Chanel, Inc. v. Molo Design, Ltd.
`Petitioner’s Demonstratives
`
`IPR2022-00543 (Patent 7,866,366)
`IPR2022-00544 (Patent 8,561,666)
`IPR2022-00545 (Patent 9,689,161)
`IPR2022-00546 (Patent 9,797,134)
`
`Exhibit 1062
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 1
`
`
`Petitioner’s Demonstratives
`
`IPR2022-00543 (Patent 7,866,366)
`IPR2022-00544 (Patent 8,561,666)
`IPR2022-00545 (Patent 9,689,161)
`IPR2022-00546 (Patent 9,797,134)
`
`Exhibit 1062
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 1
`
`
`
`IPR2022-00543 (‘366 Patent)
`
`IPR2022-00543, Paper 1 at 7
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 2
`
`
`
`‘366 Patent, Claim 1
`
`[a]
`
`1. An article of flexible furniture having
`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,
`a pair of supports at opposite ends of said core and connected to
`[b]
`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
`a plurality of fasteners on each of said supports to secure said supports
`[c]
`in said tubular configuration and to permit connection to an adjacent
`support of another similar article.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2022-00543, Ex. 1001
`
`3
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 3
`
`
`
`SoftHousing I – DBEW 2003 Website
`
`Ex. 1005
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`4
`
`Ex. 1053 (“big_img/gp02-1.jpg”)
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 4
`
`
`
`SoftHousing I – DBEW 2003 Website
`
`Ex. 1005
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`Ex. 1054 (“big_img/gp02-2.jpg”)
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 5
`
`
`
`SoftHousing I – DBEW 2003 Website
`
`Ex. 1005
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`6
`
`Ex. 1056 (“big_img/gp02-4.jpg”)
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 6
`
`
`
`SoftHousing I – DBEW 2003 Website
`
`Ex. 1005
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`Ex. 1055 (“big_img/gp02-3.jpg”)
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 7
`
`
`
`SoftHousing I – DBEW 2003 Website
`
`Ex. 1005
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`Ex. 1057 (“big_img/gp02-5.jpg”)
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 8
`
`
`
`The Petitions Used The Same Images From DBEW
`
`Ex. 1005
`
`Ex. 1050 (Forsythe Depo) at 30:15-21
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`Ex. 1050 (Forsythe Depo) at 33:11-24
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 9
`
`
`
`SoftHousing II – DBEW Book
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`10
`
`Ex. 1006, 1058-1060
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 10
`
`
`
`Images Molo Disclosed During Prosecution
`
`IPR2022-00543
`Ex. 1002 at 283
`(‘366 Patent File History)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 11
`
`
`
`Expanded Partitions With Supports Being Self-Supporting
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2022-00543, Ex. 1001
`
`12
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 12
`
`
`
`Expanded Partitions With Supports Being Self-Supporting
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1006, 1059-1060
`
`13
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 13
`
`
`
`Expanded Partitions With Supports Being Self-Supporting
`
`Ex. 1049 (MacAllen Depo) at 41:4-7
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 14
`
`
`
`Flexible So As To Be Foldable Into A Tubular Configuration
`
`Ex. 1006, 1060
`“The bedrooms/ private rooms are soft, flexible honeycomb structures, each made from 500 layers of a light, strong,
`white *paper like material (see next page for description). . . .
`Flexible partition walls made from the same material, as the bedrooms are located at both ends of the kitchen so that
`this environment may be freely shaped and or one of the sculptural walls can be pulled out to cover the kitchen work
`area. . . .
`*At the time of this submission we have begun materials testing and exploration with full size mock-ups from fire
`retardant treated white tissue paper (shown on presentation board). . . . [and] we are testing a honeycomb structure
`made from sheets of fine polyethylene fiber that is pressed into sheets.”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1005
`
`15
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 15
`
`
`
`Flexible So As To Be Foldable Into A Tubular Configuration
`
`Ex. 1049 (MacAllen Depo) at 27:4-6
`
`Ex. 1050 (Forsythe Depo) at 28:4-10
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 16
`
`
`
`SoftHousing III
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`17
`
`Ex. 1007
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 17
`
`
`
`Arens
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`18
`
`Ex. 1013 at 1:6-25, 2:54-56
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 18
`
`
`
`Kaisin
`
`Ex. 1008 (Kaisin I)
`
`Ex. 1009 (Kaisin II)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`Ex. 1019
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 19
`
`
`
`Okuno
`
`“substrates 1, 1 formed by cutting out a plate
`body such as cardboard, a hard synthetic
`resin, an aluminum plate, or plywood”
`“bringing the substrates 1, 1 together and
`fastening these by an appropriate fastener”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1011
`
`20
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 20
`
`
`
`IPR2022-00545 (‘161 Patent)
`
`IPR2022-00545, Paper 1 at 7
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`21
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 21
`
`
`
`‘161 Patent, Claim 2
`
`[a]
`
`2. A method for partitioning an area of a room, the method comprising:
`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;
`placing said base on a floor of said room, and
`[b]
`[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.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2022-00545, Ex. 1001
`
`22
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 22
`
`
`
`SoftWall Discloses A Freestanding Wall
`“standing alone free of support or attachment”
`
`Ex. 1028
`
`Ex. 1049 (MacAllen Depo) at 57:18-20
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`23
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 23
`
`
`
`Examples Of Freestanding Walls
`
`“standing alone free of support or attachment”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2022-00545, Ex. 1001
`
`24
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 24
`
`
`
`SoftHousing I & II Disclose Freestanding Walls
`
`“standing alone free of support or attachment”
`
`Ex. 1006, 1059-1060
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`25
`
`Ex. 1049 (MacAllen Depo) at 41:4-7
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 25
`
`
`
`Folded In A Tubular Configuration
`
`Ex. 1049 (MacAllen Depo) at 27:4-6
`
`Ex. 1050 (Forsythe Depo) at 28:4-10
`
`Ex. 2011 (Rake Depo) at 200:3-9
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`26
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 26
`
`
`
`‘161 Patent, Claim 22
`
`[a]
`
`22. A longitudinally flexible and extensible wall for partitioning an area of
`a 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 opposite directed
`surfaces away from each other, said base having a width of at least 10
`centimeters and placed on a floor, whereby opposite ends of said core
`may be moved 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,
`[b]
`at least two vertical supports, each comprising a base that is placed on
`the floor and dowel extending upwards from the base, and
`said dowels of said at least two vertical supports positioned in their
`respective void in said core to temporarily flex said wall into an
`expanded serpentine configuration.
`
`[c]
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2022-00545, Ex. 1001
`
`27
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 27
`
`
`
`MacAllen 2008
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`28
`
`Ex. 1037
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 28
`
`
`
`Vertical Supports Comprising Base And Dowel
`
`Ex. 1038 (Stratton)
`
`Ex. 1041 (Reisenthel)
`
`Ex. 1039 (Fischer)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`29
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 29
`
`
`
`Supports Positioned In Vertical Voids
`
`Ex. 1040 (Tolna)
`
`Ex. 1042 (EnduroFence)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`30
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 30
`
`
`
`Motivation to Add Vertical Supports
`
`• Professor Lance Rake:
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`31
`
`Ex. 1003 (Rake Decl.) ¶¶ 88, 92
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 31
`
`
`
`IPR2022-00544 (‘666 Patent)
`
`IPR2022-00544, Paper 1 at 6
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`32
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 32
`
`
`
`‘666 Patent, Claim 21
`
`[a]
`
`21. An article of flexible furniture having
`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,
`[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,
`a passage extending in a direction between said end panels and
`[c]
`intersecting said cellular structure, and
`a light source located within said passage and operable to illuminate
`[d]
`said core from the interior thereof.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2022-00544, Ex. 1001
`
`33
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 33
`
`
`
`“Passage extending in a direction between said end
`panels and intersecting said cellular structure”
`
`IPR2022-00544, Ex. 1001 (’666 Patent) at 11:28-34
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`34
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 34
`
`
`
`Okuno
`
`“substrates 1, 1 formed by cutting out a plate
`body such as cardboard, a hard synthetic
`resin, an aluminum plate, or plywood”
`“bringing the substrates 1, 1 together and
`fastening these by an appropriate fastener”
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Ex. 1011
`
`35
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 35
`
`
`
`SoftHousing I & II Disclose LED Lighting Within The Walls
`
`Ex. 1005
`
`Ex. 1006
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`36
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 36
`
`
`
`Kennedy
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`37
`
`Ex. 1035
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 37
`
`
`
`IPR2022-00546 (‘134 Patent)
`
`IPR2022-00546, Paper 1 at 6
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`38
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 38
`
`
`
`‘134 Patent, Claim 1
`
`[a]
`
`1. A flexible article having
`a core formed from a plurality of laminar panels of a flaccid material that
`are inter-connected to provide an expandable cellular structure upon
`movement of the panels away from each other,
`[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,
`a passage extending in a direction between the end panels and
`[c]
`intersecting the panels, and
`a light source located within the passage and operable to illuminate the
`[d]
`core from the interior thereof.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2022-00546, Ex. 1001
`
`39
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 39
`
`
`
`‘134 Patent, Claim 1
`
`[a]
`
`1. A flexible article having
`a core formed from a plurality of laminar panels of a flaccid material that
`are inter-connected to provide an expandable cellular structure upon
`movement of the panels away from each other,
`[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,
`a passage extending in a direction between the end panels and
`[c]
`intersecting the panels, and
`a light source located within the passage and operable to illuminate the
`[d]
`core from the interior thereof.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`IPR2022-00546, Ex. 1001
`
`40
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 40
`
`
`
`No Presumption Of Nexus
`
`• Molo and its expert failed to show the softwall products are coextensive with the Challenged Claims
`
`Molo:
`
`Molo’s expert:
`
`“Here, a nexus is presumed because the
`softwall product practices the challenged
`’336 claims.”
`
`IPR2022-00543, Paper 17 at 66
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`41
`
`Ex. 1048 (Ball Depo) at 12:16-13:6
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 41
`
`
`
`No Presumption Of Nexus
`
`• Molo cites the same secondary considerations evidence for different patents
`
`IPR2022-00543 (‘366 Patent), Paper 17 at 72
`IPR2022-00544 (‘666 Patent), Paper 17 at 34
`IPR2022-00545 (‘161 Patent), Paper 19 at 64
`IPR2022-00546 (‘134 Patent), Paper 19 at 33
`
`IPR2022-00543 (‘366 Patent), Paper 17 at 76
`IPR2022-00544 (‘666 Patent), Paper 17 at 37
`IPR2022-00545 (‘161 Patent), Paper 19 at 68
`IPR2022-00546 (‘134 Patent), Paper 19 at 36
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`42
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 42
`
`
`
`No Actual Nexus
`
`• “[T]here must be a nexus to some aspect of the claim not already in the prior art.” In re Kao, 639
`F.3d 1057, 1069 (Fed. Cir. 2011).
`
`Praise for prior art
`elements
`
`Purchase based on
`prior art elements
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`43
`
`Ex. 2029 (Lübke Affidavit) at 1
`
`Petitioner Chanel, Inc. Exhibit 1062, Page 43
`
`
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