`IPR2022-00222
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` Declaration of Professor Glenn Reinman, Ph.D
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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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`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
`v.
`MEMORYWEB, LLC
`Patent Owner
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`Patent No. 10,621,228
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`Inter Partes Review No. IPR2022-00222
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`DECLARATION OF PROFESSOR GLENN REINMAN, PH.D
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`Table of Contents
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`Page
`INTRODUCTION ................................................................................. 1
`I.
`BACKGROUND AND QUALIFICATIONS ...................................... 1
`II.
`III. MATERIALS CONSIDERED .............................................................. 6
`IV. LEGAL STANDARDS ......................................................................... 8
`A. Anticipation ........................................................................................ 8
`B. Obviousness ....................................................................................... 9
`C. Method Claims ................................................................................. 13
`D. Dependent Claims ............................................................................ 13
`V. OVERVIEW OF THE ‘228 PATENT ................................................ 13
`VI. THE ‘228 PATENT’S EFFECTIVE FILING DATE ......................... 19
`VII. LEVEL OF SKILL IN THE ART ....................................................... 19
`VIII. Summary of Petitioner’s References ................................................... 20
`IX. OPINIONS .......................................................................................... 45
`A. Comparison Petitioner’s Okamura and Belitz Combination and
`other IPRs 45
`1.
`Comparison between Belitz (Samsung) and Flora (Unified) .......... 45
`2.
`Comparison between Okamura + Belitz (Samsung) and A3UM +
`Belitz (Apple) ....................................................................................................... 50
`B. Ground 1: Okamura and Belitz ........................................................ 55
`X.
`CONCLUSION ................................................................................... 76
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` Declaration of Professor Glenn Reinman, Ph.D
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`Patent No. 10,621,228
`IPR2022-00222
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`I, Glenn Reinman, declare as follows:
`I.
`INTRODUCTION
`1.
`I have been retained on behalf of MemoryWeb, LLC, (“MemoryWeb”
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`or “Patent Owner”) as an independent expert consultant to provide this declaration
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`concerning the technical subject matter relevant to the inter partes review (“IPR”)
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`petition of U.S. Patent No. 10,621,228 (“the ‘228 patent”) filed by Samsung
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`Electronics Co., Ltd. (“Petitioner” or “Samsung”).
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`2.
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`I am being compensated at my standard hourly rate of $750 per hour
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`for the time I spend on this matter. My compensation is not related in any way to
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`the outcome of this proceeding, and I have no other interest in this proceeding.
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`3.
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`In this declaration, I offer my expert opinion regarding the technical
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`subject matter of claims 1-19 (“the challenged claims”) of the ‘228 patent.
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`Specifically, I have considered whether claims 1-19 of the ‘228 patent are valid
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`under 35 U.S.C. § 103. The substance and bases of my opinions appear below.
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`II. BACKGROUND AND QUALIFICATIONS
`4.
`A copy of my curriculum vitae is appended hereto as Appendix A. I
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`am currently a professor of Computer Science, serving as vice chair of the Computer
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`Science department, at the University of California, Los Angeles (UCLA).
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`5.
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`I received a Bachelor of Science degree in Computer Science and
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`Engineering from the Massachusetts Institute of Technology (MIT) in June 1996. In
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`March 1999, I received a Master of Science degree in Computer Science from the
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`University of California at San Diego. I received my Doctor of Philosophy degree
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`in Computer Science from the University of California at San Diego in June 2001.
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`6.
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`In 2001, I became an Assistant Professor at the University of California
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`in Los Angeles (UCLA) in the Department of Computer Science. In 2007, I was
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`promoted to the position of an Associate Professor, and in 2014, I became a Full
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`Professor. From 2016 through 2019, I was the Graduate Vice Chair of the Computer
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`Science department at UCLA, in charge of the Graduate Degree Program. Starting
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`in 2021, I became the Undergraduate Vice Chair of the Computer Science
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`department at UCLA, in charge of the Undergraduate Degree Program.
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`7.
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`I teach subjects in computer science, such as computer systems
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`architecture, microprocessor design, microprocessor simulation, distributed and
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`parallel systems.
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`8.
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`I began my career with summer internships at Intel Corporation and
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`Compaq (now HP) in 1998 and 1999, respectively. At Intel I researched issues such
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`as the viability of caching state from the branch predictor, the translation lookaside
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`buffer, and the branch target buffer in the second-level data cache. I also modified
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`SimpleScalar—a system software infrastructure used to build modeling applications
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`for program performance analysis, microarchitectural modeling, and hardware-
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`software co-verification—to use ITR traces for Windows applications for
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`predictability experiments, as well as running simulations with SimpleScalar to test
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`the effectiveness of this technique. At Compaq, I expanded the CACTI cache
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`compiler (CACTI 2.0), including enhancing CACTI 2.0 to include a fully associative
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`cache model, power modeling, multiple port models, transistor tuning, and tag path
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`balancing.
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`9.
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`From 1997 through 2001, I served as a research assistant at the
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`University of California at San Diego, where I implemented a profile-based
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`approach to classifying loads for memory renaming, value prediction, and
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`dependence prediction using SimpleScalar and ATOM (Analysis Tools with OM). I
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`also created a fetch unit with a branch prediction structure called FTB, as well as
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`working with SimpleScalar to generate a hybrid predictive technique including
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`renaming, value prediction, address prediction, and dependence prediction.
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`10. Starting in 2002, I began teaching Computer Science classes at UCLA.
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`During my time at UCLA, I have implemented a flipped classroom in my
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`undergraduate courses, where I provide video content ahead of class with my
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`lectures, and then use the classroom to answer questions and work through sample
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`problems. These undergraduate courses are large, often 400 students or more in a
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`single class. Such large classes require robust and efficient web sites to host the
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`video content for the students, and I have spent considerable time and effort in
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`designing and maintaining these web sites.
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`11. From 2011 to 2021, I designed, implemented, and maintained multiple
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`websites outside of UCLA including multi-media content (e.g., photos, videos, etc.)
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`with user interfaces for displaying the content. The websites were built on a Joomla
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`framework, and I added a great deal of custom PHP scripting to implement signup,
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`store, and content delivery functionality. The site hosted multimedia content
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`including video and photos, and needed to be designed for a lay audience.
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`12.
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`I am a named inventor on two U.S. Patents, and have published around
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`100 papers, textbook chapters, and reports on such topics as steering behaviors,
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`accelerator-rich architectures, RF interconnects, microarchitecture design, computer
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`animation, 3D integration, 3D architecture modeling, multi-actor simulations, real-
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`time physics simulation, error-tolerance in physics-based animation, micro-
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`architecture pipelining, classifying load and store instructions for memory renaming,
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`predictive techniques for load speculation, and instruction scheduling. I have
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`received awards or other recognition from organizations such as the International
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`Symposium on High-Performance Computer Architecture, the Engineering Society
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`of the University of California, and the National Science Foundation.
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`13.
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`I have also participated in organizations like the International
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`Symposium on Microarchitecture, Computing Frontiers, the Symposium on
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`Interactive 3D Graphics and Games (I3D), the Workshop on Memory Systems
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`Performance, the International Symposium on Computer Architecture, and the
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`International Conference on Compilers, Architecture, and Synthesis for Embedded
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`Systems.
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`14.
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`I have performed research in many computer science areas. For
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`example, I have researched multimedia streaming, compression, and encryption as
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`part of an effort to create application-specific hardware to reduce the latency and
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`power consumption associated with these applications. I have also researched
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`interactive entertainment, specifically focusing on the user’s perception of a virtual
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`world. In particular, I surveyed users to gauge how realistic they felt an interactive
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`experience was when using approximate computing to improve processing
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`efficiency. This work included graphics, navigation, and real-time physics. In
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`addition to a number of publications, this research resulted in the creation of
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`SteerSuite, a set of virtual world scenarios that could be used to benchmark the
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`navigation/steering and physics algorithms of other researchers.
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`15.
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`I have also developed an approximate computing architecture that uses
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`lightweight checking to verify the quality of neural network-based computing
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`elements. I have proposed an accelerator-rich microprocessor design that uses a
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`heterogeneous set of building blocks to dynamically compose different accelerators
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`depending on application demand. I developed a chip multiprocessor design for real-
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`time physics called “ParallAX,” which enhances parallel processing capabilities for
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`reducing demand on the system. Similarly, I researched hierarchical floating point
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`using dynamic precision reduction to reduce the area required at each fine grain core
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`by sharing resources.
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`16.
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`In 2009, my collaborators and I competed for and received an NSF
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`Expedition award for our proposal that has established the Center for Domain
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`Specific Computing (CDSC) here at UCLA (the lead institution), along with other
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`faculty from Rice University, Ohio State, and UCSB. I am one of four faculty on the
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`executive committee of this Center. I lead the Architecture Thrust of this Center, in
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`charge of designing our customizable hardware platform. This grant had been
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`extended in 2014 to cover further extensions to healthcare including genomics, and
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`is still currently providing funding to the Center. For example, we have targeted
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`medical imaging as one candidate application. We researched best practices in
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`medical imaging (e.g., MRI) for de-blurring, de-noising, image registration, image
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`segmentation, and recognition, and also implemented customized software/hardware
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`solutions to reduce patient wait time.
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`III. MATERIALS CONSIDERED
`17.
`In forming the opinions set forth in this declaration, I have considered
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`and relied upon my education, knowledge of the relevant field, and my experience.
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`I have also reviewed and considered the ‘228 patent (Ex. 1001) and its file history
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`(Ex. 1002), and at least the following additional materials:
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` Petition for Inter Partes Review of the ‘228 Patent (“Petition”)
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`Patent No. 10,621,228
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` Declaration of Dr. Philip Greenspun (Ex. 1003)
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` U.S. Patent App. Pub. No. 2011/0122153 (“Okamura,” Ex. 1005)
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` U.S. Patent App. Pub. No. 2010/0058212 (“Belitz,” Ex. 1006)
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` U.S. Patent App. Pub. No. 2011/0074811 (“Hanson,” Ex. 1021)
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` Stephen Shankland, “What’s the best Web site for geotagged photos?”
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`CNET (Mar. 18, 2009) (Ex. 1022)
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` Panoramio, “Embedding a Panoramio map into your web” (Archive.org:
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`Mar. 28, 2010) (Ex. 1023)
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` U.S. Patent App. Pub. No. 2009/0113350 (“Hibino”)
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` U.S. Patent App. Pub. No. 2006/0165380 (“Tanaka”)
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` Certified English Translation of Japanese Unexamined Patent
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`Application Publication No. 2001-160058 (“Fujiwara,” Ex. 2002)
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` Certified English Translation of Japanese Unexamined Patent
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`Application Publication No. 2007-323544 (“Takakura,” Ex. 2003)
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` U.S. Patent No. 6,714,215 (“Flora,” Ex. 2004)
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` Petition for Inter Partes Review, Apple Inc. v. MemoryWeb, LLC,
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`IPR2022-00031, Paper 1 (filed Oct. 30, 2021) (Ex. 2007)
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` Petition for Inter Partes Review, Unified Patents, LLC v. MemoryWeb,
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`LLC, IPR2021-001413, Paper 2 (filed Sept. 3, 2021)
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`I reserve the right to amend and supplement this declaration in light of
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`additional evidence, arguments, or testimony should an IPR be instituted.
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`IV. LEGAL STANDARDS
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`18.
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`I am not a patent attorney nor have I independently researched the law
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`on patentability. I have a general understanding of validity, prior art and priority
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`date based on my discussions with counsel.
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`A. Anticipation
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`19.
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`I understand that anticipation analysis is a two-step process. The first
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`step is to determine the meaning and scope of the asserted claims. Each claim must
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`be viewed as a whole, and it is improper to ignore any element of the claim. For a
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`claim to be anticipated under U.S. patent law: (1) each and every claim element must
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`be identically disclosed, either explicitly or inherently, in a single prior art reference;
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`(2) the claim elements disclosed in the single prior art reference must be arranged in
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`the same way as in the claim; and (3) the identical invention must be disclosed in the
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`single prior art reference, in as complete detail as set forth in the claim. Where even
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`one element is not disclosed in a reference, the anticipation contention fails.
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`Moreover, to serve as an anticipatory reference, the reference itself must be enabled,
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`i.e., it must provide enough information so that a person of ordinary skill in the art
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`can practice the subject matter of the reference without undue experimentation.
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`20.
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`I further understand that where a prior art reference fails to explicitly
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`disclose a claim element, the prior art reference inherently discloses the claim
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`element only if the prior art reference must necessarily include the undisclosed claim
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`element. Inherency may not be established by probabilities or possibilities. The fact
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`that an element may result from a given set of circumstances is not sufficient to prove
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`inherency. I have applied these principles in forming my opinions in this matter.
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`B. Obviousness
`21.
`I understand that a patent claim is invalid under 35 U.S.C. § 103 as
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`being obvious only if the differences between the claimed invention and the prior art
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`are such that the subject matter as a whole would have been obvious at the time the
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`invention was made to a person of ordinary skill in that art. An obviousness analysis
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`requires consideration of four factors: (1) scope and content of the prior art relied
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`upon to challenge patentability; (2) differences between the prior art and the claimed
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`invention; (3) the level of ordinary skill in the art at the time of the invention; and
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`(4) the objective evidence of nonobviousness, such as commercial success,
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`unexpected results, the failure of others to achieve the results of the invention, a
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`long-felt need which the invention fills, copying of the invention by competitors,
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`praise for the invention, skepticism for the invention, or independent development.
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`22.
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`I understand that a prior art reference is proper to use in an obviousness
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`determination if the prior art reference is analogous art to the claimed invention. I
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`understand that a prior art reference is analogous art if at least one of the following
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`two considerations is met. First, a prior art reference is analogous art if it is from
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`the same field of endeavor as the claimed invention, even if the prior art reference
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`addresses a different problem and/or arrives at a different solution. Second, a prior
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`art reference is analogous art if the prior art reference is reasonably pertinent to the
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`problem faced by the inventor, even if it is not in the same field of endeavor as the
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`claimed invention.
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`23.
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`I understand that it must be shown that one having ordinary skill in the
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`art at the time of the invention would have had a reasonable expectation that a
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`modification or combination of one or more prior art references would have
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`succeeded. Furthermore, I understand that a claim may be obvious in view of a
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`single prior art reference, without the need to combine references, if the elements of
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`the claim that are not found in the reference can be supplied by the knowledge or
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`common sense of one of ordinary skill in the relevant art. However, I understand
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`that it is inappropriate to resolve obviousness issues by a retrospective analysis or
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`hindsight reconstruction of the prior art and that the use of “hindsight reconstruction”
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`is improper in analyzing the obviousness of a patent claim.
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`24.
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`I further understand that the law recognizes several specific guidelines
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`that inform the obviousness analysis. First, I understand that a reconstructive
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`hindsight approach to this analysis, i.e., the improper use of post-invention
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`information to help perform the selection and combination, or the improper use of
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`the listing of elements in a claim as a blueprint to identify selected portions of
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`different prior art references in an attempt to show that the claim is obvious, is not
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`permitted. Second, I understand that any prior art that specifically teaches away
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`from the claimed subject matter, i.e., prior art that would lead a person of ordinary
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`skill in the art to a specifically different solution than the claimed invention, points
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`to non-obviousness, and conversely, that any prior art that contains any teaching,
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`suggestion, or motivation to modify or combine such prior art reference(s) points to
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`the obviousness of such a modification or combination. Third, while many
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`combinations of the prior art might be “obvious to try,” I understand that any obvious
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`to try analysis will not render a patent invalid unless it is shown that the possible
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`combinations are: (1) sufficiently small in number so as to be reasonable to conclude
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`that the combination would have been selected; and (2) such that the combination
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`would have been believed to be one that would produce predictable and well
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`understood results. Fourth, I understand that if a claimed invention that arises from
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`the modification or combination of one or more prior art references uses known
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`methods or techniques that yield predictable results, then that factor also points to
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`obviousness. Fifth, I understand that if a claimed invention that arises from the
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`modification or combination of one or more prior art references is the result of
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`known work in one field prompting variations of it for use in the same field or a
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`different one based on design incentives or other market forces that yields predicable
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`variations, then that factor also points to obviousness. Sixth, I understand that if a
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`claimed invention that arises from the modification or combination of one or more
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`prior art references is the result of routine optimization, then that factor also points
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`to obviousness. Seventh, I understand that if a claimed invention that arises from
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`the modification or combination of one or more prior art references is the result of a
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`substitution of one known prior art element for another known prior art element to
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`yield predictable results, then that factor also points to obviousness.
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`25.
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`I understand that each alleged prior art reference in a proposed
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`obviousness combination must be evaluated as an entirety, i.e., including those
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`portions that would argue against obviousness, and must be considered for
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`everything that it teaches, not simply the described invention or a preferred
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`embodiment. I understand that it is impermissible to pick and choose from any one
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`reference only so much of it as will support a given position to the exclusion of other
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`parts necessary to the full appreciation of what such reference fairly suggests to one
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`skilled in the art, or to ignore portions of the reference that argue against
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`obviousness. I also understand that all of the supposed prior art to be combined as
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`proposed must also be evaluated as a whole, and should be evaluated for what they
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`teach in combination as well as separately.
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`C. Method Claims
`26.
`I understand that as a general rule, unless the steps of a method actually
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`recite an order, the steps are not ordinarily construed to require one. However, I
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`understand that such a result can ensue when the method steps implicitly require that
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`they be performed in the order written. I understand that this determination involves
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`a two-part inquiry: (1) whether the claim language requires an order as a matter of
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`logic or grammar; and (2) if the answer to (1) is in the negative, whether the
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`specification directly or implicitly requires such a narrow construction.
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`D. Dependent Claims
`27.
`I understand that a dependent claim incorporates each and every
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`limitation of the claim from which it depends. Thus, my understanding is that if a
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`prior art reference fails to anticipate an independent claim, then that prior art
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`reference also necessarily fails to anticipate all dependent claims that depend from
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`the independent claim. Similarly, my understanding is that if a prior art reference or
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`combination of prior art references fails to render obvious an independent claim,
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`then that prior art reference or combination of prior art references also necessarily
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`fails to render obvious all dependent claims that depend from the independent claim.
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`V. OVERVIEW OF THE ‘228 PATENT
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`28. The ’228 patent is directing to methods for “allow[ing] people to
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`organize, view, preserve these files with all the memory details captured, connected
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`and vivified via an interactive interface.” Ex. 1001 at 1:61-65. The ‘228 patent
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`describes methods for organizing and displaying digital files, like digital
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`photographs and videos, in user-friendly and intuitive ways.
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`29. FIG. 41 of the ‘228 patent shows a map view including “an interactive
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`map.” Ex. 1001 at 29:41-45.
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`Ex. 1001 at FIG. 41
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`30.
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`In the map view, “individual or groups of Digital Files are illustrated as
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`photo thumbnails (see indicators 0874 and 0875)) on the map.” Id. at 29:48-55. The
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`geographic map is interactive at least because the user can “narrow the map view by
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`either using the Zoom in/Zoom out bar (0876) on the left or simply selecting the
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`map.” Id. at 29:52-55.
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`31. The ‘228 patent also states that in the map view illustrated in FIG. 41,
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`“the user can select the thumbnail to see all the Digital Files with the same location
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`(as seen FIG. 34 (indicator 1630)).” Ex. 1001 at 29:48-55.
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`Ex. 1001 at FIG. 34
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`32.
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`In the “Single Location Application View” shown in FIG. 34, “a single
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`location (1630) is illustrated,” which includes “[t]he individual location name” and
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`“[t]humbnails of each Digital File within the specification collection.” Id. at 24:22-
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`28. Thus, the map view and location view allow users to efficiently and intuitively
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` Declaration of Professor Glenn Reinman, Ph.D
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`locate and display digital files associated with a particular location.
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`33. The ‘228 patent also describes a people view for organizing digital files.
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`FIG. 32 of the ‘228 patent illustrates a people view 1400 including for “each person,
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`a thumbnail of their face along with their name is depicted.” Ex. 1001 at 22:59-23:4.
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`Ex. 1001 at FIG. 32
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`34. The “Single People Profile Application View” includes a variety of
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`information, including, for example, a person’s name 1431, a profile photo 1440,
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`and photos 1452 associated with that person. Id. at 23:12-49.
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`35.
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`Independent claim 1 of the ‘228 patent is reproduced below. I have
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`added the same identifiers used by Petitioner and Dr. Greenspun for ease of reference
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`throughout this declaration.
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`1. [1pre] A method comprising:
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`[1a] responsive to a first input, causing a map view to be displayed on an
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`interface, the map view including:
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`[1b] an interactive map;
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`[1c] a first location selectable thumbnail image at a first location on the
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`interactive map; and
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`[1d] a second location selectable thumbnail image at a second location
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`on the interactive map;
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`[1e] responsive to an input that is indicative of a selection of the first location
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`selectable thumbnail image, causing a first location view to be
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`displayed on the interface, the first location view including (i) a first
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`location name associated with the first location and (ii) a representation
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`of at least a portion of one digital file in a first set of digital files, each
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`of the digital files in the first set of digital files being produced from
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`outputs of one or more digital imaging devices, the first set of digital
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`files including digital files associated with the first location;
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`[1f] responsive to an input that is indicative of a selection of the second
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`location selectable thumbnail image, causing a second location view to
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`be displayed on the interface, the second location view including (i) a
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`second location name associated with the second location and (ii) a
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`representation of at least a portion of one digital file in a second set of
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`digital files, each of the digital files in the second set of digital files
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`being produced from outputs of the one or more digital imaging
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`devices, the second set of digital files including digital files associated
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`with the second location; and
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`[1g] responsive to a second input that is subsequent to the first input, causing
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`a people view to be displayed on the interface, the people view
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`including:
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`[1h] a first person selectable
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`thumbnail
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`image
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`including a
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`representation of a face of a first person, the first person being
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`associated with a third set of digital files including digital
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`photographs and videos;
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`[1i] a first name associated with the first person, the first name being
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`displayed adjacent to the first person selectable thumbnail image;
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`[1j] a second person selectable thumbnail image including a
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`representation of a face of a second person, the second person
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`being associated with a fourth set of digital files including digital
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`photographs and videos; and
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`[1k] a second name associated with the second person, the second
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`name being displayed adjacent to the second person selectable
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`thumbnail image.
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`VI. THE ‘228 PATENT’S EFFECTIVE FILING DATE
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`36.
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`I understand that the application leading to the ‘228 patent, U.S. Patent
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`Application No. 16/578,238, was filed on September 20, 2019. I also understand
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`that the ‘228 patent claims priority to U.S. Patent Application No. 14/193,426, filed
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`on February 28, 2014 and U.S. Patent Application No. 13/157,214, filed on June 9,
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`2011.
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`37.
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`I understand that the Petition and Dr. Greenspun applied June 9, 2011
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`as the effective filing date. For purposes of this declaration, I have been asked to
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`assume that the effective filing date or “time of the invention” for claims 1-19 of the
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`‘228 patent is June 9, 2011. However, my views and opinions herein will be the
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`same regardless of whether the effective filing date is June 9, 2011 or February 28,
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`2014.
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`VII. LEVEL OF SKILL IN THE ART
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`38.
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`I have been informed and understand that the level of ordinary skill in
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`the relevant art at the time of the invention is relevant to inquiries such as the
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`meaning of claim terms, the meaning of disclosures found in the prior art, and the
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`reasons one of ordinary skill in the art may have for combining references.
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`39.
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`I have reviewed the definition of the level of ordinary skill in the art
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`proposed by Petitioner. The Petition states that a person having ordinary skill in the
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`art (“POSITA”) with respect to the ‘228 patent “would have had (1) a bachelor’s
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`degree in computer science, computer engineering, electrical engineering, or a
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`related field, and (2) at least one year of experience designing graphical user
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`interfaces for applications such as photo organization systems.” Petition at p. 2. For
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`purposes of this declaration, I have been asked to apply this level of skill in the art
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`in my analysis, but I reserve the right to identify a level of skill in the art for the ‘228
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`patent that differs from Petitioner’s proposal should I be asked to do so in the future.
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`40.
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`I was, at the time of invention, and still am, one of at least ordinary skill
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`in the art through my education and experience under Petitioner’s proposed
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`definition. Indeed, I am very familiar with people having this level of skill.
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`VIII. SUMMARY OF PETITIONER’S REFERENCES
`A. Okamura
`41. Okamura generally describes “an information processing apparatus
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`which displays contents such as image files.” Ex. 1005 at ¶ [0002].
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`1. Okamura’s Description of the Related Art
`In a section entitled “Description of the Related Art,” Okamura explains
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`42.
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`that prior s