Inter Partes Reviews
`U.S. Patent No. 9,269,208
`and
`U.S. Patent No. 9,665,705
`Oral Argument, June 29, 2023
`
`Apple Inc. v. CPC Patent Technologies PTY, LTD.
`Case Nos. IPR2022-00601 and IPR2022-00602
`
`Petitioner’s Demonstrative Exhibits – Not Evidence
`
`Petitioner’s DX-1
`
`
`U.S. Patent No. 9,269,208
`and
`U.S. Patent No. 9,665,705
`Oral Argument, June 29, 2023
`
`Apple Inc. v. CPC Patent Technologies PTY, LTD.
`Case Nos. IPR2022-00601 and IPR2022-00602
`
`Petitioner’s Demonstrative Exhibits – Not Evidence
`
`Petitioner’s DX-1
`
`
`
`Grounds for ’705 Patent
`} Ground 1: Claims 1, 4, 6, 10-12, and 14-17
`} Mathiassen (Ex. 1004) in view of McKeeth (Ex. 1005) and Anderson (Ex.
`1006)
`} The ’208 Patent IPR has substantially similar ground
`} Summary of Modifications to Mathiassen
`} Mathiassen modified by McKeeth to output two additional accessibility
`attributes (i.e., alert and duress)
`
`} Mathiassen modified by Anderson to characterize Mathiassen’s series of
`fingerprint touches by the duration of each touch and number of
`touches
`
`} Mathiassen modified to include an enrollment command in command
`table that instructs enrollment of new user
`
`Petition (Paper 1), 5 (summarizing ground); Pet. Reply (Paper 20), 1, 23 (summarizing modifications)
`All citations to the ’705 Patent IPR
`
`Petitioner’s DX-2
`
`
`
`’705 Patent, Claim 1
`
`1(b2)
`
`1(d1) – 1(d3)
`
`’705 Patent (Ex. 1001), Claim 1
`
`Petitioner’s DX-3
`
`
`
`Duration Limitation:
`Mathiassen’s Modification with Anderson
`
`Proposed Modification to Mathiassen Applying
`Anderson’s Duration Teachings
`Straightforward
`Modification to
`Mathiassen
`
`Mathiassen (Ex. 1004), [0192]
`
`Pet., 31-37; Pet. Reply, 15; Dr. Sears’ Declaration (Ex. 1003), ¶¶ 223-224
`
`Petitioner’s DX-4
`
`
`
`CPC’s “Simpler” Solutions:
`Additional Fingerprints and a Push Button
`CPC’s “Simpler” Solutions for Indicating Duress
`PO Sur-Reply, p. 4
`
`
`
`
`
`Add
`
`Mechanical
`Push Button
`
`
`
`Add
`Additional
`Fingerprints
`
`CPC’s Declarant Opinion:
`
`Easttom’s Conclusory Opinion:
`
`Pet. Reply, 7-9
`
`Dr. Easttom Dec. (Ex. 2013), ¶ 59
`Petitioner’s DX-5
`
`
`
`Duration Limitation:
`Mathiassen’s Modification with Anderson
`Improvements of Analyzing Press Durations vs.
`Finger Movement in Fingerprint Recognition
`
`Minimizes skin
`distortion that
`creates less
`reliable results
`
`Decreases
`complexity: image
`reconstruction
`uses less
`complicated logic
`
`No
`compensation
`for varying shift
`(data skew) in
`finger position
`
`Factual Basis for Dr. Sears’ Opinions: See Ex. 1053
`
`Ex. 1003, ¶ 223
`
`CPC has not rebutted or addressed Ex. 1003, ¶ 223
`Pet. Reply, 13-14
`
`Pet., 36
`
`Petitioner’s DX-6
`
`
`
`Duration Limitation:
`Mathiassen’s Modification with Anderson
`} The Board already addressed Anderson’s teachings of a digitizer
`pad and fingerprint:
`
`Institution Decision (Paper 11), 31
`
`Pet. Reply, 19, 21
`
`Anderson, Ex. 1006, 7:1-8
`
`Petitioner’s DX-7
`
`
`
`CPC’s “Computer Art” Theory
`} References directed to accessing an electronically-secured item
`Dr. Sears’ Supplemental
`Declaration (Ex. 1090), ¶ 15
`
`} Dr. Sears’ Declaration:
`
`Pet. Reply, 13-14
`
`Ex. 1003, ¶ 106
`
`Petitioner’s DX-8
`
`
`
`Mathiassen’s “accessibility attribute”
`’705 Patent, Exemplary Accessibility Attribute:
`
`Mathiassen’s Accessibility Attribute:
`
`’705 Patent, 10:38-42
`
`’705 Patent, 12:15-23
`
`’705 Patent, 8:26-30
`Petitioner’s DX-9
`
`Ex. 1004, [0165, 0182, 0185]
`
`Pet. Reply, 3-4 (citing Ex. 1003, ¶ 140); Pet., 16-19, 46
`
`
`
`Mathiassen’s “accessibility attribute”
`Dr. Easttom’s Testimony:
`
`Pet. Reply, 4-5
`
`Ex. 1089, 21:20-22:7
`Petitioner’s DX-10
`
`
`
`Mathiassen Teaches a Series of Entries of the
`Biometric Signal
`} CPC’s argument re series of biometric signal entries:
`
`} Petitioner Reply:
`
`Pet., 31-38; Pet. Reply, 7
`
`PO Sur-Reply
`(Paper 26), p. 24
`
`Pet. Reply, 7
`
`Petitioner’s DX-11
`
`
`
`Mathiassen Teaches a Series of Entries of the
`Biometric Signal
`
`Anderson (Ex. 1006), 7:28-34,
`FIG. 4A (annotated)
`
`Mathiassen (Ex. 1004), [0192]
`
`Pet., 32-33, 35, 37
`
`Petitioner’s DX-12
`
`
`
`Mathiassen-Anderson Renders Obvious
`Populating the Data Base
`} CPC’s argument regarding the “populating” mapping:
`
`} Petition’s Modification:
`
`PO Sur-Reply, p. 23
`
`PO Sur-Reply, 23
`
`Pet., 31-38; Pet. Reply, 23
`
`Pet. Reply, 23
`
`Petitioner’s DX-13
`
`
`
`Mathiassen-Anderson Renders Obvious
`Populating the Data Base
`Claims limitations
`’705 Patent’s
`1(d1)-1(d3)
`Exemplary Support
`Receive a series of entries
`Receive a series of finger
`of the biometric signal
`presses from administrator
`characterized according to
`encoded by the number and
`at least one of the number
`duration of finger presses
`of entries and duration of
`each entry
`Map said series into an
`instruction
`
`(’705 Patent, 10:56-63)
`Finger presses are checked
`against stored legal controls
`
`Populate the data base
`according to the instruction
`
`(’705 Patent, 10:63-67)
`Finger presses successfully
`check against a control to
`“Enroll an ordinary user”
`
`(’705 Patent, 11:1-3)
`
`Petition’s Mapping
`
`Mathiassen receives car
`administrator’s series of fingerprint
`touches characterized by number and
`duration (per Anderson) (Pet. 32-37)
`
`Mathiassen translates, using a
`command table, the series of touches
`into an associated control signal (Pet.,
`37)
`Mathiassen renders obvious the
`command table including a control
`signal to enroll a new user; according
`to the enrollment control signal, the
`data base is populated with the new
`user’s master minutiae tables (Pet.,
`38-42)
`
`Pet., 32-42; Pet. Reply, 23-24; Ex. 1004, [0192]
`
`Petitioner’s DX-14
`
`
`
`Mathiassen-Anderson Renders Obvious
`Populating the Data Base
`} Prosecution History of ’705 Patent:
`
`“populate…according to”
`
`“receive”
`
`“characterized”
`
`“Map”
`
`Pet. Reply, 25
`
`Ex. 1002, 120-121
`
`Ex. 1002, 120-121
`Petitioner’s DX-15
`
`
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