Petitioner’s Demonstratives
`
`Google LLC
`v.
`Touchstream Technologies, Inc.
`
`IPR2022‐00793, IPR2022‐00794, IPR2022‐00795
`
`June 13, 2023
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`GOOGLE EXHIBIT 1021
`GOOGLE v. TOUCHSTREAM
`IPR2022-00795
`
`
`
`Google LLC
`v.
`Touchstream Technologies, Inc.
`
`IPR2022‐00793, IPR2022‐00794, IPR2022‐00795
`
`June 13, 2023
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`GOOGLE EXHIBIT 1021
`GOOGLE v. TOUCHSTREAM
`IPR2022-00795
`
`
`
`
`
`PatentsPatents
`
`IPR2022‐00793
`U.S. Patent No. 8,782,528
`
`“Play control of content on a
`display device”
`
`IPR2022‐00794
`U.S. Patent No. 8,904,289
`
`“Play control of content on a
`display device”
`
`IPR2022‐00795
`U.S. Patent No. 8,356,251
`
`“Play control of content on a
`display device”
`
`Computing
`Device
`
`Content
`Presentation
`Device
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCEEx-1001, FIG. 1; IPR2022-00793, 794, and 795, Pet. 4
`
`2
`
`
`
`
`
`GroundsGrounds
`
`•
`
`•
`
`•
`
`IPR2022‐00793
`Ground Claims
`
`IPR2022‐00794
`Ground Claims
`
`IPR2022‐00795
`Ground Claims
`
`1
`2
`1
`2
`1
`2
`
`1-5, 8, 11, 12, 14, 15, 27, and 28 Muthukumarasamy
`1-5, 8, 11, 12, 14, 15, 27, and 28 Muthukumarasamyand Hayward
`IPR2022-00793, Pet. 3
`1-2 and 6-8
`Muthukumarasamy
`1-2 and 6-8
`Muthukumarasamyand Hayward
`IPR2022-00794, Pet. 2
`1-2 and 5-9
`Muthukumarasamy
`1-2 and 5-9
`Muthukumarasamyand Hayward
`IPR2022-00795, Pet. 2-3
`
`Obviousness Basis
`
`Obviousness Basis
`
`Obviousness Basis
`
`3
`
`
`
`
`
`Ground 1: MuthukumarasamyGround 1: Muthukumarasamy
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`4
`
`
`
`
`
`Prior art: MuthukumarasamyPrior art: Muthukumarasamy
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`IPR2022-00793, Pet. 6-9
`IPR2022-00794, Pet. 7-11
`IPR2022-00794, Pet. 6-10
`
`5
`
`
`
`
`
`Prior art: MuthukumarasamyPrior art: Muthukumarasamy
`
`IPR2022-00793, Pet. 6-9
`IPR2022-00794, Pet. 7-11
`IPR2022-00794, Pet. 6-10
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`6
`
`
`
`
`
`Touchstream’s Flawed PremisesTouchstream’s Flawed Premises
`
`Touchstream’s Flawed Premises
`
`The RCIBSprocess and the zHub/zNodeprocess are
`alternative processes; only one of the two would be used
`in presenting any particular content
`No. 2 The zHuband the zNodeare not part of a “server system”
`No. 3 The IED’s requests for content do not identify “media
`players”
`No. 4 The Petition did not map the RCIBSas part of the “server
`system”
`“Programming code” should be construed as “computer
`program instruction(s) encoded for execution by a data
`processing apparatus (such as a computer processor)”
`
`No. 1
`
`No. 5
`
`Claim Limitations
`
`“server system”
`“media player”
`“programming
`code”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`7
`
`
`
`
`
`Touchstream’s 1st & 2nd Flawed PremisesTouchstream’s 1st & 2nd Flawed Premises
`
`Muthukumarasamy does not
`teach the “server system”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`8
`
`
`
`
`
`Premise No. 1 is WrongPremise No. 1 is Wrong
`
`No. 1
`
`Touchstream’s First Flawed Premise
`
`The RCIBS process and the zHub/zNode process are alternative processes; only
`one of the two would be used in presenting any particular content
`
`• Premise No. 1 is wrong: The RCIBS, zHub, and zNodework together to provide a
`“device-agnostic and source-agnostic entertainment experience”
`• Premise No. 1 is wrong: Muthukumarasamy discloses that the zHub/zNode
`process is used to present internet content
`• Premise No. 1 is wrong: The computer hosting the RCIBSis a media device
`controllable by the zHub/zNodeprocess
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`9
`
`
`
`
`
`Premise No. 1 is WrongPremise No. 1 is Wrong
`
`No. 1
`
`Touchstream’s First Flawed Premise
`The RCIBS process and the zHub/zNode process are alternative processes; only
`one of the two would be used in presenting any particular content
`• Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`“device‐agnostic and source‐agnostic entertainment experience”
`
`• Premise No. 1 is wrong: Muthukumarasamy discloses that the zHub/zNode
`process is used to present internet content
`• Premise No. 1 is wrong: The computer hosting the RCIBSis a media device
`controllable by the zHub/zNodeprocess
`POR, 36-38
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`10
`10
`
`
`
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`
`“device‐agnostic and source‐agnostic entertainment experience"“device‐agnostic and source‐agnostic entertainment experience"
`
`Muthukumarasamy, Abstract
`
`.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`IPR2022-00793, Pet. 6-9, 13-22; Reply 4-13
`IPR2022-00794, Pet. 7-11, 15-25; Reply 4-13
`IPR2022-00795, Pet. 6-10, 14-24; Reply 4-13
`
`11
`
`
`
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`
`“device‐agnostic and source‐agnostic entertainment experience"“device‐agnostic and source‐agnostic entertainment experience"
`
`Muthukumarasamy, Fig. 1
`.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Muthukumarasamy, Fig. 18
`IPR2022-00793, Pet. 6-9, 13-22; Reply 4-13
`IPR2022-00794, Pet. 7-11, 15-25; Reply 4-13
`IPR2022-00795, Pet. 6-10, 14-24; Reply 4-13
`
`12
`
`
`
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`
`“device‐agnostic and source‐agnostic entertainment experience"“device‐agnostic and source‐agnostic entertainment experience"
`
`Muthukumarasamy, Figs. 1&18
`.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`IPR2022-00793, Pet. 6-9, 13-22; Reply 4-13
`IPR2022-00794, Pet. 7-11, 15-25; Reply 4-13
`IPR2022-00795, Pet. 6-10, 14-24; Reply 4-13
`
`13
`
`
`
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`
`“device‐agnostic and source‐agnostic entertainment experience"“device‐agnostic and source‐agnostic entertainment experience"
`
`Muthukumarasamy, ¶ [0068]
`
`Muthukumarasamy, ¶ [0069]
`IPR2022-00793, Pet. 6-9, 13-22, 25-31, 47-48; Reply 4-13
`IPR2022-00794, Pet. 7-11, 15-25, 29-34, 53-54 ; Reply 4-13
`IPR2022-00795, Pet. 6-10, 14-24, 28-34; Reply 4-13
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`14
`
`
`
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`
`“device‐agnostic and source‐agnostic entertainment experience"“device‐agnostic and source‐agnostic entertainment experience"
`
`Muthukumarasamy, ¶ [0036] [0045]
`Muthukumarasamy, ¶ [0027]
`
`Muthukumarasamy, ¶ [0044]
`
`Muthukumarasamy, ¶ [0084]
`Muthukumarasamy, ¶ [0048]
`IPR2022-00793, Pet. 6-9, 13-22, 25-31, 48-51; Reply 4-13
`IPR2022-00794, Pet. 7-11, 15-25, 29-34, 54-57 ; Reply 4-13
`IPR2022-00795, Pet. 6-10, 14-24, 28-34, 48-51 ; Reply 4-13
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`15
`
`
`
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`
`“device‐agnostic and source‐agnostic entertainment experience"“device‐agnostic and source‐agnostic entertainment experience"
`
`Muthukumarasamy, ¶ [0036] [0045]
`IPR2022-00793, Pet. 6-9, 13-22; Reply 4-13
`IPR2022-00794, Pet. 7-11, 15-25; Reply 4-13
`IPR2022-00795, Pet. 6-10, 14-24; Reply 4-13
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`16
`
`
`
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`
`“device‐agnostic and source‐agnostic entertainment experience"“device‐agnostic and source‐agnostic entertainment experience"
`
`Muthukumarasamy, ¶ [0047]
`Muthukumarasamy, ¶ [0031]
`
`Muthukumarasamy, Fig. 16
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Muthukumarasamy, ¶ [0134]
`IPR2022-00793, Pet. 6-9, 13-22, 32-36; Reply 4-13
`IPR2022-00794, Pet. 7-11, 15-25, 35-41; Reply 4-13
`IPR2022-00795, Pet. 6-10, 14-24, 35-38; Reply 4-13
`
`17
`
`
`
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`Premise No. 1 is wrong: RCIBS, zHub, and zNode work together to provide
`
`“device‐agnostic and source‐agnostic entertainment experience"“device‐agnostic and source‐agnostic entertainment experience"
`
`Muthukumarasamy, ¶ [0061]
`
`Muthukumarasamy, ¶ [0062]
`
`Muthukumarasamy, ¶ [0070]
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`IPR2022-00793, Pet. 6-9, 13-22, 32-36; Reply 4-13
`IPR2022-00794, Pet. 7-11, 15-25, 35-41; Reply 4-13
`IPR2022-00795, Pet. 6-10, 14-24, 35-38; Reply 4-13
`
`18
`
`
`
`
`
`Premise No. 1 is WrongPremise No. 1 is Wrong
`
`No. 1
`
`Touchstream’s First Flawed Premise
`The RCIBS process and the zHub/zNode process are alternative processes; only
`one of the two would be used in presenting any particular content
`
`• Premise No. 1 is wrong: RCIBS, zHub, and zNodework together to provide “device-
`agnostic and source-agnostic entertainment experience”
`• Premise No. 1 is wrong: A computer hosting the RCIBSis a media device
`controllable by the zHub/zNodeprocess
`
`• Premise No. 1 is wrong: Muthukumarasamy discloses that the zHub/zNode
`process is used to present internet content
`
`POR, 38-39
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`19
`
`
`
`
`Premise No. 1 is wrong: Muthukumarasamy discloses that the Premise No. 1 is wrong: Muthukumarasamy discloses that the
`
`zHub/zNode process is used to present internet contentzHub/zNode process is used to present internet content
`
`POR, 39
`
`Muthukumarasamy, ¶ [0045]
`IPR2022-00793, Pet. 6-9, 13-22, 40-44, 51; Reply 10-13
`IPR2022-00794, Pet. 7-11, 15-25, 45-50, 57 ; Reply 10-13
`IPR2022-00795, Pet. 6-10, 14-24, 42-46, 51, 53-54; Reply 10-13
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`20
`
`
`
`
`Premise No. 1 is wrong: Muthukumarasamy discloses that the Premise No. 1 is wrong: Muthukumarasamy discloses that the
`
`zHub/zNode process is used to present internet contentzHub/zNode process is used to present internet content
`
`Muthukumarasamy, Fig. 5
`IPR2022-00793, Pet. 6-9, 13-22, 40-44, 51; Reply 10-13
`IPR2022-00794, Pet. 7-11, 15-25, 45-50, 57 ; Reply 10-13
`IPR2022-00795, Pet. 6-10, 14-24, 42-46, 51, 53-54; Reply 10-13
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`21
`
`
`
`
`
`Premise No. 1 is WrongPremise No. 1 is Wrong
`
`No. 1
`
`Touchstream’s First Flawed Premise
`The RCIBS process and the zHub/zNode process are alternative processes; only
`one of the two would be used in presenting any particular content
`
`• Premise No. 1 is wrong: RCIBS, zHub, and zNodework together to provide “device-
`agnostic and source-agnostic entertainment experience”
`• Premise No. 1 is wrong: Muthukumarasamy discloses that the zHub/zNode
`process is used to present internet content
`
`• Premise No. 1 is wrong: The computer hosting the RCIBS is a media device
`controllable by the zHub/zNode process
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`22
`
`
`
`
`Premise No. 1 is wrong: The computer hosting RCIBS is a Premise No. 1 is wrong: The computer hosting RCIBS is a
`
`media device controllable by the zHub/zNode processmedia device controllable by the zHub/zNode process
`
`Dr. Bederson:
`
`POR, 31
`
`Muthukumarasamy, ¶ [0044]
`IPR2022-00793, Pet. 6-9, 13-22, 25-27, 48-51; Reply 14-15
`IPR2022-00794, Pet. 7-11, 15-25, 28-30, 54-57 ; Reply 14-15
`IPR2022-00795, Pet. 6-10, 14-24, 27-31, 48-51; Reply 14-15
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Ex-2021, 58:14-61:20, 63:10-21
`
`23
`
`
`
`
`Premise No. 1 is wrong: The computer hosting RCIBS is a Premise No. 1 is wrong: The computer hosting RCIBS is a
`
`media device controllable by the zHub/zNode processmedia device controllable by the zHub/zNode process
`
`Muthukumarasamy, Fig. 1
`IPR2022-00793, Pet. 6-9, 13-22, 25-27, 48-51; Reply 14-15
`IPR2022-00794, Pet. 7-11, 15-25, 28-30, 54-57 ; Reply 14-15
`IPR2022-00795, Pet. 6-10, 14-24, 27-31, 48-51; Reply 14-15
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`24
`
`
`
`
`Premise No. 1 is wrong: The computer hosting RCIBS is a Premise No. 1 is wrong: The computer hosting RCIBS is a
`
`media device controllable by the zHub/zNode processmedia device controllable by the zHub/zNode process
`
`POR, 42
`
`Muthukumarasamy, ¶ [0056]
`IPR2022-00793, Pet. 6-9, 13-22, 25-27, 48-51; Reply 15-17
`IPR2022-00794, Pet. 7-11, 15-25, 28-30, 54-57 ; Reply 15-17
`IPR2022-00795, Pet. 6-10, 14-24, 27-31, 48-51; Reply 15-17
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`25
`
`
`
`
`Premise No. 1 is wrong: The computer hosting RCIBS is a Premise No. 1 is wrong: The computer hosting RCIBS is a
`
`media device controllable by the zHub/zNode processmedia device controllable by the zHub/zNode process
`
`Muthukumarasamy, Fig. 1
`IPR2022-00793, Pet. 6-9, 13-22, 25-27, 48-51; Reply 15-17
`IPR2022-00794, Pet. 7-11, 15-25, 28-30, 54-57 ; Reply 15-17
`IPR2022-00795, Pet. 6-10, 14-24, 27-31, 48-51; Reply 15-17
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`26
`
`
`
`
`
`Premise No. 1 is WrongPremise No. 1 is Wrong
`
`No. 1
`
`Touchstream’s First Flawed Premise
`The RCIBS process and the zHub/zNode process are alternative processes; only
`one of the two would be used in presenting any particular content
`
`• Premise No. 1 is wrong: RCIBS, zHub, and zNodework together to provide “device-
`agnostic and source-agnostic entertainment experience”
`• Premise No. 1 is wrong: Muthukumarasamydiscloses that the zHub/zNode
`process is used to present internet content
`• Premise No. 1 is wrong: A computer hosting the RCIBSis a media device
`controllable by the zHub/zNode
`
`The RCIBS and zHub/zNode are both part of the
`DBCS, which teaches the claimed “server system”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`27
`
`
`
`
`
`Touchstream’s 1st Flawed Premise FailsTouchstream’s 1st Flawed Premise Fails
`
`Muthukumarasamy does not
`teach the “server system”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`28
`
`
`
`
`
`Premise No. 2 is WrongPremise No. 2 is Wrong
`
`No. 2
`
`Touchstream’s Second Flawed Premise
`The zHub and the zNode are not part of a server system
`
`• Premise No. 2 is wrong: The zHuband zNodeare components specially
`designed to carry out the DBCSfunctions
`• Premise No. 2 is wrong: The zHub/zNodenetwork works together with the
`Internet Server
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`29
`
`
`
`
`
`Premise No. 2 is WrongPremise No. 2 is Wrong
`
`No. 2
`
`Touchstream’s Second Flawed Premise
`The zHub and the zNode are not part of a server system
`• Premise No. 2 is wrong: The zHub and zNode are components specially
`designed to carry out the DBCS functions
`
`• Premise No. 2 is wrong: The zHub/zNodenetwork works together with the
`Internet Server
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`30
`
`
`
`
`Premise No. 2 is wrong: The zHub and zNode are components Premise No. 2 is wrong: The zHub and zNode are components
`
`specially designed to carry out the DBCS functionsspecially designed to carry out the DBCS functions
`
`Muthukumarasamy, ¶ [0026]
`
`Muthukumarasamy, ¶ [0058]
`
`Muthukumarasamy, ¶ [0057]
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`IPR2022-00793, 794, and 795, Reply 27-30
`
`31
`
`
`
`
`Premise No. 2 is wrong: The zHub and zNode are components Premise No. 2 is wrong: The zHub and zNode are components
`
`specially designed to carry out the DBCS functionsspecially designed to carry out the DBCS functions
`
`Muthukumarasamy, Fig. 8
`
`Muthukumarasamy, Fig. 10
`
`.
`.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`IPR2022-00793, 794, and 795, Reply 27-30
`
`32
`
`
`
`
`
`Premise No. 2 is WrongPremise No. 2 is Wrong
`
`No. 2
`
`Touchstream’s Second Flawed Premise
`The zHub and the zNode are not part of a server system
`
`• Premise No. 2 is wrong: The zHuband zNodeare components specially
`designed to carry out the DBCSfunctions
`
`• Premise No. 2 is wrong: The zHub/zNode network works together with
`the Internet Server
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`33
`
`
`
`
`Premise No. 2 is wrong: The zHub/zNode network works Premise No. 2 is wrong: The zHub/zNode network works
`
`together with Internet Servertogether with Internet Server
`
`Muthukumarasamy, Fig. 1
`.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Muthukumarasamy, Fig. 12
`IPR2022-00793, Pet 25-32, 48-51, Reply 27-30
`IPR2022-00793, Pet 28-35, 54-57, Reply 27-30
`IPR2022-00793, Pet 27-33, 48-51, 53-56, Reply 27-30
`
`34
`
`
`
`
`Premise No. 2 is wrong: The zHub/zNode network works Premise No. 2 is wrong: The zHub/zNode network works
`
`together with Internet Servertogether with Internet Server
`
`Muthukumarasamy, ¶ [0045]
`
`Muthukumarasamy, ¶ [0066]
`
`Muthukumarasamy, ¶ [0069]
`
`Muthukumarasamy, ¶ [0057]
`
`Muthukumarasamy, ¶ [0068]
`IPR2022-00793, Pet 25-32, 48-51, Reply 27-30
`IPR2022-00793, Pet 28-35, 54-57, Reply 27-30
`IPR2022-00793, Pet 27-33, 48-51, 53-56, Reply 27-30
`
`35
`
`.
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`
`
`
`
`Premise No. 2 is WrongPremise No. 2 is Wrong
`
`No. 2
`
`Touchstream’s Second Flawed Premise
`
`The zHub and the zNode are not part of a server system
`
`• Premise No. 2 is wrong: The zHuband zNodeare components specially
`designed to carry out the DBCSfunctions
`• Premise No. 2 is wrong: The zHub/zNodenetwork works together with the
`Internet Server
`
`The zHub and zNode are both part of the DBCS,
`which teaches the claimed “server system”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`36
`
`
`
`
`
`Touchstream’s 1st & 2nd Flawed Premises FailTouchstream’s 1st & 2nd Flawed Premises Fail
`
`Muthukumarasamy does not
`teach the “server system”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`37
`
`
`
`
`
`Touchstream’s 3rd and 4th Flawed PremisesTouchstream’s 3rd and 4th Flawed Premises
`
`Muthukumarasamy does not teach
`the “server system” receiving a
`message identifying a “particular
`media player”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`38
`
`
`
`
`
`Premise No. 3 is WrongPremise No. 3 is Wrong
`
`No. 3
`
`Touchstream’s Third Flawed Premise
`The IED’s requests for content do not identify “media players”
`
`• Premise No. 3 is wrong: Because the IED allows a user to request content
`from disparate sources, the IED’s request identifies a media player
`associated with the source of the requested content
`• Premise No. 3 is wrong: Hardware device sources (e.g., DVR, Set-Top Box)
`use media players
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`39
`
`
`
`
`
`Premise No. 3 is WrongPremise No. 3 is Wrong
`
`No. 3
`
`Touchstream’s Third Flawed Premise
`The IED’s requests for content do not identify “media players”
`• Premise No. 3 is wrong: Because the IED allows a user to request
`content from disparate sources, the IED’s request identifies a media
`player associated with the source of the requested content
`
`• Premise No. 3 is wrong: Hardware device sources (e.g., DVR, Set-Top Box)
`use media players
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`40
`
`
`
`
`Premise No. 3 is wrong: Because the IED allows a user to request content from Premise No. 3 is wrong: Because the IED allows a user to request content from
`
`disparate sources, IED’s request identifies a media player associated with the source disparate sources, IED’s request identifies a media player associated with the source
`
`of the requested contentof the requested content
`
`Id., ¶ [0049]
`
`Id., ¶ [0047]
`
`Muthukumarasamy, Fig. 2
`
`IPR2022-00793, Pet. 32-35, 40-41, 48-51, Reply 18-20, 26-27
`IPR2022-00794, Pet. 35-38, 45-46, 54-57, Reply 18-20, 26-27
`IPR2022-00794, Pet. 35-37, 42-43, 48-51, Reply 18-20, 26-27
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`Id., ¶ [0048]
`
`41
`
`
`
`
`Premise No. 3 is wrong: Because the IED allows a user to request content from Premise No. 3 is wrong: Because the IED allows a user to request content from
`
`disparate sources, IED’s request identifies a media player associated with the source disparate sources, IED’s request identifies a media player associated with the source
`
`of the requested contentof the requested content
`
`Ex. 1005, ¶ 100
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`42
`
`
`
`
`
`Premise No. 3 is WrongPremise No. 3 is Wrong
`
`No. 3
`
`Touchstream’s Third Flawed Premise
`The IED’s requests for content do not identify “media players”
`
`• Premise No. 3 is wrong: Because the IED allows a user to request content
`from disparate sources, the IED’s request identifies a media player
`associated with the source of the requested content
`
`• Premise No. 3 is wrong: Hardware device sources (e.g., DVR, Set‐Top
`Box) use software media players
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`43
`
`
`
`
`Premise No. 3 is wrong: Hardware device sources (e.g., Set‐Top Premise No. 3 is wrong: Hardware device sources (e.g., Set‐Top
`
`Box, DVR) use media playersBox, DVR) use media players
`
`Petitioner’s expert explained that Muthukumarasamy’shardware devices
`load software media players to play and control certain media content:
`
`Ex. 1005, ¶ 71
`
`IPR2022-00793, Pet. 20-21, 32-35, 40-41, 48-51, Reply 18-20, 26-27
`IPR2022-00794, Pet. 23-24, 35-38, 45-46, 54-57, Reply 18-20, 26-27
`IPR2022-00794, Pet. 22-23, 35-37, 42-43, 48-51, Reply 18-20, 26-27
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`44
`
`
`
`
`Premise No. 3 is wrong: Hardware device sources (e.g., Set‐Top Premise No. 3 is wrong: Hardware device sources (e.g., Set‐Top
`
`Box, DVR) use media playersBox, DVR) use media players
`
`Touchstream’sexpert admits that a hardware device source like a set-
`top box presents content from disparate sources
`
`Ex. 2022, ¶ 154
`
`IPR2022-00793, Pet. 32-35, 40-41, 48-51, Reply 18-20, 26-27
`IPR2022-00794, Pet. 35-38, 45-46, 54-57, Reply 18-20, 26-27
`IPR2022-00794, Pet. 35-37, 42-43, 48-51, Reply 18-20, 26-27
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`45
`
`
`
`
`Premise No. 3 is wrong: Hardware device sources (e.g., Set‐Top Premise No. 3 is wrong: Hardware device sources (e.g., Set‐Top
`
`Box, DVR) use media playersBox, DVR) use media players
`
`Here, Touchstreamargues a hardware device like a set top box does not
`usea “media player”
`But elsewhere, Touchstreamrecognizes that a hardware device like a set
`POR, 49
`top box usesa “media player”
`
`Ex. 1019, ¶ 38
`
`IPR2022-00793, Pet. 32-35, 40-41, 48-51, Reply 18-20, 26-27
`IPR2022-00794, Pet. 35-38, 45-46, 54-57, Reply 18-20, 26-27
`IPR2022-00794, Pet. 35-37, 42-43, 48-51, Reply 18-20, 26-27
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`46
`
`
`
`
`
`Premise No. 3 is WrongPremise No. 3 is Wrong
`
`No. 3
`
`Touchstream’s Third Flawed Premise
`The IED’s requests for content do not identify “media players”
`
`• Premise No. 3 is wrong: Because the IED allows a user to request content
`from disparate sources, the IED’s request identifies a media player
`associated with the source of the requested content
`• Premise No. 3 is wrong: Hardware device sources (e.g., DVR, Set-Top Box)
`use media players
`
`A content request sent from Muthukumarasamy’s IED is
`“receiv[ed]” in a server system” and “identif[ies] a
`particular media player for playing content from the file”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`47
`
`
`
`
`
`Touchstream’s 3rd Flawed Premise FailsTouchstream’s 3rd Flawed Premise Fails
`
`Muthukumarasamy does not teach
`the “server system” receiving a
`message identifying a “particular
`media player”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`48
`
`
`
`
`
`Premise No. 4 is Irrelevant and WrongPremise No. 4 is Irrelevant and Wrong
`
`No. 4
`
`Touchstream’s Fourth Flawed Premise
`The Petition did not map the RCIBS as part of the “server system”
`
`• Premise 4 is irrelevant: As explained for Premise 1, because the computer
`running the RCIBSis controllable by the zHub/zNode(server system),
`whether the RCIBSitself is the server system is irrelevant.
`• Premise No. 4 is wrong: Muthukumarasamy describes the RCIBSas part of
`the “DBCS”
`• Premise No. 4 is wrong: The Petition mapped the DBCS—including the
`RCIBS—to the “server system”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`49
`
`
`
`
`
`Premise No. 4 is Irrelevant and WrongPremise No. 4 is Irrelevant and Wrong
`
`No. 4
`
`Touchstream’s Fourth Flawed Premise
`The Petition did not map the RCIBS as part of the “server system”
`• Premise 4 is irrelevant: As explained for Premise 1, because the
`computer running the RCIBS is controllable by the zHub/zNode (server
`system), whether the RCIBS itself is the server system is irrelevant.
`
`• Premise No. 4 is wrong: Muthukumarasamy describes the RCIBSas part of
`the “DBCS”
`• Premise No. 4 is wrong: The Petition mapped the DBCS—including the
`RCIBS—to the “server system”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`50
`
`
`
`
`Premise No. 4 is irrelevant: the computer running the RCIBS is Premise No. 4 is irrelevant: the computer running the RCIBS is
`
`controllable by the zHub/zNode (server system)controllable by the zHub/zNode (server system)
`
`POR, 28
`
`Muthukumarasamy, ¶ [0083]
`IPR2022-00793, Pet. 6-9, 13-22, 25-27, 48-51; Reply 13-17
`IPR2022-00794, Pet. 7-11, 15-25, 28-30, 54-57 ; Reply 13-17
`IPR2022-00795, Pet. 6-10, 14-24, 27-31, 48-51; Reply 13-17
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`51
`
`
`
`
`Premise No. 4 is irrelevant: the computer running the RCIBS is Premise No. 4 is irrelevant: the computer running the RCIBS is
`
`controllable by the zHub/zNode (server system)controllable by the zHub/zNode (server system)
`
`Muthukumarasamy, Fig. 1
`IPR2022-00793, Pet. 6-9, 13-22, 25-27, 48-51; Reply 13-17
`IPR2022-00794, Pet. 7-11, 15-25, 28-30, 54-57 ; Reply 13-17
`IPR2022-00795, Pet. 6-10, 14-24, 27-31, 48-51; Reply 13-17
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`52
`
`
`
`
`
`Premise No. 4 is Irrelevant and WrongPremise No. 4 is Irrelevant and Wrong
`
`No. 4
`
`Touchstream’s Fourth Flawed Premise
`The Petition did not map the RCIBS as part of the “server system”
`
`• Premise 4 is irrelevant: As explained for Premise 1, because the computer
`running the RCIBSis controllable by the zHub/zNode(server system),
`whether the RCIBSitself is the server system is irrelevant.
`• Premise No. 4 is wrong: The Petition mapped the DBCS—including the
`RCIBS—to the “server system”
`
`• Premise No. 4 is wrong: Muthukumarasamy describes the RCIBS as
`part of the “DBCS”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`53
`
`
`
`
`Premise No. 4 is wrong: Muthukumarasamy describes the Premise No. 4 is wrong: Muthukumarasamy describes the
`
`RCIBS as part of the “DBCS”RCIBS as part of the “DBCS”
`
`Muthukumarasamy, ¶ [0083]
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`IPR2022-00793, Pet. 8, 13, 25, 38, Reply 20-22
`IPR2022-00794, Pet. 9, 27, 65, Reply 20-22
`IPR2022-00795, Pet. 8, 27, 40, 67, 70, Reply 20-22
`
`54
`
`
`
`
`
`Premise No. 4 is WrongPremise No. 4 is Wrong
`
`No. 3
`
`Touchstream’s Third Flawed Premise
`The Petition did not map the RCIBS as part of the “server system”
`
`• Premise 4 is irrelevant: As explained for Premise 1, because the computer
`running the RCIBSis controllable by the zHub/zNode(server system),
`whether the RCIBSitself is the server system is irrelevant.
`• Premise No. 4 is wrong: Muthukumarasamy describes the RCIBSas part of
`the “DBCS”
`
`• Premise No. 4 is wrong: The Petition mapped the DBCS—including the
`RCIBS—to the “server system”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`55
`
`
`
`
`Premise No. 4 is wrong: The Petition mapped the DBCS—Premise No. 4 is wrong: The Petition mapped the DBCS—
`
`including the RCIBS—to the “server system”including the RCIBS—to the “server system”
`
`The Petition mapped the “RCIBS” as part of the “server system”
`
`Pet. 8
`
`Pet. 13
`
`Pet. 25, 38
`IPR2022-00793, Pet. 8, 13, 25, 38, Reply 20-22
`IPR2022-00794, Pet. 9, 27, 65, Reply 20-22
`IPR2022-00795, Pet. 8, 27, 40, 67, 70, Reply 20-22
`
`56
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`
`
`
`
`Touchstream’s 4th Flawed Premise FailsTouchstream’s 4th Flawed Premise Fails
`
`Muthukumarasamy does not teach
`the “server system” receiving a
`message identifying a “particular
`media player”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`57
`
`
`
`
`
`Premise No. 4 is WrongPremise No. 4 is Wrong
`
`No. 3
`
`Touchstream’s Third Flawed Premise
`The Petition did not map the RCIBS as part of the “server system”
`
`• Premise 4 is irrelevant: As explained for Premise 1, because the computer
`running the RCIBSis controllable by the zHub/zNode(server system),
`whether the RCIBSitself is the server system is irrelevant.
`• Premise No. 4 is wrong: Muthukumarasamy describes the RCIBSas part of
`the “DBCS”
`• Premise No. 4 is wrong: The Petition mapped the DBCS—including the
`RCIBS—to the “server system”
`
`A content request sent to Muthukumarasamy’s RCIBS is
`“receiv[ed]” in a server system” and “identif[ies] a
`particular media player for playing content from the file”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`58
`
`
`
`
`
`Touchstream’s 5th Flawed PremiseTouchstream’s 5th Flawed Premise
`
`Muthukumarasamy does not
`teach the “programming code”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`59
`
`
`
`
`
`Premise No. 5 is WrongPremise No. 5 is Wrong
`
`No. 5
`
`Touchstream’s Fifth Flawed Premise
`Programming code should be construed as “computer program instruction(s)
`encoded for execution by a data processing apparatus (such as a computer
`processor)”
`
`• Premise No. 5 is wrong: Nothing in the claims requires the “programming code”
`be computer program instructions
`• Premise No. 5 is wrong: The patent discloses other options like pulses of light
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`60
`
`
`
`
`
`Premise No. 5 is WrongPremise No. 5 is Wrong
`
`No. 5
`
`Touchstream’s Fifth Flawed Premise
`Programming code should be construed as “computer program instruction(s)
`encoded for execution by a data processing apparatus (such as a computer
`processor)”
`• Premise No. 5 is wrong: Nothing in the claims requires the “programming
`code” be computer program instructions
`
`• Premise No. 5 is wrong: The patent discloses other options like pulses of light
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`61
`
`
`
`
`Premise No. 5 is wrong: Nothing in the claims requires the Premise No. 5 is wrong: Nothing in the claims requires the
`
`“programming code” be computer program instructions“programming code” be computer program instructions
`
`Term
`
`“Programming
`code”
`
`Google’s Position
`
`No construction
`necessary
`
`Touchstream’s Position
`
`“[C]omputerprogram instruction(s) encoded
`for execution by a data processing apparatus
`(such as a computer processor)”
`
`’528 Patent, claim 1
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`IPR2022-00793, Pet. 48-53, 57-60, Reply 2-3
`IPR2022-00794, Pet. 54-61, Reply 2-3
`IPR2022-00795, Pet. 48-52, 58-63, Reply 2-3
`
`62
`
`
`
`
`
`Premise No. 5 is WrongPremise No. 5 is Wrong
`
`No. 5
`
`Touchstream’s Fifth Flawed Premise
`Programming code should be construed as “computer program instruction(s)
`encoded for execution by a data processing apparatus (such as a computer
`processor)”
`
`• Premise No. 5 is wrong: Nothing in the claims requires the “programming code”
`be computer program instructions
`
`• Premise No. 5 is wrong: The patent discloses other options like pulses of
`light
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`63
`
`
`
`
`Premise No. 5 is wrong: The patent discloses other options like Premise No. 5 is wrong: The patent discloses other options like
`
`pulses of lightpulses of light
`
`Dr. Bederson:
`
`’528 Patent, 9:36-51
`
`Ex-2021, 94:12-18, 95:7-12
`IPR2022-00793, Pet. 48-53, 57-60, Reply 22-26
`IPR2022-00794, Pet. 54-61, Reply 22-26
`IPR2022-00795, Pet. 48-52, 58-63, Reply 22-26
`
`64
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`
`
`
`
`Muthukumarasamy’s RF and IR signals are programming codeMuthukumarasamy’s RF and IR signals are programming code
`
`Muthukumarasamy, ¶ [0044]
`
`Muthukumarasamy, ¶ [0128]
`
`Muthukumarasamy, ¶ [0057]
`
`Muthukumarasamy, ¶ [0058]
`IPR2022-00793, Pet. 48-51, 57-58, Reply 22-26
`IPR2022-00794, Pet. 54-60, Reply 22-26
`IPR2022-00795, Pet. 48-51, Reply 22-26
`
`65
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`
`
`
`
`Muthukumarasamy’s RF and IR signals are programming codeMuthukumarasamy’s RF and IR signals are programming code
`
`Dr. Bederson:
`
`Ex-2021, 58:14-61:20
`
`Ex-2021, 101:9-17
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`IPR2022-00793, Pet. 48-51, 57-58, Reply 22-26
`IPR2022-00794, Pet. 54-60, Reply 22-26
`IPR2022-00795, Pet. 48-51, Reply 22-26
`
`66
`
`
`
`
`
`Premise No. 5 is WrongPremise No. 5 is Wrong
`
`No. 5
`
`Touchstream’s Fifth Flawed Premise
`Programming code should be construed as “computer program instruction(s)
`encoded for execution by a data processing apparatus (such as a computer
`processor)”
`
`• Premise No. 5 is wrong: Nothing in the claims requires the “programming code”
`be computer program instructions
`• Premise No. 5 is wrong: The patent discloses other options like pulses of light
`
`Muthukumarasamy’s RF and IR signals teach
`the claimed “programming code”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`67
`
`
`
`
`
`Touchstream’s 5th Flawed Premise FailsTouchstream’s 5th Flawed Premise Fails
`
`Muthukumarasamy does not
`teach the “programming code”
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`68
`
`
`
`
`Ground 2: Muthukumarasamy and Ground 2: Muthukumarasamy and
`
`HaywardHayward
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`69
`
`
`
`
`
`Prior art: HaywardPrior art: Hayward
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`IPR2022-00793, Pet. 10-11, 14-17
`IPR2022-00794, Pet. 12-13, 16-20
`IPR2022-00795, Pet. 11-12, 15-20
`
`70
`
`
`
`Combination of RCIBS process and Hayward teaches “loading the
`Combination of RCIBS process and Hayward teaches “loading the
`
`particular media player in the content presentation device”particular media player in the content presentation device”
`
`Muthukumarasamy, Fig. 18
`
`Muthukumarasamy, Fig. 19
`IPR2022-00793, Pet. 14-17, 22-25, Reply 30-31
`IPR2022-00794, Pet. 16-20, 25-28, Reply 30-31
`IPR2022-00795, Pet. 15-20, 24-27, Reply 30-31
`
`71
`
`DEMONSTRATIVE EXHIBIT –NOT EVIDENCE
`
`
`
`Combination of RCIBS process and Hayward teaches “loading the
`Combination of RCIBS process and Hayward
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