent Owner.
`____________
`
`IPR2021-01413
`Patent10,621,228 B2
`____________
`
`PUBLIC
`Record of Oral Hearing
`Held: December 16, 2022
`
`
`BEFORE: LYNNE H. BROWNE, NORMAN H. BEAMER, and
`KEVIN C. TROCK, Administrative Patent Judges
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`IPR2021-01413
`Patent 10,621,228 B2
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`A P P E A R A N C E S
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`ON BEHALF OF THE PETITIONER:
`
`
`ELLYAR Y. BARAZESH, ESQUIRE
`ROSHAN MANSINGHANI, ESQUIRE
`MICHELLE ASPEN, ESQUIRE
`UNIFIED PATENTS, LLC
`4445 Willard Avenue
`Suite 600
`Chevy Chase, Maryland 20815
`(202) 894-1874
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`
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`ON BEHALF OF THE PATENT OWNER:
`
`
`JENNIFER HAYES, ESQUIRE
`NIXON PEABODY LLP
`300 South Grand Avenue
`Suite 4100
`Los Angeles, California 90071
`(213) 629-6179
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`ALSO PRESENT:
`Mr. Schwartz and Mr. Christopher
`Charles Slay, Host
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`
`The above-entitled matter came on for hearing on, Friday,
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`December 16, 2022, commencing at 1:00 p.m. EST, by video/by telephone.
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`IPR2021-01413
`Patent 10,621,228 B2
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` P R O C E E D I N G S
` JUDGE TROCK: Good day, everyone. This is Judge
`Trock. With me on the Panel today are Judges Beamer and
`Browne.
` This is in the matter of IPR2021-01413,
`regarding Patent Number 10,621,228, in the matter of
`Unified Patents v. MemoryWeb.
` We'll start with appearances. Counsel for
`Petitioner.
` MR. BARAZESH: Good afternoon, Your Honor. This
`is Ellyar Barazesh, for Petitioner. Also with me is
`Roshan Mansinghani and Michelle Aspen.
` JUDGE TROCK: Okay, Counsel.
` Appearances for Patent Owner.
` MS. HAYES: Good afternoon, Your Honors.
`Jennifer Hayes from Nixon Peabody for Patent Owner,
`MemoryWeb. With me today is Mr. Werber, also from Nixon
`Peabody.
` I also understand that members -- that
`MemoryWeb itself is listening on the public line of this
`hearing, as well are my colleagues, Mr. Schwartz and Mr.
`Christopher.
` JUDGE TROCK: Thank you.
` So thank you all for attending this hearing
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`today. First, I wanted to let everybody know that this
`hearing will be broken up into two sessions. There will
`be a public session that we will have first, and then,
`there will be a confidential section that we will have
`following that. And between the two, though, we will be
`disconnecting the public line so that only the
`Panel and counsel will be attending the confidential
`section.
` There is a court reporter here today who will
`be transcribing everything that's being said.
` So before we begin, I just wanted to cover a
`few things. First, our primary concern here is your
`right to be heard. If at any time during this
`proceeding you encounter a technical or other difficulty
`that you believe undermines your ability to represent
`your client, let us know right away, and contact one of
`the team members that have provided you with the
`connection information today.
` Second, when you are not speaking, please mute
`your microphone. That will make it easier for everybody
`to hear and for the court reporter to take an accurate
`transcript.
` Third, each time you speak, please identify
`yourself. That will also aid the court reporter in
`preparing a transcript.
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` And fourth, we have the entire record, your
`Demonstratives, all the exhibits, and so forth. When
`you are referring them, please refer to them by exhibit
`and page number, so that we can -- and give us a moment
`to pull them up on our screens, and so that we can also
`have that information for the transcript as well.
` Now, before we begin, Petitioner has 75 minutes to present their entire
`case today, and Patent Owner has 60 minutes. We had
`indicated before that you can allocate that
`amount of time as you wish.
` Petitioner, how would you like to allocate
`the 75 minutes of time? And let's start with how much
`time do you want to allocate to the confidential
`section?
` MR. BARAZESH: Thank you, Your Honor. So we'd
`like to allocate ten minutes for the confidential
`section.
` JUDGE TROCK: Okay. So that will give you 65
`minutes for the public section and ten minutes for the
`confidential section.
` Patent Owner, how would you like to allocate
`your time?
` MS. HAYES: We would also like ten minutes for
`the confidential portion.
` JUDGE TROCK: Okay. That will give you ten
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`minutes for the confidential, and then, 50 minutes for
`the public portion.
` Petitioner, you're going to go first, and
`we're going to cover the entire public portion first,
`which means your case in chief, followed by Patent
`Owner's presentation, followed by any rebuttal that you
`reserve, and any rebuttal that the Patent Owner
`reserves.
` So with respect to rebuttal, how much of your
`65 minutes would you like to reserve?
` MR. BARAZESH: Thank you, Your Honor. We'd like
`to reserve 15 minutes for rebuttal.
` JUDGE TROCK: Okay. So that will give you 50
`minutes for your case in chief.
` And then, Patent Owner, how much time would you
`like to reserve for your rebuttal?
` MS. HAYES: Patent Owner would like to reserve
`ten minutes for rebuttal.
` JUDGE TROCK: Okay. And that will give you 40
`minutes for your case in chief.
` All right. Petitioner, you have the floor.
` MR. BARAZESH: Okay. Thank you, Your Honors.
`And may I please the Board.
` My name is Ellyar Barazesh, counsel for
`Petitioner, Unified Patents. I'll be presenting
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`Unified's case, demonstrating that the challenged
`claims, 1 through 7 of the '228 Patent, are
`unpatentable.
` And just so we're all on the same page, I want
`to make sure you all have our Demonstratives handy.
`I'll be referring to those throughout the presentation.
` JUDGE TROCK: We do.
` MR. BARAZESH: So if we first turn to slide 3.
`The '228 Patent is generally directed to managing
`digital files according to location using a map view,
`and people present in the files using a people view. On
`slide 3 of the Demonstrative, we have an example of
`this. This is the map of -- example of the map view
`where thumbnails shown in orange and blue are positioned
`on the map at different locations where content has been
`captured. A user can select one of those thumbnails,
`such as the orange thumbnail, and circled in red.
` And turning to slide 4, another display will
`show all of the content associated with that particular
`location. And this is on slide 4 of Fig. 34 from the
`'228 Patent.
` Turning to slide 5, for the people view,
`various thumbnails are displayed showing the faces of
`people present in content. In the example of slide 5,
`we show first person highlighted in blue, a second
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`person highlighted in purple, that are present in
`content. And by a user selecting one of those
`thumbnails, they will be able to view the content
`associated with that specific person.
` So if we now turn, jump ahead a little bit to
`slide 7, I'll briefly cover the file history of the '228
`Patent just to set up the context of this dispute.
` So during prosecution, the Patent Owner filed a
`preliminary amendment before any examination adding new
`claim, Claim 40, which eventually issued as Claim 1.
`Claim 40 focused only on the map view limitations.
` Turning to slide 8, a first action notice of
`allowance issued, but to get to allowance, the Patent
`Owner agreed to an examiner's amendment incorporating
`the limitations regarding the people view. So what made
`the claim allowable was the addition of the people view.
` But the Petitioner's grounds teach the people
`view limitations as well as the map view limitations.
`And specifically, turning to slide 10, Okamura teaches
`the concept of a people view and a map view.
` So how is this? Okamura is generally directed
`to managing digital files just like the '228 Patent
`according to people present in the files using a face
`tab, which we have highlighted in pink, and location
`associated with the files using a place tab, which we've
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`highlighted in green. The example on slide 10 shows
`Fig. 18, which is what is displayed to a user when they
`select a place tab in green. Content is organized by
`location.
` Jumping ahead to slide 12, we show an example
`of Fig. 21 from Okamura. Now, this figure shows what
`would be displayed when the face tab which we've
`highlighted in pink is selected by a user. Here
`different thumbnail faces of people present in content
`are displayed. And we've highlighted two of those
`people in blue and purple.
` Turning to slide --
` JUDGE TROCK: Counsel, this is Judge Trock. Not
`to interrupt you. But going back to your slide 10, what
`do you say to Patent Owner's argument that what's
`displayed here on this 414 is a matrix of map
`excerpts and it's not an interactive map?
` MR. BARAZESH: Thank you, Your Honor.
` So the position -- the Petition presented two
`different positions for map. It -- it presented that
`the arranged cluster maps form a map, but it also
`combined with the Flora reference which clearly has a
`geographic map, and presented that combination to teach
`the map term as well. And it relied on that
`combination, then, for the details of the interactive
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`map and the thumbnails which come later in the claim.
` So turning back to slide 13, we have the Flora
`reference presented, and as I -- as I just mentioned,
`Flora teaches a geographic map with thumbnails shown in
`orange and blue. Flora again organized -- directed to
`organizing content, and shows a map view that -- that is
`very similar to the '228 Patent.
` And if we actually jump ahead now to slide 21,
`we can kind of focus on what is the main -- one of the
`main disputes in this proceeding. And that's the
`combination of Okamura and Flora. And on slide 21,
`we've reproduced the relevant limitations. It's the map
`view including an interactive map, with a first location
`selectable thumbnail image, and a second location
`selectable thumbnail image on the interactive map.
` So stepping through the combination here,
`Okamura describes this map view in the form of its map
`display area, and that includes content organized by
`location.
` Turning to slide 22, Flora describes a
`geographic -- geographic map having thumbnails showing
`locations where content has been captured. And it also
`describes a media viewer that allows a user to view all
`the content associated with particular location.
` Turning to slide 23, the combination of Okamura
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`and Flora provides that Okamura's map display area
`displays content as taught by Flora's geographic map
`with locations where content has been captured indicated
`by Flora's thumbnails.
` And on slides 23 through 25, we've reproduced
`the just highlights of the motivations to combine that
`the Petition presented.
` Turning to Patent Owner's main dispute, on
`slide 26, essentially argues Patent Owner argues that
`Okamura teaches away. Patent Owner makes some of the
`same arguments regarding teaching away that are made in
`the POPR and some different arguments. But Your Honors
`recognized at institution that Okamura did not teach
`away from the combination with Flora, noting that
`Okamura uses concepts that the Patent Owner says it
`disparage, such as the use of different scales on a map.
` Turning to slide 27, memory rep -- MemoryWeb
`repeated its arguments from the POPR about
`disparagement of scales but actually didn't respond to
`one of the points about Okamura's teachings of using
`scales found in paragraph 93. Paragraph 93 explicitly
`says that in Okamura's system, it has map data
`corresponding to a plurality of scales. And it
`elaborates on how that map data can be used. For
`example, for background map displaying content. An
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`example of that --
` JUDGE TROCK: Counsel, this is Judge Trock
`again.
` MR. BARAZESH: Yes, Your Honor.
` JUDGE TROCK: How do you respond to Patent
`Owner's argument that Okamura recognizes a scaling
`problem with maps when you have content information from
`various geographic locations? And they highlight this
`issue with respect to how Okamura deals with the display
`of content from different geographic areas. For
`example, they talk about the issue of displaying content
`with respect to photographs being taken in Japan and
`Hawaii on the same map, and at a scale if you do it that
`way, you really -- it would be difficult for someone to
`understand the content. And that's why Okamura uses
`that matrix to display these small sections of maps
`rather than one big interactive map. How do you respond
`to that argument?
` MR. BARAZESH: Thank you, Your Honor. So I
`actually have two points for that. So first, actually,
`if we turn to slide 29, Okamura's disclosure is not
`limited to merely having to display content from very
`disparate locations, as Patent Owner tries to
`characterize the reference. For example, Fig. 27A and
`B, which is from Okamura's first embodiment, clearly
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`shows a limited geographic area displaying where content
`has been captured. So that's -- that's kind of the
`first point.
` The second point is that the characterization
`of Okamura as having those issues you mentioned about
`scaleability, Okamura discusses that in the context of a
`specific related art system. And if you actually turn
`to slide 30, the system is described as being, Related
`art where images representing contents and marks
`indicating generated positions of these contents are
`displayed together, and how they can be displayed like
`those components, the orange images representing
`contents, and then, on a map, separate marks indicating
`those generated positions can be displayed relatively
`far apart. And in terms of scaling, it's hard to -- to
`grasp the correspondence between those contents. So
`basically, how the sidebar of images relate to the marks
`on a map.
` And how is that so? Well, it's we've provided
`the snippet from a paragraph 8, which is in Okamura,
`discussing the related art. But we've also pointed to
`Okamura's explicit examples of the related art that it
`points to. It points to two Japanese references,
`Takakura and Fujiwara. Takakura -- and it actually
`points to specific figures from these Japanese
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`references. Takakura at Fig. 7, which we've reproduced
`on slide 30, it shows the orange images representing
`contents and green marks on a map. Similar to Fujiwara
`also in orange, the images side-by-side of the side of a
`map having green outlined marks.
` So the argument about the scaleability is
`limited to these type of systems and the correspondence
`between these components of the system.
` JUDGE TROCK: This is Judge Trock
`again.
` In response to this, Okamura, in its figure,
`has its matrix, it also has the small geographic maps,
`the center one being Mount Fuji, but it also has one
`from Hawaii at the same time. And that's the argument
`that Patent Owner is making.
` So for example, I think they discuss this
`on page 42 of their Response; that if you are
`going to display content from Japan, and content from
`Hawaii, you wouldn't be able to get -- the scale would
`be so large that you wouldn't be able to get any
`recognizable information if you display it on a map that
`way. And that's why Okamura goes to the matrix system
`as opposed to the system that you're proposing
`with Flora. So that's the question I have. How do you
`resolve that?
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` MR. BARAZESH: Thank you, Your Honor. So I
`think that is resolved by again looking at Okamura and
`Figs. 27A and 27B which are actually from the same
`embodiment as Fig. 18 which shows the clusters. And
`this is described in Okamura at 275 to 281, where it
`explains that Fig. 27A and B are another way of
`displaying those clusters. And it's clearly shown in
`those figures. The marks identifying those locations
`are not from -- necessarily from a disparate location
`such as Hawaii and Japan.
` So I think just kind of as a whole, Okamura
`shows that its content doesn't have to be displayed, or
`it doesn't have to display content from all of these
`different disparate locations. Okamura's disclosure
`contemplates displaying content only from kind of a more
`limited geographic location.
` JUDGE TROCK: Okay. Thank you.
` MR. BARAZESH: Thank you, Your Honor.
` So if we move to slide 31, due to those
`differences between -- because -- well, just stepping
`back. As I mentioned about Okamura's related art, it is
`couched in that system of the orange images, and this is
`on slide 30, and the green marks and the correspondence
`issues that you have there.
` Turning to slide 31, Flora doesn't suffer from
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`those issues. Flora doesn't have those correspondence
`issues because its system doesn't have the orange
`side-by-side images with marks on a map, so there isn't
`correspondence issues between the two. And what's
`important to note is Flora's media viewer is only
`displayed when a thumbnail is selected. So there's a
`difference, a significant difference, between Flora and
`Okamura's related art.
` So moving -- unless there are further questions
`on that point, I -- we can actually skip ahead to slide
`33.
` JUDGE TROCK: This is Judge Trock.
` While you have Flora's Fig. 3 up here, let's
`talk about this other issue that Patent Owner raises
`with respect to the Petition. That the Fig. 3 from Flora that you put in your
`Petition actually
`came from the file history, not from the patent, and you
`didn't advise the Board about that. So how are we
`supposed to resolve that issue?
` MR. BARAZESH: Thank you, Your Honor.
` So -- so that issue that you've raised related
`to media viewer and the location name disclosure from
`Flora related to the media viewer. And that was a typo
`in the Petition, and I think how that's resolved is that
`first, the context of Flora, its media viewer is
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`providing information about the -- a particular
`location. That media viewer is displayed when a
`particular thumbnail is selected.
` The next point is that while Your -- Your
`Honors are right, we didn't rely on the file history in
`our ground as, you know, one of the references we're
`relying on. But there's no actual dispute that the
`context -- or the content of the file history in Fig. 3
`is different from the Fig. 3 in Flora. You know, they
`-- they're are the same figure, this is just legibility
`issues.
` The third point is that we have multiple
`grounds that address this issue. So we have the Wagner
`reference, which teaches a specific media viewer that
`clearly shows the location name associated with content,
`issue is the city name. And so from our perspective, we
`teach the location name aspect in multiple ways, and
`that's actually the point that that issue that you
`raised is directed to.
` JUDGE TROCK: Well, the other point, aside from
`the substantive point has to do with the credibility
`part; not advising us. And you mentioned that it is a
`typo. So how are we supposed to resolve that? You're
`not relying on the file history as far as the
`Petition is concerned, but you take something out of the
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`file history to provide. And I understand that it is an
`issue of legibility. We agree that if you look at the
`figure, it's substantially the same
`figure, and the one from the file history is more
`legible and readable. We understand that. The problem
`we have is that you didn't advise us that that figure
`came from the file history and did not come from the
`patent. So what are the consequences of that?
` Even if we agree with you that it was just a
`typo, what are the consequences to that?
` MR. BARAZESH: Well, the consequent -- I -- what
`I can say about that is that there was a mislabeling
`mistake in the Petition. I think that if -- if to the
`extent that the Board is not comfortable relying on that
`version of that figure for Flora for the particular
`limitation that it's been raised for, the location name,
`and just, you know, didn't feel like it wanted to
`consider the reference for that teaching , we have
`presented in the Wagner reference in our other grounds
`the -- the teaching that would show the location name.
`And -- and that is the allegedly kind of unclear part
`from the figure. I'm not sure what consequences there
`would be from having a typo in the Petition. I
`understand kind of the credibility concerns you might
`have, but you know, I think just the response is that it
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`was a mislabeling in the Petition.
` JUDGE TROCK: All right. So your response is if
`we don't rely on this aspect from Flora, that
`you're directing us to Wagner; is that correct?
` MR. BARAZESH: That's correct. And -- and --
`and I think I also want to note that, you know, we
`apologize for the mistake, and to the, you know, that it
`seems to have brought concern to the Panel, that was
`definitely not our intent, and you know, all I can do is
`kind of apologize for that.
` JUDGE TROCK: We understand. We appreciate
`that. And so when this issue was brought up by Patent
`Owner, did you respond to it in the papers, or are
`we hearing this for the first time?
` MR. BARAZESH: No, so we did respond to it. I
`mean, we noted that the file history is a clearer
`version. I think we also noted that Wagner teaches this
`-- this aspect as -- as well. So we did address that
`portion in the -- in the papers.
` JUDGE TROCK: Right, but did you provide the
`explanation you're providing us now that it was a
`typographical mistake?
` MR. BARAZESH: I would -- I would have to check
`what the reply explicitly said. I'm not sure if we went
`into detail on that in the -- in the reply. But again,
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`like, you know, I -- I think that we cover that teaching
`with our backup grounds, and it was a kind of mistake
`that we didn't intend to make, so if -- if we haven't --
`hadn't apologized for that and corrected that
`previously, I definitely do now and take responsibility
`for that.
` JUDGE TROCK: Okay. So I just want to make
`clear so if we're not going to rely on
`this aspect of Flora, you direct us to Wagner, correct?
` MR. BARAZESH: Correct.
` JUDGE TROCK: All right. Thank you.
` MR. BARAZESH: Okay. So thank you, Your Honors.
` So we can move to slide 33. So we've -- there
`are four grounds in this Petition as we've talked about
`Wagner a little bit. But Ground 1, which isn't on slide
`33. It is obviously Okamura and Flora. But we also
`have Grounds 2, 3, 4, that again all of the grounds
`challenging claims 1 through 7, and the majority of
`disputes regarding Grounds 2 through 4 are related to
`the combination of Okamura and Flora in Ground 1.
`Otherwise, the arguments for against Wagner and Gilley,
`which are our separate references in these grounds, are
`generic in high level, and Petitioner's -- from
`Petitioner's view insufficient.
` I'm not going to go into detail on those
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`motivations today, but I -- if we turn to slide 34 -- I
`can if you'd like, but if we turn to slide 34, what I
`will address is the specific limitations that have been
`argued against by the Patent Owner. And it's important
`to note here that these limitations are not actually
`contested for every ground.
` On slides 35 and 36, and starting at slide 35,
`we've provided a table outlining the disputed
`limitations. On slide 35, each of the limitations
`shown, the Petition actually proposed alternative
`positions in Grounds 2 through 4, that the substance of
`which the Patent Owner didn't properly address.
` And turning to slide 36 is where kind of the
`real disputed issues lie. First, the responsive to a
`first input term. And that's what I'll cover next if we
`move to slide 37.
` So slide 37, we just show the entire limitation
`for context. The limitation reads that, Responsive to a
`first input, causing a map view to be displayed on an
`interface, the map view, including interactive map, and
`the first and second thumbnail images on the map.
` At slide 38, we summarized the positions of the
`parties. So and it should be noted that neither party
`has actually proposed a formal construction here. But
`what Patent Owner is essentially doing is interpreting
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`this limitation to require a close-ended situation where
`there cannot be an intervening input between the first
`input and display of a map view. And to put this into
`context, in our combination of the Petition, we don't
`have intervening inputs. So even if Patent Owner's
`interpretation was adopted, our prior art meets it, but
`we still feel that the interpretation is overly
`restrictive because the claim language doesn't require
`it, the specification doesn't require it, and neither
`does the file history. And Patent Owner's own expert
`said that Fig. 41, which Patent Owner relies on, is not
`limiting in this regard.
` Turning to slide 39, we actually stepped
`through what the combination is. And just another note,
`under Petitioner's interpretation, Patent Owner hasn't
`contested the limitation.
` But on slide 39, as the Petition explained, the
`user can select the place tab in green, which is a first
`input, and that causes display of Okamura's map display
`area. There are no intervening inputs there.
` Flora's teachings, as we've touched on a little
`bit previously, is a geographic map with thumbnails at
`various locations. And that's taught to Okamura's map
`display area. So how the combination works is that a
`user selects the place tab, and the geographic map with
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`thumbnail images of various locations is displayed.
` Slide 40. Patent Owner's argument is that
`Flora or the combination requires separate inputs to
`cause display of Flora's thumbnails. But this
`misunderstands the combination. We have provided a
`snippet of the combination from the Petition on slide
`40. The combination is, as I've discussed, as I just
`mentioned, the map display area with Flora's geographic
`map and media viewer, and content of various locations
`indicated by Flora's thumbnails on the geographic map.
` Unless there are any questions, I'll keep
`moving on.
` So turning to slide 41. The next limitation at
`issue is the thumbnail image. Now, for this term,
`Patent Owner argues that -- Patent Owner's argument is
`regarding an accused infringer construction from
`District Court. Patent Owner hasn't actually said that
`this construction should be adopted for thumbnail image,
`and the construction is that a thumbnail is a reduced
`size duplicate of an image. And from Petitioner's
`perspective, no construction is needed here because
`Flora is clear, Flora refers to its icons indicating
`content as thumbnails. So to resolve the disputes
`regarding a thumbnail image, that there is no need to
`construe the term because Flora describes thumbnails.
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` Turning to slide 42, we have actually briefly
`addressed the map term. Again, Patent Owner is focusing
`on the cluster map, but the Petition presented both
`Okamura's teachings as well as the combination of
`Okamura and Flora, and used the combination of Okamura
`and Flora for the details of the map as the claim
`recites.
` So next, actually, turning to slide 43, this
`actually goes to the location name claim term which we
`were discussing previously. And I'm actually going to
`address Wagner now, because as I've mentioned, Wagner is
`used in Grounds 2 and 4 for the teaching of a location
`name. Wagner clearly displays the city, the city name
`associated with content and the media viewer, and this
`shown in Fig. 5B of the Wagner reference Ex. 1006.
`Patent Owner's argument questioning reliance on Wagner
`is that Okamura already accomplishes this function. So
`it says Okamura already describes the location name.
`But what Wagner explicitly specifies is that the
`location name is displayed in a media viewer, and that
`that location name is a city name in the media viewer
`that's associated with content.
` Turning to slide 44, the Petition also
`presented Flora's teachings of the location's name as
`we've already discussed.
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` And on slide 45, also presented Okamura as
`teaching location information and the location name in
`terms of it describing, for example, Mt. Fuji, or
`Tokyo-prefecture, or an address associated with various
`content.
` Unless there are any questions on that, I'll
`turn to slide 46. Here, the limitations at issue are
`the first name and second name. And Patent Owner is
`arguing that the plain meaning requires simultaneous
`display of a first name and second name in the people
`view.
` Again, Petitioner's perspective is that the --
`the claims are not this restrictive in the claim
`language, the spec, or the file history, but also, our
`grounds render this limitation obvious under either
`interpretation, under Patent Owner's or P
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