1
`
`Samsung Electronics Co., Ltd.
`v.
`MemoryWeb, LLC
`
`IPR2022-00221
`U.S. Patent No. 10,423,658
`
`Patent Owner’s Demonstrative Exhibit
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`MemoryWeb Ex. 2034
`Samsung v. MemoryWeb - IPR 2022-00221
`
`
`
`Samsung Electronics Co., Ltd.
`v.
`MemoryWeb, LLC
`
`IPR2022-00221
`U.S. Patent No. 10,423,658
`
`Patent Owner’s Demonstrative Exhibit
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`MemoryWeb Ex. 2034
`Samsung v. MemoryWeb - IPR 2022-00221
`
`
`
`2
`
`’658 Patent Overview –
`Methods of Organizing and Displaying
`Digital Files that Allow Preservation of
`Memory Details
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`’658 Patent Overview
`
`3
`
`EX1001, 1:61 – 67
`
`EX1001, 13:31 – 35
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1001, cover
`
`POR, 1-6
`
`
`
`’658 Patent Overview – “views”
`
`4
`
`Map View
`
`Location View
`
`People View
`
`Person View
`
`EX1001, FIG. 34
`
`EX1001, FIG. 32
`
`EX1001, FIG. 7
`
`EX1001, FIG. 41
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 1-6
`
`
`
`’658 Patent Overview – the “map view” including
`an “interactive map”
`
`5
`
`EX1001, FIG. 41
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 1-6
`
`EX1001, 29:48 – 55
`
`
`
`’658 Patent Overview – the “location view”
`
`6
`
`EX1001, FIG. 34
`
`EX1001, 24:37 – 41
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 1-6
`
`
`
`’658 Patent Overview – the “people view”
`
`7
`
`EX1001, FIG. 32 (excerpted)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 1-6
`
`EX1001, FIG. 7
`
`
`
`’658 Patent Overview – the “person view”
`
`8
`
`EX1001, FIG. 32
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 1-6
`
`EX1001, FIG. 7
`
`
`
`9
`
`Claim Construction
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Claim 1
`
`10
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 13-17
`
`
`
`11
`
`Claim
`Construction
`
`CLAIMS 1, 3-5, 7, AND 9-15
`“RESPONSIVE TO”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`“responsive to”
`
`“responsive to … displaying” requires a cause-effect relationship
`
`12
`
`Claim Term/Phrase
`
`Patent Owner’s Construction
`
`Petitioner’s Construction
`
`“responsive to a click or
`tap . . . displaying . . . ”
`
`(claims 3-5, 7, 9-10, 12-15)
`
`Plain and ordinary meaning:
`
`requiring a cause-effect
`relationship between (i) a click or
`tap of the _____ and (ii) displaying
`_____
`
`“the term ‘responsive to’ merely
`requires that the second event
`happen ‘subsequent to’ the first
`event based on a combination of
`user interaction and software
`implementation.”
`
`POR, 17-25
`
`Reply, 4
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 17-25; POSR, 1-6
`
`
`
`“responsive to … displaying” requires a cause-effect
`relationship
`Claim 5: “responsive to a click or tap of the people selectable element, displaying a people view”
`
`13
`
`Claims 7 and 10: “responsive to a click or tap of the [first/second] person selectable thumbnail image,
`displaying a [first/second] person view”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1001, FIG. 32 (modified and annotated)
`
`POR 21-23; POSR, 4-5, 9-11
`
`EX1001, 22:60 – 23:4
`
`
`
`“responsive to … displaying” requires a cause-effect
`relationship
`
`14
`
`Petitioner does not distinguish any of Patent Owner’s authority
`
`American Calcar, Inc. v. American Honda Motor Co., Inc.,
`651 F.3d 1318, 1339-1340 (Fed. Cir. 2011)
`
`Microsoft Corp. v. FG SRC, LLC,
`860 F. App'x 708, 714 (Fed. Cir. 2021)
`
`Fujitsu Ltd. v. Belkin Int'l, Inc.,
`2012 U.S. Dist. LEXIS 142102, at *88
`(N.D. Cal. Sep. 28, 2012)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 19-20; POSR, 1-2
`
`
`
`“responsive to … displaying” requires a cause-effect
`relationship
`
`15
`
`“responsive to” does not mean “subsequent to”
`
`Dr. Greenspun’s Second Deposition
`
`The Reply
`
`Reply, 4
`
`EX1047, ¶7
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX2033, 17:11-25
`
`POSR, 1-2
`
`
`
`“responsive to … displaying” requires a cause-effect
`relationship
`
`16
`
`“responsive to … displaying” requires a cause-effect relationship
`
`Dr. Greenspun’s Second Deposition
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 1-4
`
`EX2033, 20:23-21:6
`
`
`
`“responsive to … displaying” requires a cause-effect
`relationship
`
`17
`
`“responsive to … displaying” requires a cause-effect relationship
`
`Dr. Greenspun’s First Deposition
`
`Dr. Greenspun’s Second Declaration
`
`EX2024, 92:3-13
`
`EX1047, ¶ 7
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 25; POSR, 1-2
`
`
`
`“responsive to … displaying” requires a cause-effect
`relationship
`
`18
`
`The ‘658 patent’s sort function does not support Petitioner’s construction
`
`Dr. Greenspun’s Second Deposition
`
`Prof. Reinman’s Deposition
`
`EX2033, 23:16-24:1
`
`EX1046, 74:4-17
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 5
`
`
`
`“responsive to … displaying” requires a cause-effect
`relationship
`
`19
`
`The ‘658 patent’s “Items Per Page” feature does not support Petitioner’s construction
`
`Dr. Greenspun’s Second Deposition
`
`EX1001, FIG. 32 (excerpted)
`
`EX1001, 22:55-58
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX2033, 59:23-60:24
`
`POSR, 5
`
`
`
`“responsive to … displaying” requires a cause-effect
`relationship
`
`20
`
`FIG. 13 does not support Petitioner’s construction
`
`EX1001, FIG. 6
`
`EX1001, FIG. 13
`
`EX1001, 3:20-21
`
`EX2033, 40:16-24
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 6
`
`
`
`21
`
`Claim
`Construction
`
`CLAIM 5:
`RESPONSIVE TO A CLICK OR TAP …
`DISPLAYING A PEOPLE VIEW, THE
`DISPLAYING THE PEOPLE VIEW
`INCLUDING DISPLAYING…
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Claim 5: the “people view”
`
`22
`
`Claim 5 requires displaying all claimed “people view” elements simultaneously
`
`Petitioner’s Reply
`
`Reply, 8
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1001, 36:28-49
`
`POR, 25-28 POSR, 7-11
`
`EX1001, FIG. 32
`
`
`
`Claim 5: the “people view”
`
`23
`
`The experts agree that the “adjacent to” language requires each name and associated thumbnail
`be displayed simultaneously
`
`Prof. Reinman
`
`EX2023, ¶ 132
`
`Dr. Greenspun’s Second Deposition
`
`EX2033, 47:5-24
`
`EX2033, 47:25 – 48:12
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 26-27; POSR, 7
`
`
`
`Claim 5: the “people view”
`
`24
`
`Claim 5
`
`The Reply
`
`Reply, 9
`
`Dr. Greenspun Second Deposition
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX2033, 56:20 – 57:8
`
`POSR, 8-9
`
`
`
`Claim 5: the “people view”
`
`The “people view” and “person view” are different
`
`25
`
`Dr. Greenspun
`
`EX2033, 44:10-17
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1001, FIG. 32 (annotated)
`
`POSR, 8-9
`
`
`
`Claim 5: the “people view”
`
`Claim 6 reinforces that all items must be displayed simultaneously
`
`26
`
`EX1001, 36:50-55
`
`EX1001, FIG. 32
`
`EX1001, FIG. 32
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 9
`
`
`
`27
`
`Claim
`Construction
`
`CLAIM 13:
`“THE DISPLAYING THE ALBUM
`VIEW INCLUDING DISPLAYING:
`… A FIRST ALBUM NAME
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Claim Construction: Claim 13
`
`28
`
`Claim 13 requires displaying both album thumbnails and names simultaneously
`
`EX1001, 37:21-38:13
`
`EX1001, FIG. 33
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 29-30; POSR, 11-12
`
`
`
`29
`
`Claim
`Construction
`
`CLAIM 1: “APPLICATION
`VIEW”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`‘658: The “application view” is a distinct view
`
`30
`
`Claim Term
`
`Patent Owner’s Construction
`
`Petitioner’s Construction
`
`application view
`
`application view that is distinct from the
`map view, the first location view, and
`the second location view
`
`a type of application view
`
`POR, 13-17; POSR, 12-13
`
`Reply, 2-3
`
`Claim 1
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 13-17; POSR, 12-13
`
`
`
`‘658: The “application view” is a distinct view
`
`31
`
`people view
`
`album view
`
`map view
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 14-17
`
`
`
`‘658: The “application view” is a distinct view
`
`32
`
`Dr. Greenspun First Deposition
`
`Dr. Greenspun Second Deposition
`
`Dr. Greenspun Second Declaration
`
`EX1047, ¶ 5
`
`EX2024, 39:19-40:2
`
`EX2033, 61:15-62:15
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 12-13
`
`
`
`33
`
`Petitioner Has Not Carried Its
`Obviousness Burden
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`34
`
`Petitioner did
`not meet its
`burden for
`claims 7-10
`
`CLAIMS 7 AND 10:
`
`“RESPONSIVE TO A CLICK OR
`TAP OF THE [FIRST/SECOND]
`PERSON SELECTABLE
`THUMBNAIL IMAGE, DISPLAYING
`A [FIRST/SECOND] PERSON
`VIEW”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Okamura does not disclose displaying the
`claimed “[first/second] person view”
`
`35
`
`Claim 7
`
`Petition
`
`EX1001, 36:56-62
`
`Petition, 80
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 69-75; POSR,13-18
`
`
`
`Okamura does not disclose displaying the
`claimed “[first/second] person view”
`
`36
`
`Okamura’s Purported Disclosure
`
`FIG. 21
`
`FIG. 24
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Petition, 81; EX1003, FIGS. 21 and 24 (annotated)
`
`POR, 69; POSR, 14
`
`
`
`Okamura does not disclose displaying the
`claimed “[first/second] person view”
`
`37
`
`Okamura’s Actual Disclosure
`
`Okamura FIGS. 21-24 (annotated)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 15
`
`
`
`Okamura does not disclose displaying the
`claimed “[first/second] person view”
`
`38
`
`Prof. Reinman
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX2023, ¶ 278
`
`POR, 69, 72; POSR, 15
`
`
`
`Okamura does not disclose displaying the
`claimed “[first/second] person view”
`
`39
`
`Dr. Greenspun’s Second Deposition
`
`Petitioner’s Reply
`
`Reply, 26
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX2033, 152:18-153:7
`
`POSR, 15
`
`
`
`Okamura does not disclose displaying the
`claimed “[first/second] person view.”
`
`40
`
`Dr. Greenspun’s First Deposition
`
`Okamura’s Flow Diagrams
`
`EX2024, 123:22-124:9
`
`EX1005, FIG. 32
`(excerpted and annotated)
`
`EX1005, FIG. 33
`(excerpted and annotated)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 73-75; POSR, 15
`
`
`
`Okamura does not disclose displaying the
`claimed “[first/second] person view.”
`
`41
`
`EX1005, FIG. 21
`
`EX1005, FIG. 24
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1005, FIG. 21 (excerpted)
`
`EX1005, FIG. 24 (excerpted)
`
`POSR, 15
`
`
`
`Okamura FIG. 24 is not displayed “responsive to”
`a click or tap on FIG. 21
`
`42
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 14-18
`
`
`
`The Petition did not proffer an obviousness
`argument for claims 7 and 10
`
`43
`
`Dr. Greenspun’s First Deposition
`
`Dr. Greenspun’s Second Deposition
`
`c
`
`EX2024, 125:2-10
`
`EX2033, 131:4-10
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 17
`
`
`
`44
`
`Okamura does
`not render claim
`5 obvious
`
`CLAIM 5:
`“THE DISPLAYING THE PEOPLE
`VIEW” INCLUDING
`DISPLAYING ITEMS (I) – (IV)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Okamura does not disclose displaying any name
`responsive to a click or tap
`
`45
`
`Prof. Reinman
`
`EX2023, ¶ 264
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1005, ¶ [0247]
`
`POR 65-67; POSR, 18
`
`
`
`Petitioner did not make an obviousness
`argument in the Petition
`
`46
`
`Petitioner’s Reply
`
`Dr. Greenspun’s First Deposition
`
`Reply, 24
`
`EX2024, 112:2-8
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 67-68; POSR, 18-19
`
`
`
`Petitioner did not make an obviousness
`argument in the Petition
`
`47
`
`Dr. Greenspun’s First Declaration (¶ 162)
`
`Dr. Greenspun’s Second Deposition
`
`EX2033, 121:4-18
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1003, ¶ 162
`
`POR, 67-68; POSR, 19-20
`
`
`
`Petitioner did not make an obviousness
`argument in the Petition
`
`48
`
`Dr. Greenspun’s Second Deposition
`
`Dr. Greenspun’s Second Deposition (‘228
`Testimony)
`
`EX2033, 123:4-12
`
`EX2033, 124:7-24
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 67-68; POSR, 19-20
`
`
`
`A POSITA would not have modified Okamura
`
`49
`
`Okamura employs mouse hovering to avoid cluttering the screen with excessive content.
`
`Prof. Reinman
`
`Dr. Greenspun’s Second Deposition
`
`EX2023, ¶ 268
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 67-68; POSR, 19-21
`
`EX2033, 118:12-21
`
`
`
`A POSITA would not have modified Okamura
`
`50
`
`Dr. Greenspun’s Second Deposition
`
`Prof. Reinman
`
`EX2033, 116:1-6
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1046, 111:11-25
`
`POSR, 18
`
`
`
`51
`
`Okamura does
`not render
`claims 13-15
`obvious
`
`CLAIMS 13-15:
`DISPLAYING THE “ALBUM VIEW”
`AND “THE [FIRST/SECOND]
`ALBUM VIEW”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Okamura does not disclose displaying multiple
`album names simultaneously
`
`52
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1003, ¶ 198 (annotating EX1005, FIG. 20)
`
`POR, 86-87; POSR, 22
`
`
`
`Okamura does not disclose displaying multiple
`album names simultaneously
`
`53
`
`Prof. Reinman
`
`EX2023, ¶ 327
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX2023, ¶ 328
`
`POR, 87-88
`
`
`
`Petitioner did not make an obviousness
`argument in the Petition
`
`54
`
`Dr. Greenspun Second Deposition
`
`Dr. Greenspun First Deposition
`
`EX2033, 144:21-145:11
`
`EX2024, 188:20-189:5
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 22
`
`
`
`Petitioner did not make an obviousness
`argument in the Petition
`
`55
`
`Dr. Greenspun’s Second Deposition
`
`Dr. Greenspun’s First Declaration
`
`EX2033, 149:23-150:8
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1003, ¶ 76
`
`POSR, 22
`
`
`
`Petitioner did not make an obviousness
`argument in the Petition
`
`56
`
`Dr. Greenspun’s Second Deposition
`
`Dr. Greenspun’s First Declaration
`
`EX2033, 150:9-21
`
`EX1003, ¶ 75
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 22
`
`
`
`57
`
`Okamura and
`Belitz do not
`render obvious
`claim 1
`
`PETITIONER’S FIRST
`COMBINATION
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Petitioner's First Combination Would Not Have
`Been Obvious
`
`58
`
` A POSITA Would Not Have Been Motivated to Replace Okamura’s Cluster Maps with
`Images That Are Not Maps
`
` Petitioner’s First Combination is Analogous to “Related Art” Discredited by Okamura
`
` Petitioner’s First Combination Also Conflicts with Belitz’s Objectives
`
` Petitioner’s Alleged “Motivations” Lack Merit
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 31-53; POSR, 23-28
`
`
`
`Petitioner's First Combination
`
`59
`
`Okamura
`
`Belitz
`
`Okamura + Belitz
`
`EX1005, Fig. 41
`
`EX1006, Fig. 4b
`
`Petition, 23, 47
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 39-48; POSR, 23-28
`
`
`
`Petitioner's First Combination
`
`60
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX2024, 47:5-48:6
`
`EX1003, ¶ 121
`
`POR, 31-33; POSR, 23-28
`
`
`
`Petitioner's First Combination Would Not Have
`Been Obvious
`A POSITA Would Not Have Been Motivated to Replace Okamura’s Cluster Maps with Images That
`Are Not Maps
`
`61
`
`EX1005, ¶ [0331]
`
`EX1005, ¶ [0325]
`
`EX1005, FIG. 41 (partial)
`
`EX1005, ¶ [0213]
`
`EX1005, ¶ [0421]
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 7-10, 33-35
`
`
`
`Petitioner's First Combination Would Not Have
`Been Obvious
`A POSITA Would Not Have Been Motivated to Replace Okamura’s Cluster Maps with Images That
`Are Not Maps
`
`62
`
`Belitz
`
`Prof. Reinman
`
`EX1006, [0011]
`
`EX2023, ¶ 188
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 36, 57
`
`POR, 33; EX1005, FIG. 41 (partial)
`
`POR, 33; EX1006, FIG. 4b (partial)
`
`
`
`Petitioner's First Combination Would Not Have
`Been Obvious
`
`63
`
`The First Combination is Analogous to “Related Art” Discredited by Okamura
`
`Okamura
`
`. . . .
`
`Okamura
`
`Related Art
`
`EX1005, Fig. 41
`
`EX2020, Fig. 1 (annotated)
`
`Polaris Indus., Inc. v. Arctic Cat, Inc., 882 F.3d 1056, 1069 (Fed. Cir. 2018)
`
`its statements regarding
`“[E]ven if a reference is not found to teach away,
`preferences are relevant to a finding regarding whether a skilled artisan would be
`motivated to combine that reference with another reference.”`
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 38-42
`
`
`
`Petitioner's First Combination Would Not Have
`Been Obvious
`
`64
`
`The First Combination is Analogous to “Related Art” Discredited by Okamura
`
`EX1005, ¶ [0005]
`
`EX1005, ¶ [0006]
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 38-42
`
`
`
`Petitioner's First Combination Would Not Have
`Been Obvious
`
`65
`
`The First Combination is Analogous to “Related Art” Discredited by Okamura
`
`EX1005, ¶ [0008]
`
`EX1005, ¶ [0010]
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1005, ¶ [0009]
`
`POR, 38-43
`
`
`
`Petitioner's First Combination Would Not Have
`Been Obvious
`
`66
`
`The First Combination is Analogous to “Related Art” Discredited by Okamura
`
`Dr. Greenspun’s Second Deposition
`
`Dr. Greenspun’s Second Declaration
`
`EX2033, 96:10-14
`
`EX1047, ¶ 21
`
`Polaris Indus., Inc. v. Arctic Cat, Inc., 882 F.3d 1056, 1069 (Fed. Cir. 2018)
`
`its statements regarding
`“[E]ven if a reference is not found to teach away,
`preferences are relevant to a finding regarding whether a skilled artisan would be
`motivated to combine that reference with another reference.”`
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 42-43, 47; POSR 24-25
`
`
`
`Petitioner's First Combination Would Not Have
`Been Obvious
`
`67
`
`The First Combination Conflicts with Belitz’s Objectives
`
`Belitz
`
`EX1006, [0054]
`
`Clutter
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 11, 44-45, 50, 56
`
`Overlap
`
`Petition, 23, 47 (partial)
`
`
`
`Petitioner's First Combination Would Not Have
`Been Obvious
`
`68
`
`Okamura and Belitz are not “functionally equivalent”
`
`Dr. Greenspun’s Second Deposition
`
`Reply, 13
`
`Map
`
`Image
`
`Town
`
`Landmark
`
`Road
`
`≠
`
`EX1005, FIG. 41 (partial)
`
`EX1006, FIG. 4b (partial)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX2033, 93:16-94:7
`
`POR, 49-51; POSR, 25-26
`
`
`
`Petitioner’s Alleged “Motivations” Lack Merit
`
`69
`
`Belitz’s Thumbnails Reduce the Ability to Provide a View of “What Location Is Associated With What”
`
`Zoomed-in view of
`underlying map
`
`Small image obstructing
`view of underlying map
`
`Belitz
`
`EX1006, ¶ [0002]
`
`Okamura
`
`EX1005, ¶ [0331]
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX1005, FIG. 41 (partial); EX1006, FIG. 4b (partial)
`
`POR, 45-48
`
`
`
`Petitioner’s Alleged “Motivations” Lack Merit
`
`70
`
`Okamura Already Allows a User to “Preview Pictures”
`
`Kinetic Concepts, Inc. v. Smith & Nephew, Inc.,
`688 F.3d. 1342, 1369 (Fed. Cir. 2012)
`
`references
`these
`of
`both
`addition,
`In
`functions,
`independently accomplish similar
`namely, draining fluids. Because each device
`independently operates effectively, a person
`having ordinary skill
`in the art, who was merely
`seeking to create a better device to drain fluids
`from a wound, would have no reason to
`combine the features of both devices into a
`single device.
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 45-49
`
`EX1005, FIG. 41
`
`
`
`Petitioner's First Combination Would Not Have
`Been Obvious
`
`71
`
`Thumbnail Images Are Not “Known and Predictable Alternative[s]” To Cluster Maps
`
`Prof. Reinman
`
`EX2023, ¶ 224
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 49
`
`
`
`72
`
`Okamura and
`Belitz do not
`render obvious
`claim 1
`
`PETITIONER’S
`SECOND
`COMBINATION
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Petitioner’s Second Combination Would Not
`Have Been Obvious
`
`73
`
`Petitioner’s Second Combination Carries The Same Deficiencies as Petitioner’s First Combination
`
`content listing display area 782
`comprising multiple “contents” (i.e.
`images)
`
`EX1006, FIG. 4b; EX1005, FIG. 41 (annotated)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 54-57; POSR 28-29
`
`
`
`Petitioner’s Second Combination Would Not
`Have Been Obvious
`
`74
`
`Petitioner’s Second Combination Carries The Same Deficiencies as Petitioner’s First Combination
`
`Belitz
`
`When multiple
`images correspond
`to one location,
`shown via pop-up
`window
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 54-57; POSR 28-29
`
`EX1006, FIGS. 4a – 4c
`
`
`
`Petitioner’s Second Combination Would Not
`Have Been Obvious
`
`75
`
`Petitioner’s Second Combination Carries The Same Deficiencies as Petitioner’s First Combination
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 54-57; POSR 28-29
`
`EX1005, FIG. 41 (annotated)
`
`EX1006, FIG. 4c (annotated)
`
`
`
`Petitioner’s Second Combination Would Not
`Have Been Obvious
`
`76
`
`Much of The Information Shown in FIG. 41 of Okamura Would Be Lost if Displayed According to Belitz
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 54-57; POSR 28-29
`
`EX1005, FIG. 41 (annotated); POSR, 29
`
`
`
`77
`
`Okamura and
`Belitz do not
`render obvious
`claim 1
`
`PETITIONER’S
`THIRD
`COMBINATION
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Petitioner’s Third Combination Would Not Have
`Been Obvious
`
`78
`
`Petitioner’s Third Combination Also Eliminates Cluster Maps
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 58-60; POSR, 30-31
`
`EX1006, FIG. 4b; EX1005, FIG. 18 (annotated)
`
`
`
`Petitioner’s Third Combination Would Not Have
`Been Obvious
`“a [first/second] location selectable thumbnail image at a [first/second] location on the interactive
`map”
`
`79
`
`Belitz
`
`Okamura
`
`Map in one scale
`
`Maps of different
`scales
`
`Tokyo
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 58-60; POSR, 30-31
`
`EX1006, FIG. 4b
`
`Hawaii
`
`EX1005, FIG. 18
`
`
`
`80
`
`CLAIM 1: “APPLICATION
`VIEW”
`
`Okamura does
`not disclose a
`distinct
`“application
`view”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Okamura Does Not Disclose A Distinct
`“Application View”
`
`81
`
`Okamura’s alleged “map” and “application” views
`
`Dr. Greenspun’s Second Deposition
`
`EX1005, FIG. 18 (annotated); POSR, 31-32
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX2033, 107:23-108:1-12
`
`POR, 61-62; POSR, 31-32
`
`
`
`Okamura Does Not Disclose A Distinct
`“Application View”
`
`82
`
`Prof. Reinman
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 61-62; POSR, 31-32
`
`EX2023, ¶ 254
`
`
`
`83
`
`Okamura does
`not render
`obvious claims 9
`and 12
`
`CLAIMS 9 AND 12:
`“DISPLAYING A
`REPRESENTATION OF ALL
`LOCATIONS”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Okamura and Yee do not disclose displaying
`“all locations”
`
`84
`
`Prof. Reinman
`
`Petition, 84 (annotating EX1005, FIG. 23)
`
`EX2023, ¶ 293
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 75-77
`
`
`
`Okamura and Yee do not disclose displaying
`“all locations”
`
`85
`
`Prof. Reinman
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 79-80
`
`EX2023, ¶ 307
`
`
`
`Okamura and Yee do not disclose displaying
`“all locations”
`
`86
`
`Prof. Reinman
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 79-80
`
`EX2023, ¶¶ 308-309
`
`
`
`Okamura and Yee do not disclose displaying
`“all locations”
`
`87
`
`Prof. Reinman
`
`EX2023, ¶ 318
`
`EX1041, FIG. 1 (annotated)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 81-85; POSR, 33
`
`
`
`88
`
`Okamura does
`not render
`obvious claims
`3-4
`
`CLAIMS 3-4:
`THE “[FIRST/SECOND] MAP
`IMAGE”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`
`
`Okamura does not disclose displaying a “map
`image” responsive to a click/tap of a scaled replica
`
`89
`
`“responsive to a click or tap of a first one of the displayed scaled replicas in the first location views,
`displaying . . . a first map image”
`
`Prof. Reinman
`
`EX2023, ¶ 259
`
`EX1005, FIG. 50; EX1003 ¶ 152 (annotated)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 63-64; POSR, 32-33
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Patent Owner’s
`
`Demonstrative Exhibit was served on May 2, 2023, by email:
`
`IPR39843-0116IP1@fr.com
`
`PTABInbound@fr.com
`
`axf-ptab@fr.com
`
`jjm@fr.com
`
`in@fr.com
`
`cgreen@fr.com
`
`Counsel for Petitioner, Samsung Electronics Co., Ltd.
`
`By: /s/ Jennifer Hayes
`Counsel for Patent Owner
`
`
`
`
`
`
`
`
`
`
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