Apple Inc.
`v.
`Aire Technology Ltd.
`
`IPR2022-01137, U.S. Patent No. 8,581,706
`
`Patent Owner’s Demonstrative Exhibits
`
`October 2, 2023
`
`Ex. 2013
`
`Aire Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Aire Technology Ltd.
`Ex. 2013 - Page 1
`
`
`v.
`Aire Technology Ltd.
`
`IPR2022-01137, U.S. Patent No. 8,581,706
`
`Patent Owner’s Demonstrative Exhibits
`
`October 2, 2023
`
`Ex. 2013
`
`Aire Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`Aire Technology Ltd.
`Ex. 2013 - Page 1
`
`
`
`Why Petition Fails
`
`1. A POSITA would not be motivated to combine Guthery with Nozawa
`because the proposed combination contradicts Guthery’s goal of
`tightly coupling the execution of applications with management of
`limited RAM memory. [Grounds 1, 2]
`
`2. A POSITA would not be motivated to combine Guthery with RFID
`Handbook because the proposed combination leaves Guthery’s RAM
`memory, which cannot be segmented, vulnerable to security risks.
`[Grounds 2, 4]
`
`Aire Technology Ltd.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`Aire Technology Ltd.
`Ex. 2013 - Page 2
`
`
`
`Grounds 1, 2: POSITA Would Not Combine Guthery & Nozawa
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`Aire Technology Ltd.
`Ex. 2013 - Page 3
`
`
`
`No Motivation to Combine Guthery with Nozawa
`
`Aire Technology Ltd.
`
`’706 Patent (Ex. 1001), claim 1; see also claim 11.
`Grounds 1, 2
`Grounds 2, 4
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`4
`
`Aire Technology Ltd.
`Ex. 2013 - Page 4
`
`
`
`Guthery’s Goal of Managing Limited Resources
`
`Guthery (Ex. 1005), 2:52-58.
`
`Guthery (Ex. 1005), 10:42-46.
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`Aire Technology Ltd.
`Ex. 2013 - Page 5
`
`
`
`Guthery’s Utilizes One or Multiple Packets
`
`Guthery (Ex. 1005), 7:43-46.
`
`Guthery (Ex. 1005), 7:58-65.
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`6
`
`Aire Technology Ltd.
`Ex. 2013 - Page 6
`
`
`
`Guthery’s Packet-by-Packet Control
`
`Guthery (Ex. 1005), 9:7-12.
`
`Guthery (Ex. 1005), 9:26-29.
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`Guthery (Ex. 1005), 12:65-13:4.
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`Aire Technology Ltd.
`Ex. 2013 - Page 7
`
`
`
`Guthery’s Packet-by-Packet Control – cont’d
`
`Guthery (Ex. 1005), 9:35-39.
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`Guthery (Ex. 1005), 13:5-14.
`
`Aire Technology Ltd.
`Ex. 2013 - Page 8
`
`
`
`Guthery’s Exemplary Cases
`
`• Executing single application
`with single packet input and
`single packet output; see Figs.
`14A-14B.
`
`• Executing two applications
`simultaneously, each with single
`packet input and single packet
`output; see Figs. 15A-15D.
`
`Guthery (Ex. 1005), 12:17-22.
`
`Guthery (Ex. 1005), 12:54-59.
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`Aire Technology Ltd.
`Ex. 2013 - Page 9
`
`
`
`Guthery’s Exemplary Cases – cont’d
`
`• Executing single application
`with single packet input and
`multiple packet output; see
`Figs. 16A-16B.
`
`• Executing single application
`with multiple packet input and
`multiple packet output, where
`processing of the input packets
`only begins after all input
`packets have been received;
`see Figs. 17A-17C.
`
`Guthery (Ex. 1005), 12:60-64.
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`Guthery (Ex. 1005), 13:20-30.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`10
`
`Aire Technology Ltd.
`Ex. 2013 - Page 10
`
`
`
`Guthery’s Exemplary Cases – cont’d
`
`• Executing single application
`with multiple packet input and
`multiple packet output, where
`processing of the input packets
`begins after the first input
`packet has been received; see
`Figs. 18A-18D.
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
`
`Guthery (Ex. 1005), 13:43-52.
`
`Aire Technology Ltd.
`Ex. 2013 - Page 11
`
`
`
`Guthery’s “Embodiment”
`
`• Guthery’s ubiquitous use of “embodiment” refers to
`individual aspects or features of the “present
`invention.”
`
`• Guthery only discloses a preferred embodiment
`without an alternative embodiment.
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`Paper 22, Patent Owner’s Sur-Reply at 6-9
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`Aire Technology Ltd.
`Ex. 2013 - Page 12
`
`
`
`No Motivation to Combine Guthery with Nozawa
`
`• Petition proposes to modify Guthery with Nozawa’s application tracking
`history to automatically select a particular application upon establishing a
`new connection with a host.
`• Petition incorrectly asserts the benefit of efficiency gains.
`• No efficiency gained because Guthery implements a tightly coupled
`scheduling regimen to efficiently utilize limited RAM.
`• Not waiting to receive a Request-to-Send before selecting an application is
`detrimental to that scheduling regimen.
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`Paper 17, Patent Owner’s Response at 11-15; Paper 22, Patent Owner’s Sur-Reply at 1, 15, 16
`
`Aire Technology Ltd.
`Ex. 2013 - Page 13
`
`
`
`No Motivation to Combine Guthery with Nozawa
`
`• Without the Request-to-Send, Guthery’s applications cannot determine:
`– the size of the message to be received from the host (slide 8)
`
`– the type of data to be received, e.g., encrypted, numbers for storage (slides 10, 11)
`
`– the number of buffers the application should request from the card manager (slide 7)
`
`– how to issue Permissions-to-Send (Figs. 17, 18)
`• Modifying Guthery’s Request-to-Send regimen does not reduce the number of
`initialization steps as Petitioner asserts.
`• Destroys Guthery’s objective of a tightly coupled scheduling regimen.
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`Paper 17, Patent Owner’s Response at 11-15; Paper 22, Patent Owner’s Sur-Reply at 1, 15, 16
`
`Aire Technology Ltd.
`Ex. 2013 - Page 14
`
`
`
`No Motivation to Combine Guthery with Nozawa
`
`• Petitioner points to Figs. 14-15 as limited to single packet communications.
`• Petitioner incorrectly asserts that multiple packet capabilities are a
`different “embodiment” for Guthery.
`
`– In Figs. 14-18, Guthery gives “exemplary cases” to cover all options for either single or
`multiple packet scenarios in both input and output, not just single packets.
`• Petitioner cannot “pick and choose from any one reference only so much of it
`as will support a given position, to the exclusion of other parts necessary to
`the full appreciation of what such reference fairly suggests to one of ordinary
`skill in the art.”
`
`– Application of Wesslau, 353 F.2d 238, 241 (C.C.P.A. 1965).
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`Paper 22, Patent Owner’s Sur-Reply at 1, 10-12
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`15
`
`Aire Technology Ltd.
`Ex. 2013 - Page 15
`
`
`
`Grounds 2, 4: POSITA Would Not Combine Guthery & RFID Handbook
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`Aire Technology Ltd.
`Ex. 2013 - Page 16
`
`
`
`No Motivation to Combine Guthery with Nozawa
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`17
`
`’706 Patent, claim 20; see also claim 16.
`
`Aire Technology Ltd.
`Ex. 2013 - Page 17
`
`
`
`No Motivation to Combine Guthery with RFID Handbook
`
`• Petition proposes to modify Guthery with RFID Handbook’s segmented EEPROM.
`• EEPROM is not Guthery’s only memory ⏤ Guthery’s RAM cannot be segmented.
`
`– Guthery’s RAM “is logically divided into several buffers [that] can be assigned to an
`application 32 according to the application’s needs,” Guthery at 7:12-15, Fig. 3.
`
`– The buffers are shared among applications to service all incoming and outgoing data.
`• Petition incorrectly asserts that the proposed combination enhances security
`by “effectively isolating each application” because data communicated with
`the host is not isolated by application.
`• POSITA would not have recognized any benefit from segmenting Guthery’s
`EEPROM memory.
`
`Aire Technology Ltd.
`
`Paper 17, Patent Owner’s Response at 1, 2, 17-19; Paper 22, Patent Owner’s Sur-Reply at 1, 10-12
`Grounds 2, 4
`MTA
`Grounds 1, 2
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`18
`
`Aire Technology Ltd.
`Ex. 2013 - Page 18
`
`
`
`Contingent Motion to Amend
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`Aire Technology Ltd.
`Ex. 2013 - Page 19
`
`
`
`Substitute Claims
`
`(Proposed substitute for claim 11) A contactlessly communicating portable data carrier,
`23.
`comprising at least two applications stored thereon and a communication device configured to control
`communication between a reading device and the at least two applications,
`wherein the communication device is set up to generate communication-readiness signals to the
`reading device which in each case indicate to the reading device a communication readiness for one of
`the applications and comprise an identification number assigned to the corresponding communication-
`readiness application, and
`wherein after selection of one of the plurality of applications, subsequent communication between
`the reading device and the selected application takes place without requiring any further steps, and
`wherein the communication device is set up to store information in a nonvolatile memory of the
`data carrier about which of the at least two applications last communicated with a reading device.
`…
`
`Paper 16, Patent Owner’s Motion to Amend, Appendix A
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`20
`
`Aire Technology Ltd.
`Ex. 2013 - Page 20
`
`
`
`Substitute Claims
`
`(Proposed substitute for claim 11) A contactlessly communicating portable data carrier,
`23.
`comprising at least two applications stored thereon and a communication device configured to control
`communication between a reading device and the at least two applications,
`wherein the communication device is set up to generate communication-readiness signals to the
`reading device which in each case indicate to the reading device a communication readiness for one of
`the applications and comprise an identification number assigned to the corresponding communication-
`readiness application, and
`wherein after selection of one of the plurality of applications, subsequent communication between
`the reading device and the selected application takes place without requiring any further steps, and
`wherein the communication device is set up to store information in a nonvolatile memory of the
`data carrier about which of the at least two applications last communicated with a reading device.
`…
`
`Paper 16, Patent Owner Motion to Amend, Appendix A
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`21
`
`Aire Technology Ltd.
`Ex. 2013 - Page 21
`
`
`
`U.S. Patent No. 8,581,706
`
`generate
`communication-readiness
`signals
`
`selection of one of the
`plurality of applications
`
`subsequent communication
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`22
`
`Ex. 1002 at 313-314
`
`Aire Technology Ltd.
`Ex. 2013 - Page 22
`
`
`
`U.S. Patent No. 8,581,706
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`23
`
`Ex. 1002 at 290
`
`Aire Technology Ltd.
`Ex. 2013 - Page 23
`
`
`
`U.S. Patent No. 8,581,706
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`24
`
`Ex. 1002 at 295-296
`
`Aire Technology Ltd.
`Ex. 2013 - Page 24
`
`
`
`U.S. Patent No. 8,581,706
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`25
`
`Ex. 1002 at 297-298
`
`Aire Technology Ltd.
`Ex. 2013 - Page 25
`
`
`
`U.S. Patent No. 6,824,064 (Guthery)
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`26
`
`Ex. 1005 at 8:30-39
`
`Aire Technology Ltd.
`Ex. 2013 - Page 26
`
`
`
`U.S. Patent No. 6,824,064 (Guthery)
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`27
`
`Ex. 1005 at 8:65-9:17.
`
`Aire Technology Ltd.
`Ex. 2013 - Page 27
`
`
`
`U.S. Patent No. 6,824,064 (Guthery)
`
`“Card manager sends application index…”
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`28
`
`Ex. 1005 at 8:30-39; Paper 19, Pet. Opp. to Motion to Amend at 15
`
`Aire Technology Ltd.
`Ex. 2013 - Page 28
`
`
`
`U.S. Patent No. 6,824,064 (Guthery)
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`29
`
`Ex. 1005 at 12:53-59, 10:6-12, 10:26-31
`
`Aire Technology Ltd.
`Ex. 2013 - Page 29
`
`
`
`Substitute Claims
`
`24. (Proposed substitute for claim 12) The data carrier according to claim 11 23,
`wherein the communication device is set up to emit, upon new contacting of a reading device
`with the data carrier, a communication-readiness signal first for one of the at least two
`applications that is different from the application designated by the stored information,
`wherein the communication device is set up to uniquely address the one or more of the
`least two applications with a receiving device, and
`wherein communication between the reading device and the uniquely addressed
`application takes place subsequently without requiring any further steps after the
`communication-readiness signals are generated.
`
`Paper 16, Patent Owner’s Motion to Amend, Appendix A
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`30
`
`Aire Technology Ltd.
`Ex. 2013 - Page 30
`
`
`
`Substitute Claims
`
`(Proposed substitute for claim 18) A contactlessly communicating portable data carrier,
`25.
`comprising at least two applications stored thereon and a communication device configured to control
`communication between a reading device and the at least two applications,
`wherein the communication device is set up to generate communication-readiness signals to the
`reading device which in each case indicate to the reading device a communication readiness for one of
`the applications and comprise an identification number assigned to the corresponding communication-
`readiness application,
`wherein after selection of one of the plurality of applications, subsequent communication between
`the reading device and the selected application takes place without requiring any further steps, and
`wherein the data carrier is configured as a security module in a device comprising a communication
`device configured for contactless communication, the security module having software configured to
`communicate contactlessly via the communication device of the device.
`Paper 16, Patent Owner’s Motion to Amend, Appendix A
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`31
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`Aire Technology Ltd.
`Ex. 2013 - Page 31
`
`
`
`Substitute Claims
`
`26. (Proposed substitute for Claim 20) A contactlessly communicating portable data carrier,
`comprising at least two applications stored thereon and a communication device configured to control
`communication between a reading device and the at least two applications,
`wherein the communication device is set up to generate communication-readiness signals to the
`reading device which in each case indicate to the reading device a communication readiness for one of
`the applications and comprise an identification number assigned to the corresponding communication-
`readiness application,
`wherein after selection of one of the plurality of applications, subsequent communication between
`the reading device and the selected application takes place without requiring any further steps, and
`wherein the data carrier is configured as an electronic device with a contactless interface for
`communication with a reading device and with a plurality of memories, each of the memories having no
`more than one of the at least two applications stored therein in each case.
`
`Paper 16, Patent Owner’s Motion to Amend, Appendix A
`
`Aire Technology Ltd.
`
`Grounds 1, 2
`
`Grounds 2, 4
`
`MTA
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`32
`
`Aire Technology Ltd.
`Ex. 2013 - Page 32
`
`
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