throbber
1
`
`Samsung Electronics Co., Ltd.
`v.
`MemoryWeb, LLC
`IPR2022-00222
`U.S. Patent No. 10,621,228
`Patent Owner’s Demonstrative Exhibit
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`MemoryWeb Ex. 2027
`Samsung v. MemoryWeb - IPR 2022-00222
`
`

`

`2
`
`’228 Patent Overview –
`Methods of Organizing and Displaying
`Digital Files that Allow Preservation of
`Memory Details
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`

`

`’228 Patent Overview
`
`3
`
`Ex. 1001, 1:61 – 67
`
`EX1001, 13:31 – 35
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex.1001, cover
`
`ID, 3-4; POSR, 14-17
`
`

`

`’228 Patent Overview – “views”
`
`Location View
`
`People View
`
`Map View
`
`Ex. 1001, FIG. 41
`
`4
`
`Person View
`
`Ex. 1001, FIG. 7
`
`Ex. 1001, FIG. 34
`
`Ex. 1001, FIG. 32
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 1-4
`
`

`

`’228 Patent Overview – the “map view” including
`an “interactive map”
`
`5
`
`Ex. 1001, FIG. 41
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex. 1001, 29:48 – 55
`
`POR, 1-2
`
`

`

`’228 Patent Overview – the “location view”
`
`6
`
`Ex. 1001, 24:37 – 41
`
`Ex. 1001, FIG. 34
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 2-3
`
`

`

`’228 Patent Overview – the “people view”
`
`7
`
`Ex. 1001, 22:59 – 23:4
`
`Ex. 1001, FIG. 32
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 3-4
`
`

`

`’228 Patent Overview – the “first person view”
`
`8
`
`Ex. 1001, 23:12 – 22
`
`Ex. 1001, 38:8 – 13
`
`Ex. 1001, FIG. 32
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 4, 17-19
`
`

`

`9
`
`Claim Construction
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`

`

`Claim 1
`
`10
`
`Relevant
`Limitations
`
`[1g]
`
`[1h]-[1i]
`
`[1j]-[1k]
`
`Claim Language
`
`[g] responsive to a second input …
`causing a people view to be
`the
`displayed on the interface,
`people view including:
`(i) a first person selectable thumbnail
`image … (ii) a first name . . . displayed
`adjacent to the first person selectable
`thumbnail image …
`(iii) a second person selectable
`thumbnail image … and (iv) a second
`name . . . displayed adjacent to the
`second person selectable thumbnail
`image
`
`POR, 11, 14, 28
`
`Ex. 1001, 35:32 – 36:11
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`

`

`11
`
`Claim
`Construction
`
`[1G] “RESPONSIVE TO”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`

`

`“responsive to”
`
`12
`
`The “people view” displayed in response to the “second input” must include a “first name”
`
`Ex. 1001, 35:61 – 67
`
`Reply, 3 – 4
`
`Ex. 1001, 22:60 – 23:4
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 11-13; POSR, 4-6
`
`

`

`“responsive to”
`
`13
`
`The “people view” displayed in response to the “second input” must include a “first name”
`
`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, 11-12; POSR, 1-4
`
`

`

`“responsive to”
`
`14
`
`The “people view” displayed in response to the “second input” must include a “first name”
`
`Petitioner and Dr. Greenspun
`
`Helmsderfer v. Bobrick Washroom Equip., Inc.,
`527 F.3d 1379, 1381-82 (Fed. Cir. 2008)
`
`Petitioner’s Reply, Paper 24, 3
`
`Ex. 1001, 35:61 – 67
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 11-13; POSR, 1-4
`
`

`

`“responsive to”
`
`15
`
`The “people view” displayed in response to the “second input” must include a “first name”
`
`“People” (1401)
`
`Ex. 1001, FIG. 32
`
`Drop-down (1402) to sort
`
`Ex. 1001, 22:60 – 23:4
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR 11-13; POSR, 4-6
`
`

`

`“responsive to”
`
`16
`
`The “people view” displayed in response to the “second input” must include a “first name”
`
`Dr. Greenspun (August 2022 Deposition)
`
`Dr. Greenspun (December 2022 Declaration)
`
`Dr. Greenspun (January 2022 Deposition)
`
`Ex. 1041, ¶ 5
`
`Ex. 2022, 50:4 – 15
`
`Ex. 2025, 38:1 – 10
`
`EX2025, 9:22-10:1
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 4-6
`
`

`

`“responsive to”
`
`17
`
`The “people view” displayed in response to the “second input” must include a “first name”
`
`“People” (1401)
`
`Ex. 1001, FIG. 32
`
`“Items Per Page” button 1405
`
`Ex. 1001, 22:60 – 23:6
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 4-6
`
`

`

`“responsive to”
`
`18
`
`The “people view” displayed in response to the “second input” must include a “first name”
`
`Dr. Greenspun
`
`Ex. 1001, 23:12 – 25
`
`Ex. 2025, 59:2 – 12
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 4-6
`
`

`

`19
`
`Claim
`Construction
`
`LIMITATIONS [1G], [1I] AND
`[1K]: “THE PEOPLE VIEW
`INCLUDING: . . . A FIRST
`NAME … [AND] … A
`SECOND NAME”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`

`

`“responsive to a second input… the people view
`including:… a first name…[and] a second name”
`The “people view” displayed in response to the “second input” must include both a “first name”
`and a “second name”
`
`20
`
`Claim 1
`
`Ex. 1001, Fig. 32
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex. 1001, 35:63 – 36:11
`
`Ex. 1001, 22:60 – 23:6
`
`POR, 14-17; POSR, 9-10
`
`

`

`
`“responsive to a second input… the people view “responsive to a second input… the people view
`
`including:… a first name…[and] a second name”including:… a first name…[and] a second name”
`The “people view” displayed in response to the “second input” must include both a “first name”
`The “people view” displayed in response to the “second input” must include a “second name”
`and a “second name”
`
`21
`
`Dr. Reinman
`
`Ex. 2023, ¶ 73 – 74
`
`Ex. 1040, 68:9 – 21
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 14-17; POSR, 12
`
`

`

`
`“responsive to a second input… the people view “responsive to a second input… the people view
`
`including:… a first name…[and] a second name”including:… a first name…[and] a second name”
`The “people view” displayed in response to the “second input” must include both a “first name”
`The “people view” displayed in response to the “second input” must include a “second name”
`and a “second name”
`
`22
`
`Dr. Greenspun
`
`. . .
`
`Ex. 2025, 69:9 – 13
`
`Ex. 2022, 52:3 – 13
`
`Ex. 2025, 61:10 –
`13
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 14-17; POSR, 9-11
`
`

`

`
`“responsive to a second input… the people view “responsive to a second input… the people view
`including:… a first name…[and] a second name”
`including:… a first name…[and] a second name”
`The “people view” displayed in response to the “second input” must include both a “first name”
`The “people view” displayed in response to the “second input” must include a “second name”
`and a “second name”
`
`23
`
`Dr. Greenspun
`
`EX2025, 102:1 – 103:22; EX2026
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 14-17; POSR, 12-15
`
`

`

`“responsive to a second input… the people view
`including:… a first name…[and] a second name”
`The “people view” displayed in response to the “second input” must include both a “first name”
`and a “second name”
`
`24
`
`Claim 1 (“people view”)
`
`Dr. Greenspun (“person view”)
`
`=
`
`EX2025, 102:1 – 103:22; EX2026
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex. 1001, 35:63 – 36:11
`
`POR, 14-17; POSR, 14-15
`
`

`

`25
`
`Claim
`Construction
`
`DEPENDENT CLAIM 18
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`

`

`Claim 18
`
`26
`
`Relevant
`Limitations
`
`[1g]-[1h]
`
`[18a]
`
`[18b]
`
`Claim Language
`
`(i) the people view including … a first
`person selectable thumbnail image
`“The method of
`claim 1,
`further
`comprising responsive to an input that is
`indicative of a selection of the first person
`selectable thumbnail
`image, causing a
`first person view to be displayed . . .”
`“the first person view including (i) the first
`name and (ii) a representation of each
`digital file in the third set of digital files.”
`
`Ex. 1001, 38:7 – 13
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 17-19; POSR, 15-16
`
`

`

`“first person view… including a representation of
`each digital file in the third set of digital files”
`Claim 18 requires (i) receiving an “input” from the “people view” of limitation [1h]; and
`(ii) in response to that input, displaying a “first person view” that “includes a representation of each
`digital file in the third set of digital files
`
`27
`
`Ex. 1001, 6:24 – 26
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 17-19; POSR, 15-16
`
`Ex. 1001, FIG. 6
`
`Ex. 1001, FIG. 7
`
`

`

`“first person view… including a representation of
`each digital file in the third set of digital files”
`Claim 18 requires (i) receiving an “input” from the “people view” of limitation [1h]; and
`(ii) in response to that input, displaying a “first person view” that “includes a representation of each
`digital file in the third set of digital files
`First name
`
`28
`
`First name
`
`Ex. 1001, FIG. 32
`
`Ex. 1001, FIG. 7
`
`Representation of each digital
`file in the third set of digital files
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 17-19; POSR, 15-16
`
`

`

`29
`
`Petitioner Has Not Carried Its
`Obviousness Burden
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`

`

`30
`
`Obviousness
`
`[1G, 1I] “RESPONSIVE TO A
`SECOND INPUT … CAUSING
`A FIRST PEOPLE VIEW TO BE
`DISPLAYED … THE PEOPLE
`VIEW INCLUDING: . . . A FIRST
`NAME”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`

`

`Okamura Fails to Disclose a “second input” That Causes
`the Display of a “people view… including… a first name”
`
`31
`
`Petition
`
` “second input”
`
` “responsive to a second
`input … causing a first
`people view to be
`displayed . . . including . . .
`a first name”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Petition, 46
`
`POR, 20-25; POSR, 16-18
`
`

`

`Okamura Fails to Disclose a “second input” That Causes
`the Display of a “people view… including… a first name”
`
`32
`
`Okamura
`
`Ex. 1005, [0247]
`
`Dr. Reinman
`
`Ex. 2023, ¶ 91
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 20-25; POSR, 16-18
`
`

`

`Petitioner’s New “responsive to”
`Obviousness Theory Is Improper
`
`33
`
`Reply
`
`Dr. Greenspun (Second Declaration)
`
`Reply, 11
`
`Ex. 1041, ¶ 16; Reply 11 – 12
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 20-25; POSR, 16-18
`
`

`

`Petitioner’s New “responsive to”
`Obviousness Theory Is Improper
`
`34
`
`Dr. Greenspun (First Declaration)
`
`Dr. Greenspun (Jan. 2023 Deposition)
`
`Ex. 1003, ¶ 143
`
`Ex. 2025, 118:16 – 25
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 20-25; POSR, 16-18
`
`

`

`Petitioner’s New “responsive to”
`Obviousness Theory Is Improper
`
`35
`
`Starbucks Corporation et al v. Fall Line Patents, LLC, IPR2019-00610,
`Paper 42, at 35-36 (PTAB May 17, 2022)
`
`Intelligent Bio-Sys., Inc. v. Illumina Cambridge Ltd.,
`821 F.3d 1359, 1370 (Fed. Cir. 2016)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 20-25; POSR, 16-18
`
`

`

`36
`
`Obviousness
`
`[1G, 1I, 1K] “PEOPLE VIEW
`INCLUDING: . . . A FIRST
`NAME … [AND] … A
`SECOND NAME”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`

`

`Okamura Fails to Disclose a “people view” Including a
`“first name” and a “second name” in the Same View
`
`37
`
`Petition
`
`Dr. Reinman
`
`Petition, 54
`
`Ex. 2023, ¶¶ 99, 101 – 103
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 25-27
`
`

`

`Petitioner’s New “people view” Obviousness
`Theory Is Improper
`
`38
`
`Reply
`
`Dr. Greenspun (Second Declaration)
`
`Ex. 1041, ¶ 18
`
`Reply, 11
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 20-25; POSR, 18-19
`
`

`

`Petitioner’s New “people view” Obviousness
`Theory Is Improper
`“the people view including: . . . a first name . . . and . . . a second name”
`
`39
`
`Dr. Greenspun
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POSR, 18-19
`
`Ex. 2025, 92:6 – 93:6
`
`

`

`Petitioner’s New “people view” Obviousness
`Theories Fall Short
`“the people view including: . . . a first name . . . and . . . a second name”
`
`40
`
`Dr. Greenspun
`
`Dr. Reinman
`
`Ex. 2025, 108:12 – 24
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex. 2023, ¶ 96 – 97
`
`POR, 14-17; POSR, 19-21
`
`

`

`41
`
`Obviousness
`
`OKAMURA / BELITZ
`COMBINATION
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`

`

`“a [first/second] location selectable thumbnail image at
`a [first/second] location on the interactive map”
`
`42
`
`Interactive map
`
`Ex. 1001, 35:32 – 39
`
`First location selectable
`thumbnail image
`
`Second location selectable
`thumbnail image
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex. 1001, FIG. 41
`
`POR, 28
`
`

`

`Petitioner's First Combination Would Not Have
`Been Obvious
`
`43
`
` 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
`
`

`

`Petitioner's First Combination
`
`44
`
`Okamura
`
`Belitz
`
`Okamura + Belitz
`
`Ex. 1004, Fig. 41
`
`Ex. 1006, Fig. 4b
`
`Petition, 14
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 28-29
`
`

`

`Petitioner's First Combination
`
`45
`
`Dr. Greenspun
`
`EX2022, 70:21-73:6
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 28-31
`
`

`

`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
`
`46
`
`Ex. 1005, [0331]
`
`Ex. 1005, [0325]
`
`Ex. 1005, FIG. 41 (partial)
`
`Ex. 1005, [0213]
`
`Ex. 1005, [0421]
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 31-35
`
`

`

`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
`
`47
`
`Belitz
`
`Dr. Reinman
`
`Ex. 1006, [0011]
`
`Ex. 2023, ¶ 127
`
`POR, 33; Ex. 1005, FIG. 41 (partial)
`
`POR, 33; Ex. 1006, FIG. 4b (partial)
`
`POR, 33
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 31-35
`
`

`

`Petitioner's First Combination Would Not Have
`Been Obvious
`The First Combination is Analogous to “Related Art” Discredited by Okamura
`
`48
`
`Okamura
`
`. . . .
`
`Okamura
`
`Related Art
`
`EX1005, Fig. 41
`Polaris Indus., Inc. v. Arctic Cat, Inc., 882 F.3d 1056, 1069 (Fed. Cir. 2018)
`“[E]ven if a reference is not found to teach away,
`its statements regarding
`preferences are relevant to a finding regarding whether a skilled artisan would be
`motivated to combine that reference with another reference.”`
`
`EX2020, Fig. 7 (annotated)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 35-42; POSR, 24-26
`
`

`

`Petitioner's First Combination Would Not Have
`Been Obvious
`The First Combination is Analogous to “Related Art” Discredited by Okamura
`
`49
`
`Ex. 1005, ¶ [0005]
`
`Ex. 1005, ¶ [0006]
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 35-42; POSR, 24-26
`
`

`

`Petitioner's First Combination Would Not Have
`Been Obvious
`The First Combination is Analogous to “Related Art” Discredited by Okamura
`
`50
`
`Ex. 1005, ¶ [0008]
`
`Ex. 1005, ¶ [0010]
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex. 1005, ¶ [0009]
`
`POR, 35-42; POSR, 24-26
`
`

`

`Petitioner's First Combination Would Not Have
`Been Obvious
`The First Combination is Analogous to “Related Art” Discredited by Okamura
`
`51
`
`Large Scale Map Scenario
`
`Small Scale Map Scenario
`
`Dr. Greenspun
`
`EX2022, 98:10-99:21
`
`EX2022, 143:12-144:15
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`EX2025, 143:12-144:15
`
`POR, 35-42; POSR, 24-26, 30
`
`

`

`Petitioner's First Combination Would Not Have
`Been Obvious
`The First Combination Conflicts with Belitz’s Objectives
`
`52
`
`Belitz
`
`Ex. 1006, [0054]
`
`Clutter
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 42-43
`
`Overlap
`
`Petition, 4 (partial)
`
`

`

`Petitioner’s Alleged “Motivations” Lack Merit
`
`53
`
`Thumbnail Images Are Not “Functionally Equivalent” To Cluster Maps
`
`Map
`
`Image
`
`Dr. Greenspun
`
`Town
`
`Landmark
`
`Road
`
`≠
`
`Ex. 1005, FIG. 41 (partial)
`
`Ex. 1006, FIG. 4b (partial)
`
`EX2025; 131:5-132:4
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 46-50; POSR, 22-23
`
`

`

`Petitioner’s Alleged “Motivations” Lack Merit
`
`54
`
`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
`
`Ex. 1006, [0002]
`
`Okamura
`
`Ex. 1005, [0331]
`
`Ex. 1005, FIG. 41 (partial); Ex. 1006, FIG. 4b (partial); Petition, 14, 34 (partial)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 43-46
`
`

`

`Petitioner’s Alleged “Motivations” Lack Merit
`
`55
`
`Okamura Already Allows a User to “Preview Pictures”
`
`Kinetic Concepts, Inc. v. Smith & Nephew, Inc.,
`688 F.3d. 1342, 1369 (Fed. Cir. 2012)
`addition,
`both
`of
`these
`references
`In
`independently accomplish similar
`functions,
`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, 46
`
`Ex. 1005, FIG. 41
`
`

`

`Petitioner's First Combination Would Not Have
`Been Obvious
`Thumbnail Images Are Not “Known and Predictable Alternative[s]” To Cluster Maps
`
`56
`
`Dr. Reinman
`
`Ex. 2023, ¶ 158
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 46-50; POSR, 22-23
`
`

`

`Petitioner's First Combination Would Not Have
`Been Obvious
`Petitioner Has Also Failed to Establish That the First Combination Would Be Used with Okamura’s
`FACE Index Screen
`
`57
`
`Relevant
`Limitations
`
`[1c]-[1d]
`
`[1g]
`
`Claim 1 Language
`
`“a [first/second] location
`selectable
`thumbnail
`image at a [first/second]
`location
`on
`the
`interactive map”
`“responsive to a second
`input . . . causing a first
`people
`view to
`be
`displayed . . . the people
`view including: . . .”
`Ex. 1001, 35:32 – 36:11
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`[1c]-[1d]
`
`[1g]
`
`Petition, 26 – 27; Ex. 1005, FIGS. 41, 21 (annotated)
`
`POR, 50-52
`
`

`

`Petitioner's First Combination Would Not Have
`Been Obvious
`Petitioner Has Also Failed to Establish That the First Combination Would Be Used with Okamura’s
`FACE Index Screen
`
`58
`
`Petition, 26 – 27; Ex. 1005, FIGS. 41, 21 (annotated)
`
`Ex. 1005, FIG. 49 (partial)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex. 1005, FIG. 17
`
`POR, 50-52
`
`

`

`Petitioner’s Second Combination Would Not
`Have Been Obvious
`Petitioner’s Second Combination Carries The Same Deficiencies as Petitioner’s First Combination
`
`59
`
`content listing display area 782
`comprising multiple “contents” (i.e.
`images)
`
`Petition, 19; Ex. 1006, FIG. 4b; Ex. 1005, FIG. 41 (annotated)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 52-56; POSR 28-29
`
`

`

`Petitioner’s Second Combination Would Not
`Have Been Obvious
`Petitioner’s Second Combination Carries The Same Deficiencies as Petitioner’s First Combination
`
`60
`
`Belitz
`
`When multiple
`images correspond
`to one location,
`shown via pop-up
`window
`
`Ex. 1023, ¶ 176
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex. 1006, FIGS. 4a – 4c
`
`POR, 52-56; POSR 28-29
`
`

`

`Petitioner’s Second Combination Would Not
`Have Been Obvious
`Much of The Information Shown in FIG. 41 of Okamura Would Be Lost if Displayed According to Belitz
`
`61
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 52-56; POSR 28-29
`
`Ex. 1005, FIG. 41 (annotated)
`
`

`

`Petitioner’s Third Combination Would Not Have
`Been Obvious
`Petitioner’s Third Combination Also Eliminates Cluster Maps
`
`62
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 57-59; POSR 29-30
`
`Petition, 19; Ex. 1006, FIG. 4b; Ex. 1005, 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”
`
`63
`
`Belitz
`
`Okamura
`
`Map in one scale
`Ex. 1023, ¶ 51, 184
`
`Ex. 1023, ¶ ¶ 55, 136
`Maps of different
`scales
`
`Tokyo
`Ex. 1023, ¶ 186
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex. 1006, FIG. 4b
`
`Hawaii
`Ex. 1023, ¶ 186
`
`Ex. 1005, FIG. 18
`
`POR, 57-59; POSR 29-30
`
`

`

`64
`
`Claim 18
`“responsive to an input … causing a first person view
`to be displayed … first person view including (i) the first
`name and (ii) a representation of each digital file in
`the third set of digital files”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`

`

`Okamura fails to disclose an “input” that displays a “first person
`view including … “a representation of each digital file”
`“responsive to an input … causing a first person view to be displayed … first person view including (i)
`the first name and (ii) a representation of each digital file in the third set of digital files”
`
`65
`
`Petitioner’s Theory
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 61-63; POSR 30-33
`
`Petition, 78 – 79; Ex. 1005, FIGS. 21, 24 (annotated by Petitioner)
`
`

`

`Okamura fails to disclose an “input” that displays a “first person
`view including … “a representation of each digital file”
`“responsive to an input … causing a first person view to be displayed … first person view including (i)
`the first name and (ii) a representation of each digital file in the third set of digital files”
`
`66
`
`Petitioner’s Theory
`
`Okamura
`
`Ex. 1005, [0261]
`
`Petition, 78 – 79; Ex. 1005, FIGS. 21, 24
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Ex. 1005, FIG. 23
`
`POR, 61-63; POSR 30-33
`
`

`

`Okamura fails to disclose an “input” that displays a “first person
`view including … “a representation of each digital file”
`In Okamura, there are additional views, user decisions and inputs between Fig. 21 “input” and Fig.
`24 “representation of each digital file”
`
`67
`
`Step One
`
`Okamura
`
`Ex. 1005, FIGS. 21, 22
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 61-63; POSR 30-33
`
`

`

`Okamura fails to disclose an “input” that displays a “first person
`view including … “a representation of each digital file”
`In Okamura, there are additional views, user decisions and inputs between Fig. 21 “input” and Fig.
`24 “representation of each digital file”
`
`68
`
`Step Two
`
`Okamura
`
`Ex. 1005, FIGS. 22, 23
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 61-63; POSR 30-33
`
`

`

`Okamura fails to disclose an “input” that displays a “first person
`view including … “a representation of each digital file”
`In Okamura, there are additional views, user decisions and inputs between Fig. 21 “input” and Fig.
`24 “representation of each digital file”
`
`69
`
`Step Three
`
`Okamura
`
`Ex. 1005, FIG. 23
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 61-63; POSR 30-33
`
`

`

`Okamura fails to disclose an “input” that displays a “first person
`view including … “a representation of each digital file”
`In Okamura, there are additional views, user decisions and inputs between Fig. 21 “input” and Fig.
`24 “representation of each digital file”
`
`70
`
`Step Four
`
`Okamura
`
`Ex. 1005, FIGS. 23, 24
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`POR, 61-63; POSR 30-33
`
`

`

`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Patent Owner’s
`
`Demonstrative Exhibit was served on March 9, 2023, upon the following parties via
`
`electronic service:
`
`IPR39843-0117IP1@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
`Lead Counsel for Patent Owner
`
`
`
`

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