`Google LLC v. Mira Advanced Technology Systems, Inc.Google LLC v. Mira Advanced Technology Systems, Inc.
`
`Google LLC v. Mira Advanced Technology Systems, Inc.Google LLC v. Mira Advanced Technology Systems, Inc.
`
`Petitioner Demonstratives
`Petitioner Demonstratives
`Petitioner DemonstrativesPetitioner Demonstratives
`
`IPR 2022-00742
`U.S. Patent No. 10,594,854
`July 28, 2023
`
`James Carmichael
`Steve McBride
`Carmichael IP, PLLC
`
`Exhibit 1025
`Slide 1
`
`
`
`Overview
`
`1. Background
`
`2. Dunton, Barchi And/Or Bedingfield Render The Claims Obvious
`
`A. The Claims Do Not Require Patent Owner’s “Integration”
`
`B. Dunton Is Not Limited To Its Location Table Embodiment
`
`C. Dunton, Barchi And/Or Bedingfield Render The Claims Obvious Even
`Under PO’s “Integration” Argument
`
`3. A POSITA Would Have Combined Dunton With Barchi And/Or Bedingfield
`
`4. There Are No Secondary Considerations
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 2
`
`
`
`Overview
`
`1. Background
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 3
`
`
`
`U.S Patent No. 10,594,85410,594,854
`
`
`10,594,85410,594,854
`
`• Earliest Effective Filing Date: March 11,
`2008
`
`Ground 1: Claims 1-7 are obvious over Dunton
`in view of Barchi and/or Bedingfield under 35
`U.S.C. §103
`
`See Pet., 3.
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Ex. 1001 [’854 Patent]
`
`Exhibit 1025
`Slide 4
`
`
`
`’854 Patent Claim 1
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Ex. 1001 [’854 Patent] 6:16-8:11
`
`Exhibit 1025
`Slide 5
`
`
`
`’854 Patent
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Ex. 1001 [’854 Patent] Fig. 6; Pet., 5
`
`Exhibit 1025
`Slide 6
`
`
`
`Dunton
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Ex. 1006 [Dunton] Fig. 3; Pet., 10
`
`Exhibit 1025
`Slide 7
`
`
`
`Barchi
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Ex. 1008 [Barchi]
`
`Exhibit 1025
`Slide 8
`
`
`
`Bedingfield
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Ex. 1009 [Bedingfield]
`
`Exhibit 1025
`Slide 9
`
`
`
`Patent Owner’s Acknowledged Prior Art
`
`POR, 11.
`
`POR, 12.
`
`POR, 12-13.
`
`See Reply, 2-4.
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 10
`
`
`
`Overview
`
`2. Dunton, Barchi And/Or Bedingfield Render The Claims Obvious
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 11
`
`
`
`Dunton, Barchi And/Or Bedingfield
`Render The Claims Obvious
`
`PO’s Arguments Rely On Its Characterization Of
`“CL1” and “CL2”, Not The Claim Language
`
`Sur-reply, 5.
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`POR, 13.
`
`See generally Sur-reply, 1-5; Reply, 4-6; POR, 4-8).
`
`Exhibit 1025
`Slide 12
`
`
`
`Overview
`
`A. The Claims Do Not Require Patent Owner’s “Integration”
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 13
`
`
`
`The Claims Do Not Require Patent Owner’s “Integration”
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`DI, 25
`
`Reply, 7
`
`Exhibit 1025
`Slide 14
`
`
`
`The Claims Do Not Require Patent Owner’s “Integration”
`
`Sur-reply, 4
`
`Sur-reply, 4
`
`POR, 18
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 15
`
`
`
`The Claims Do Not Require Patent Owner’s “Integration”
`
`EX1001 [‘854 Patent], Claim 1
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Reply, 8
`
`Exhibit 1025
`Slide 16
`
`
`
`The Claims Do Not Require Patent Owner’s “Integration”
`
`EX1001 [‘854 Patent], Claim 1
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Reply, 8
`
`Exhibit 1025
`Slide 17
`
`
`
`The Claims Do Not Require Patent Owner’s “Integration”
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`EX1001 [‘854 Patent], 2:39-57
`
`Reply, 9
`
`Exhibit 1025
`Slide 18
`
`
`
`The Claims Do Not Require Patent Owner’s “Integration”
`
`EX1001 [‘854 Patent], 2:24-28
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Reply, 10-11
`
`Exhibit 1025
`Slide 19
`
`
`
`The Claims Do Not Require Patent Owner’s “Integration”
`
`Petitioner’s Expert Provides Unrebutted Testimony
`Contradicting Patent Owner’s Position
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`EX1020 [Schmandt Reply Decl.], ¶ 16; see generally id., ¶¶12-17; EX1021, 3;
`EX1022, 3; EX1023, Figs. 27-42; EX1024, 2; EX1011, Fig. 2, ¶¶[0025]-[0029]
`
`Reply, 10-11
`
`Exhibit 1025
`Slide 20
`
`
`
`Overview
`
`B. Dunton Is Not Limited To Its Location Table Embodiment
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 21
`
`
`
`Dunton Is Not Limited To Its Location Table Embodiment
`
`Dunton Is Not Limited To
`The Example In Table 1
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`EX1006 [Dunton], ¶ [0034]
`
`Reply, 11-12
`
`Exhibit 1025
`Slide 22
`
`
`
`Dunton Is Not Limited To Its Location Table Embodiment
`
`Dunton’s GPS Coordinates Are “GPS
`Coordinates Of The First Viewable Entry”
`
`EX1001 [‘854 Patent], Claim 1
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`EX1006 [Dunton], ¶ 34]
`
`Reply, 11-12
`
`Exhibit 1025
`Slide 23
`
`
`
`Overview
`
`C. Dunton, Barchi And/Or Bedingfield Render The Claims Obvious Even
`Under PO’s “Integration” Argument
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 24
`
`
`
`Dunton, Barchi And/Or Bedingfield Render The Claims
`Obvious Even Under PO’s “Integration” Argument
`
`EX1006 [Dunton], ¶[0015]
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`EX1006 [Dunton] Table 1 (excerpted and annotated)
`
`See Reply, 13-15
`
`Exhibit 1025
`Slide 25
`
`
`
`Dunton, Barchi And/Or Bedingfield Render The Claims
`Obvious Even Under PO’s “Integration” Argument
`
`EX1006 [Dunton] Table 1 (annotated)
`
`EX1006 [Dunton], ¶[0015]; see also ¶¶ [0016],
`[0018], [0020], [0026], [0032], [0034], [0037]
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 26
`
`
`
`Overview
`
`3. A POSITA Would Have Combined Dunton With Barchi And/Or Bedingfield
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 27
`
`
`
`A POSITA Would Have Combined Dunton
`With Barchi And/Or Bedingfield
`
`Petitioner’s Rationales Are Well-Reasoned
`And Supported By Substantial Evidence
`
`DI, 26
`
`DI, 27
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`See also Reply, 16-20; Pet., 15-17, 24-25, 28, 37-38; EX1003 [Schmandt Decl.],
`¶¶133-144.
`
`Exhibit 1025
`Slide 28
`
`
`
`A POSITA Would Have Combined Dunton
`With Barchi And/Or Bedingfield
`
`Petitioner’s Rationales Are Well-Reasoned
`And Supported By Substantial Evidence
`
`Ex1006 [Dunton], ¶[0001]
`
`See also Reply, 16-20; Pet., 15-17, 24-25, 28, 37-38; EX1003 [Schmandt Decl.],
`¶¶133-144.
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 29
`
`
`
`A POSITA Would Have Combined Dunton
`With Barchi And/Or Bedingfield
`
`Petitioner’s Rationales Are Well-Reasoned
`And Supported By Substantial Evidence
`
`Ex1003 [Schmandt Decl.], ¶135
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Ex1003 [Schmandt Decl.], ¶139
`
`Exhibit 1025
`Slide 30
`
`
`
`A POSITA Would Have Combined Dunton
`With Barchi And/Or Bedingfield
`
`Petitioner’s Rationales Are Not Limited
`To Improving Efficiency
`
`Ex1003 [Schmandt Decl.], ¶136
`
`See also Pet., 14-17, 24-25, 28-30, 37-38, 41, 44;
`EX1003 [Schmandt Decl.], ¶¶77-111, 133-144, 154,
`174-175, 185, 210, 233, 239.
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 31
`
`
`
`A POSITA Would Have Combined Dunton
`With Barchi And/Or Bedingfield
`
`PO Admits Barchi and Bedingfield
`Were Obvious To Try
`
`“[T]he use of Bedingfield and the likes to show availability of user
`interfaces used to query against a remote database using an identifier
`for the purpose of retrieving and setting a GPS coordinates, appears to
`be at best cumulative to what Patent Owner has already acknowledged
`[as known in the prior art].”
`
`“[T]he use of Barchi and the likes to show auto-populating of a
`conventional address book, appears to be at best cumulative to what
`Patent Owner has already acknowledged [as known in the prior art].”
`
`POR, 12
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`POR, 13
`
`See also Reply, 19-20; POR, 23; Pet., 8-9, 38
`
`Exhibit 1025
`Slide 32
`
`
`
`Overview
`
`4. There Are No Secondary Considerations
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 33
`
`
`
`There Are No Secondary Considerations
`
`“In order to accord substantial weight to secondary considerations in an
`obviousness analysis, ‘the evidence of secondary considerations must have a
`‘nexus’ to the claims, i.e. , there must be ‘a legally and factually sufficient
`connection’ between the evidence and the patented invention.’” Fox Factory,
`Inc. v. SRAM, LLC, 944 F.3d 1366, 1373 (Fed. Cir. 2019)
`
`Secondary Consideration
`
`Evidence In Record?
`
`Reply, 22
`
`Product embodying claimed
`features
`
`Nexus between that product
`and the claimed features
`
`Commercial success
`
`Long-felt but unsolved need
`
`Failure of others to arrive at
`claimed invention
`
`Unexpected results
`
`Copying
`
`
`
`NoNoNoNonenenene
`
`NoNoNoNonenenene
`
`NoNoNoNonenenene
`
`NoNoNoNonenenene
`
`NoNoNoNonenenene
`
`NoNoNoNonenenene
`
`NoNoNoNonenenene
`
`Reply, 21-22
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 34
`
`
`
`There Are No Secondary Considerations
`
`PO Waived Any Copying Argument
`
`“Patent Owner is cautioned that any arguments not raised in the
`response may be deemed waived.”
`
`Paper 14 [Scheduling Order]
`
`“NuVasive abandoned its challenge to the public accessibility
`determination even though the PTAB had warned NuVasive that this
`would result in waiver. J.A. 201–02 (where the PTAB indicated in a
`scheduling order that ‘[t]he patent owner is cautioned that any
`arguments for patentability not raised and fully briefed in the response
`will be deemed waived’).” In re Nuvasive, Inc., 842 F.3d 1376, 1381
`(Fed. Cir. 2016).
`
`Reply, 21
`
`PATENT OWNER DEMONSTRATIVE
`EXHIBITS - NOT EVIDENCE
`
`IPR 2022-00742
`
`Exhibit 1025
`Slide 35
`
`
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