`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`CHANEL, INC.,
`Petitioner,
`
`
`
`v.
`MOLO DESIGN, LTD.,
`Patent Owner.
`
`
`
`Case IPR2022-00545
`Patent 9,689,161
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Filed: June 5, 2023
`
`
`
`PATENT OWNER’S DEMONSTRATIVE EXHIBITS
`FOR ORAL HEARING
`
`
`
`
`
`
`
`
`
`
`
`Oral Argument - Molo Design, Ltd.
`June 8, 2023
`
`IPR2022-00543 (Patent 7,866,366 B2)
`IPR2022-00544 (Patent 8,561,666 B2)
`IPR2022-00545 (Patent 9,689,161 B2)
`IPR2022-00546 (Patent 9,797,134 B2)
`
`
`
`IPR2022-00543
`(Patent 7,866,366 B2)
`
`Ground 1 – Obvious – Claims 1-3, 5-11, 13, 16, 18, 20-25, and 27
`SoftHousing I Alone and in view of SoftHousing II, SoftHousing III, Arens &
`Velcro
`
`
`
`The SoftHousing Subject Matter Was Before The Examiner
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 6, pp. 27-29; Ex. 1001
`Ex. 2005
`
`3
`
`
`
`The SoftHousing Subject Matter Was Before The Examiner
`
`Paper 6, pp. 27-29
`Exs. 1006, 2005
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`4
`
`
`
`’366 Patent Claim 1
`
`1.
`
`[Preamble] “An article of flexible furniture having”
`[Element a] “a core formed from a plurality of laminar panels of a flaccid material and
`each panel having a pair of oppositely directed major faces, adjacent faces of said panels being
`inter-connected to provide a cellular structure upon movement of abutting faces away from each
`other”
`
`[Element b] “a pair of supports at opposite ends of said core and connected to respective
`ones of said faces, said supports being self-supporting to provide rigidity to said core whereby
`said supports may be moved apart to expand said cellular structure and extend the length of
`said core and flexible so as to be foldable into a tubular configuration about an axis parallel to
`said major faces, and”
`[Element c] “a plurality of fasteners on each of said supports to secure said supports in
`said tubular configuration and to permit connection to an adjacent support of another similar
`article.”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`5
`
`’366 patent, 7:12-26; Ex. 1001
`
`
`
`The SoftHousing References Do NOT Disclose Self-Supporting
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 30, p. 10
`Forsythe Dec. (Ex. 2006) ¶(xi)
`
`6
`
`
`
`A POSITA Would NOT Understand The SoftHousing References
`To Be Self-Supporting
`
`Paper 30, pp. 10-11;
`Ex. 1005
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`7
`
`
`
`SoftHousing + Softwall End Supports Were Too Fragile To Fold
`
`Paper 17, p. 33-38
`MacAllen Depo (Ex. 1049) 55:24-56:14
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`8
`
`
`
`The Prior Art Does NOT Disclose Or Suggest Foldable End
`Supports
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 17, p. 35
`MacAllen Depo (Ex. 1049) 38:23-39:8
`
`9
`
`
`
`Not SoftHousing I-III
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 30, p. 6
`Rake Depo (Ex. 2011) 55:18-56:3
`
`10
`
`
`
`Not a Single Piece of Prior Art Describes Or Suggests End Supports
`Being Folded Into a Tubular Configuration
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 30, p. 6
`Rake Depo (Ex. 2011) 135:16-23
`
`11
`
`
`
`Not Kaisin I-III
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 30, p. 6
`Rake Depo (Ex. 2011) 86:15-21
`
`12
`
`
`
`Not Okuno
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 30, p. 6
`Rake Depo (Ex. 2011) 96:9-15
`
`13
`
`
`
`SoftHousing I-III FAIL To Disclose Fasteners To Secure Supports To
`Adjacent Supports Of “Similar Articles”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 30, pp. 18-20; Ex. 1007
`
`14
`
`
`
`There Is No Disclosure In SoftHousing I-III Of Similar Articles
`Attached With Fasteners
`
`Paper 30, pp. 18-20
`Rake Depo (Ex. 2011) 68:22-69:3
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`15
`
`
`
`SoftHousing III Attaches To Perimeter Wall, NOT Similar Article
`
`Chanel’s Argument That A Perimeter Wall Is A Similar Article (“Planar Surface”) Is Disingenuous
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 30, pp. 19-20
`Ball Dec.(Ex. 2010) ¶125(f)(g)
`
`16
`
`
`
`Arens Is Not Properly Combined
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 17, pp. 40-41
`Rake Depo (Ex. 2011) 70:21-71:7
`
`17
`
`
`
`The ’366 Patent Teaches Away From Arens
`
`’366 Patent, 1:25-28; Ex. 1001
`
`’366 Patent, 1:32-36; Ex. 1001
`
`’366 Patent, 1:60-62; Ex. 1001
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`18
`
`
`
`IPR2022-00543
`(Patent 7,866,366 B2)
`
`Ground 2 – Obvious – Claims 1-3, 5-11, 13, 16, 18, 20-25, and 27
`Kaisin I Alone and in view of Kaisin II, Kaisin III, Arens & Velcro
`
`
`
`Kaisin I-III FAIL To Disclose The Pair Of Supports Recited In The Claims
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 17, p. 46
`Ex. 1008 (annotated)
`
`20
`
`
`
`Folding The End Supports In A Tubular Configuration Renders Kaisin
`Inoperable
`
`Paper 30, p. 20
`
`Paper 17, p. 48
`Ex. 1009 (annotated)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`21
`
`
`
`The So-Called ‘S-Shape Configuration’ of Kaisin Does NOT Disclose
`“Self-Supporting” or “Foldable”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 30, p. 20
`Ex. 1008
`
`22
`
`
`
`Kaisin I-III Fail To Disclose Fasteners To Attach To “Similar Articles”
`
`Paper 17, pp. 53-54
`Ex. 1010
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`23
`
`
`
`IPR2022-00543
`(Patent 7,866,366 B2)
`
`Ground 3 – Obvious - – Claims 1-3, 5-11, 13, 16, 18, 20-25, and 27
`Okuno Alone and in view of Arens & Velcro
`
`
`
`The Substrate Plates Of Okuno Are NOT, And Do Not Suggest To A POSITA,
`Foldable End Supports
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 17, pp. 61-63
`Ball Dec. (Ex. 2010) ¶51
`
`25
`
`
`
`Okuno Does Not Disclose Or Suggest Foldable End Supports
`
`Paper 17, pp. 61-63
`Ex. 1011, Figs. 1-2
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`26
`
`
`
`IPR2022-00545
`(Patent 9,689,161 B2)
`
`Ground 1 – Anticipation – Claims 2, 6-8, 10, 12, and 14
`SoftHousing I
`
`
`
`The SoftHousing Subject Matter Was Before The Examiner
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 8, pp. 28-30
`Ex. 1001; Ex. 2005
`
`28
`
`
`
`’161 Patent Claim 2
`
`2.
`
`[Preamble] “A method for partitioning an area of a room, the method comprising:”
`[Element a] “positioning an extensible wall in the area of said room, said wall having a
`base, a top, oppositely directed surfaces extending between said base and said top, said base,
`top and surfaces defining a core, said core comprising a cellular structure having multiple voids
`extending from said base to said top upon movement of said oppositely directed surfaces away
`from each other, said base having a width of at least 10 centimeters and said core having a
`height of at least 1 meter;
`[Element b] “placing said base on a floor of said room, and”
`[Element c] “moving opposite ends of said core apart to expand said cellular structure
`and extend the length of said core and to form at least a substantially straight freestanding wall
`configuration, whilst maintaining its vertical extent.”
`
`’161 patent, 16:64-17:13
`Ex. 1001
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`29
`
`
`
`Freestanding – “standing alone, free of support or attachment”
`
`Paper 19, pp. 23-25
`Forsythe Dec. (Ex. 2006) ¶(xvii)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`30
`
`
`
`A POSITA Would Understand Shape Memory And Not Conclude
`SoftHousing I Was “Freestanding”
`
`Q: Did you do anything to prevent the softblock prototypes from collapsing?
`A: Mostly, we used time efficiently, so we would stretch the blocks as much as we could without tearing
`them to the point where they were as open as they could be. And then we would have a very short
`period of time to take a photograph before they would want to creep back into their original form. They
`held quite a tight shape memory. And when they creep back into their original form, of course, they
`become compressed and there’s no stability. They just fall over.
`Q: For a short period of time, you were able to get a prototype softblock to stand on its own; correct?
`A: No.
`
`Paper 32, pp. 8-10
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`31
`
`
`
`Petitioner Admits A POSITA Would Understand Shape Memory
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`32
`
`Paper 1, p. 67
`
`
`
`IPR2022-00545
`(Patent 9,689,161 B2)
`
`Ground 2 – Obvious – Claims 1-10, 12, 14, and 18
`SoftHousing I Alone and in view of SoftHousing II-III, Arens & Okuno
`
`
`
`The Figures Of The ’161 Patent Do NOT Teach Or Suggest That
`SoftHousing Is Freestanding
`
`Paper 19, pp. 33-34
`’161 Patent, Fig. 4 (annotated)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`34
`
`
`
`A POSITA Would Not Be Motivated To Fold The Ends Of
`SoftHousing I Into A Tubular Configuration – Claim 4
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`35
`
`Paper 19, pp. 38-40
`
`
`
`IPR2022-00545
`(Patent 9,689,161 B2)
`
`Ground 3 – Anticipation – Claims 2, 6, 8, 10, 12, and 14
`SoftWall
`Ground 4 – Obvious – Claims 1-10, 12, 14, and 18
`SoftWall Alone and in view of SoftHousing I-III, Arens & Okuno
`
`
`
`SoftWall Describes The Same Structures As The SoftHousing
`References And Does NOT Teach Or Suggest “Freestanding”
`
`Paper 19, pp. 42-43
`Forsythe Dec. (Ex. 2006), ¶(xvii)
`
`Ex. 1028
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`37
`
`
`
`SoftWall Does Not Teach Or Suggest A “Substantially Straight Wall”
`
`Ex. 1028
`
`Paper 19, pp. 44-47
`Ball Dec. (Ex. 2010), ¶152
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`38
`
`
`
`IPR2022-00545
`(Patent 9,689,161 B2)
`
`Ground 5 – Obvious – Claims 19-25, and 27
`MacAllen 2008 in view of Stratton, Fischer, Reisenthel, Tolna, &
`EnduroFence
`
`
`
`A POSITA Would Not Be Motivated To Combine MacAllen 2008 With
`Any Of Stratton, Fischer, Or Reisenthel – Claims 19-25, 27
`
`Paper 19, p. 51
`Ball Dec. (Ex. 2010) ¶¶ 183-185
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`40
`
`
`
`The Prior Art Fails To Disclose “a longitudinally flexible and extensible
`wall” Having “at least two vertical supports …” – Claims 19-22
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`41
`
`Paper 19, p. 47
`
`
`
`The “at least two articles … stacked vertically on top of each other to
`form a stack” Is Not Obvious – Claims 23-25, 27
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 19, pp. 54-58
`’161 Patent, Figs. 48 & 55
`
`42
`
`
`
`Stratton, Fischer, And Reisenthel Rely Completely On Their Supports,
`Are Not “Stackable,” And Do Not Render Obvious – Claims 23-25, 27
`
`Paper 19, pp. 54-58
`Stratton, Ex. 1038
`
`Fischer, Ex. 1039
`
`Reisenthel, Ex. 1041
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`43
`
`
`
`Stratton, Fischer, And Reisenthel Rely Completely On Their Supports,
`Are Not “Stackable,” And Do Not Render Obvious – Claims 23-25, 27
`
`Paper 19, p. 56
`Ball Dec. (Ex. 2010), ¶¶ 192, 194
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`44
`
`
`
`IPR2022-00544
`(Patent 8,561,666 B2)
`
`Ground 1 – Anticipation – Claim 21
`Okuno
`Ground 2 – Obvious – Claims 21-23
`Okuno Alone and in View of SoftHousing I, SoftHousing II, Kennedy,
`and Dorsey
`
`
`
`’666 Patent Claim 21
`
`21. [Preamble] “An article of flexible furniture having”
`[Element a] “a core formed from a plurality of laminar panels of a flaccid material
`and each panel having a pair of oppositely directed major faces, adjacent faces of said
`panels being inter-connected to provide a cellular structure upon movement of abutting
`faces away from each other”
`[Element b] “opposite ends of said core terminating in a pair of end panels
`whereby said panels may be move apart to expand said cellular structure and extend
`the length of said core”
`[Element c] “a passage extending in a direction between said end panels and
`intersecting said cellular structure, and”
`[Element d] “a light source located within said passage and operable to illuminate
`said core from the interior thereof.”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`’666 patent, 17:11-22; Ex. 1001
`
`46
`
`
`
`Okuno Does NOT Make Obvious “a passage extending in a direction
`between said end panels and intersecting said cellular structure”
`
`Each Substrate Forms a Different Cutout
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 17, pp. 19-20
`’666 Patent, Fig. 1 (Annotated)
`
`47
`
`
`
`The Cutouts of Okuno Do NOT Disclose Or Suggest They Extend
`Through The Interior Honeycomb Structure
`
`Chanel’s Expert Agrees
`
`Paper 17, pp. 20-22
`’666 Patent, Fig. 3 (Annotated)
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Rake Depo (Ex. 2011) 166:12-167:3
`
`48
`
`
`
`The Figures Of Okuno Do NOT Extend Through The Interior
`Honeycomb Structure
`
`Paper 30, pp. 14-16
`’666 Patent, Fig. 4
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`49
`
`
`
`IPR2022-00544
`(Patent 8,561,666 B2)
`
`Ground 3 – Anticipation – Claim 21
`SoftHousing I
`
`
`
`SoftHousing I Cannot Anticipate Claim 21 Of The ’666 Patent
`Because There Is No “Passage”
`
`SoftHousing I Does Not Teach The “Passage” extending in a direction
`between said end panels and intersecting said cellular structure
`
`Paper 17, pp. 24-26
`Ex. 1005
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`51
`
`
`
`SoftHousing I Cannot Anticipate Claim 21 Of The ’666 Patent
`Because There Is No “Passage”
`
`Paper 17, pp. 25-26
`Ex. 1006
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`52
`
`
`
`IPR2022-00544
`(Patent 8,561,666 B2)
`
`Ground 4 – Obvious – Claims 21-23
`SoftHousing I Alone and in View of SoftHousing II, Okuno, Kennedy,
`and Dorsey
`
`
`
`Kennedy Is Not Properly Before the Board For Independent Claim 21,
`And Fails To Disclose The Recited “Passage”
`
`Chanel’s Expert Offers No Analysis Of This Supposed Combination Of References
`
`Paper 30, p. 22
`Rake Depo (Ex. 2010) 173:15-174:5
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`54
`
`
`
`IPR2022-00544
`(Patent 8,561,666 B2)
`
`Ground 5 – Obvious – Claims 21-23
`MacAllen (2006) in View of SoftHousing I, SoftHousing II, Okuno, Kennedy,
`and Dorsey
`
`
`
`It Is Undisputed That MacAllen (2006) Does NOT Teach The Recited
`“Passage” Of Claims 21-23
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 1, p. 50
`
`56
`
`
`
`MacAllen (2006) Cannot Be Modified To Locate The Light Source In A
`“Passage” Within The Panel
`
`Paper 17, pp. 28-29
`Ex. 1033, ¶¶0024; 0005-0006
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`57
`
`
`
`IPR2022-00546
`(Patent 9,797,134 B2)
`
`Ground 1 – Anticipation – Claim 1
`Okuno
`
`
`
`’134 Patent Claim 1
`
`1.
`
`[Preamble] “A flexible article having”
`[Element a] “core formed from a plurality of laminar panels of a flaccid
`material that are inter-connected to provide an expandable structure upon
`movement of the panels away from each other”
`[Element b] “opposite ends of the core terminating in a pair of end panels
`whereby the end panels may be moved apart to expand the expandable
`structure”
`[Element c] “a passage extending in a direction between the end panels
`and intersecting the panels, and”
`[Element d] “a light source located within the passage and operable to
`illuminate the core from the interior thereof.”
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`’134 patent, 9:19-28; Ex. 1001
`
`59
`
`
`
`Okuno Does Not Teach Or Make Obvious The “Passage” Of Claim 1
`
`Paper 19, pp. 18-22
`Ball Dec. (Ex. 2010) ¶¶ 105-106
`Ex. 1011 (Annotated)
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`60
`
`
`
`IPR2022-00546
`(Patent 9,797,134 B2)
`
`Ground 2 – Obvious – Claims 1, 4-6
`Okuno Alone and in view of SoftHousing I, Kennedy, and Dorsey
`Ground 4 – Obvious – Claims 1, 4-6
`SoftHousing I Alone and in view of SoftHousing II, Okuno, Kennedy, and
`Dorsey
`
`
`
`Neither Dorsey Nor Kennedy Discloses Or Suggests The “Passage”
`Of The Claims
`
`Ex. 1034, ¶0023
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`62
`
`Paper 19, p. 23
`Ball Dec. (Ex. 2010), ¶¶122, 149, 159
`
`
`
`IPR2022-00546
`(Patent 9,797,134 B2)
`
`Ground 3 – Anticipation – Claims 1, 4-5
`SoftHousing I
`
`
`
`SoftHousing I Does NOT Anticipate The “Passage” Of Claims 1, 4-5
`Of The ’134 Patent
`
`Chanel’s Argument is Based on Pure Hindsight
`
`Paper 1, p. 43
`Rake Dec. (Ex. 1003), ¶117
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`64
`
`Paper 19, pp. 24-25
`Ball Dec. (Ex. 2010), ¶130
`
`
`
`IPR2022-00546
`(Patent 9,797,134 B2)
`
`Ground 5 – Obvious – Claims 1, 4-6
`MacAllen (2006) in view of SoftHousing I, SoftHousing II, Okuno,
`Kennedy, and Dorsey
`
`
`
`It Is Undisputed That MacAllen (2006) Does NOT Teach The Recited
`“Passage” Of Claims 1, 4-6
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`66
`
`Paper 1, p. 53
`
`
`
`MacAllen (2006) Cannot Be Modified To Locate The Light Source In A
`“Passage” Within The Panel
`
`Paper 19, pp. 28-29
`Ex. 1033, ¶¶0024; 0005-0006
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`67
`
`
`
`Secondary Considerations Of
`Non-Obviousness
`
`
`
`Industry Praise – The MoMA Included Softwall In Its Architecture &
`Design Display
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`Paper 17, pp. 71-72
`Exs. 2018, 2019
`
`69
`
`
`
`Industry Acceptance & Praise – Sales To, And Prominent Placements
`At, Chanel’s Competitors
`
`IPR2022-00543
`Paper 17 pp. 73-77
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`70
`
`
`
`Commercial Success – Pre-2008 Softwall + Softblock Embodied The
`Claims Of The ’366 And ’161 Patents
`
`IPR2022-00545
`Paper 19 pp. 59-63
`MacAllen Depo (Ex. 1049) 75:14-21
`
`IPR2022-00543
`Paper 17 pp. 66-71
`MacAllen Depo (Ex. 1049) 75:14-21
`
`Ex. 2021
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`71
`
`
`
`Commercial Success – Post-2008 Softwall + Softblock Also
`Embodied The Claims Of The ’666 And ’134 Patents
`
`IPR2022-00544
`Paper 17 pp. 31-33
`MacAllen Depo (Ex. 1049) 75:14-21
`
`IPR2022-00546
`Paper 19 pp. 31-32
`MacAllen Depo (Ex. 1049) 75:14-21
`
`Ex. 2021
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`72
`
`
`
`Copying – Chanel’s Infringing Products Are A Direct Copy Of Softwall
`
`IPR2022-00543
`Paper 17, pp. 77-79
`Ex. 2032
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`73
`
`
`
`Copying – Chanel Acquired A Softwall Sample Prior To Purchasing An
`Infringing Product
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`IPR2022-00543
`Paper 30, pp. 30-31
`
`74
`
`
`
`Long-Felt Need – Freestanding Curves, Flexibility To Accommodate
`Changes
`
`DEMONSTRATIVE EXHIBIT - NOT EVIDENCE
`
`IPR2022-00543
`Paper 17, pp. 79-80
`
`75
`
`
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