Comparison of EX1003 with Corrected IPR2022-01291 Petition
`
`Anthony Declaration (EX1003)
`29. Iwamiya discloses an “optical
`biological information detecting
`apparatus” which is a physiological
`monitoring device. APPLE-1004,
`Abstract. For example, Iwamiya
`describes that the “optical biological
`information detecting apparatus” is
`provided in “a central portion of the
`back cover” of “a wristwatch” (i.e.,
`facing the wearer’s wrist). APPLE-
`1004, 5:54-66, FIG. 1. As shown in the
`following annotated FIG. 4 from
`Iwamiya, the device includes LEDs 6
`(shown in green) that emit light
`(orange) that is refected by the tissue of
`the wearer’s wrist (pink) and detected
`by photodiodes 9 (yellow).
`
`Corrected IPR2022-01291 Petition
`Iwamiya discloses an “optical
`biological information detecting
`apparatus” which is a physiological
`monitoring device. APPLE-1004,
`Abstract. For example, Iwamiya
`describes that the “optical biological
`information detecting apparatus” is
`provided in “a central portion of the
`back cover” of “a wristwatch” (i.e.,
`facing the wearer’s wrist). APPLE-
`1004, 5:54-66, FIG. 1. As shown in the
`following annotated FIG. 4 from
`Iwamiya, the device includes LEDs 6
`(shown in green) that emit light
`(orange) that is refected by the tissue of
`the wearer’s wrist (light pink) and
`detected by photodiodes 9 (yellow).
`APPLE-1003, [29]:
`
`APPLE-1004, Detail of FIG. 4
`(annotated)
`
`30. Sarantos describes a “wristband-
`type wearable fitness monitor” that
`measures “physiological parameters”
`of the wearer, such as the person’s
`“heart rate” and “blood oxygenation
`levels.” APPLE-1005, 2:5-14, 5:55-59,
`7:12-14, 13:39-47. The monitor
`performs these measurements using a
`photoplethysmographic (PPG) sensor,
`
`APPLE-1004, Detail of FIG. 4
`(annotated)
`
`(Pet. 6-7)
`Sarantos describes a “wristband-type
`wearable fitness monitor” that
`measures “physiological parameters”
`of the wearer, such as the person’s
`“heart rate” and “blood oxygenation
`levels.” APPLE-1005, 2:5-14, 5:55-59,
`7:12-14, 13:39-47. The monitor
`performs these measurements using a
`photoplethysmographic (PPG) sensor,
`
`1
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`which includes one or more light
`sources (e.g., LEDs) and an array of
`photodetectors. Id., 1:9-10, 43-47,
`7:12-16, 15:23-43. Sarantos describes
`that when the monitor “is worn by a
`person in a manner similar to a
`wristwatch, the back face” of the
`monitor “may be pressed against the
`person's skin, allowing the light
`sources” of the PPG sensor “to
`illuminate the person’s skin.” Id., 1:48-
`51, 7:12-23. The light “diffuses
`through the person's flesh and a portion
`of this light is then emitted back” (i.e.,
`reflected) “out of the person's skin in
`close proximity to where the light was
`introduced into the flesh.” Id., 7:24-28.
`The photodetector array of the PPG
`sensor measures the “intensity” of this
`reflected light, and provides signals
`representing the intensity to “control
`logic” of the monitoring device.
`APPLE-1005, 2:5-14, 7:12-23, 13:39-
`47. The control logic can then calculate
`different physiological parameters
`based on characteristics of the reflected
`light signal. Id., 1:54-56, 7:12-23. For
`example, the person’s heart rate can be
`calculated based on “fluctuations in the
`amount of light from the light source
`that is emanated back out of the flesh”
`that correspond fluctuations in blood
`volume associated with each beat of
`the person’s heart. Id., 7:23-60.
`
`
`
`31. In the combination, Iwamiya
`discloses an “optical biological
`
`which includes one or more light
`sources (e.g., LEDs) and an array of
`photodetectors. Id., 1:9-10, 43-47,
`7:12-16, 15:23-43. Sarantos describes
`that when the monitor “is worn by a
`person in a manner similar to a
`wristwatch, the back face” of the
`monitor “may be pressed against the
`person's skin, allowing the light
`sources” of the PPG sensor “to
`illuminate the person’s skin.” Id., 1:48-
`51, 7:12-23. The light “diffuses
`through the person's flesh and a portion
`of this light is then emitted back” (i.e.,
`reflected) “out of the person's skin in
`close proximity to where the light was
`introduced into the flesh.” Id., 7:24-28;
`APPLE-1003, [30]. The photodetector
`array of the PPG sensor measures the
`“intensity” of this reflected light, and
`provides signals representing the
`intensity to “control logic” of the
`monitoring device. APPLE-1005, 2:5-
`14, 7:12-23, 13:39-47. The control
`logic can then calculate different
`physiological parameters based on
`characteristics of the reflected light
`signal. Id., 1:54-56, 7:12-23. For
`example, the person’s heart rate can be
`calculated based on “fluctuations in the
`amount of light from the light source
`that is emanated back out of the flesh”
`that correspond fluctuations in blood
`volume associated with each beat of
`the person’s heart. Id., 7:23-60;
`APPLE-1003, [30].
`
`(Pet. 7-8)
`In the combination, Iwamiya discloses
`an “optical biological information
`2
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`information detecting apparatus” which
`is a physiological monitoring device.
`APPLE-1004, Abstract. For example,
`Iwamiya describes that the “optical
`biological information detecting
`apparatus” is provided in “a central
`portion of the back cover” of “a
`wristwatch” (i.e., facing the wearer’s
`wrist). APPLE-1004, 5:54- 66, FIG. 1.
`As shown in the following annotated
`FIG. 4 from Iwamiya, the device
`includes LEDs 6 (shown in green) that
`emit light (orange) that is refected by
`the tissue of the wearer’s wrist (pink)
`and detected by photodiodes 9
`(yellow).
`
`detecting apparatus” which is a
`physiological monitoring device.
`APPLE-1004, Abstract; APPLE-1003,
`[31]. For example, Iwamiya describes
`that the “optical biological information
`detecting apparatus” is provided in “a
`central portion of the back cover” of “a
`wristwatch” (i.e., facing the wearer’s
`wrist). APPLE-1004, 5:54- 66, FIG. 1.
`As shown in the following annotated
`FIG. 4 from Iwamiya, the device
`includes LEDs 6 (shown in green) that
`emit light (orange) that is refected by
`the tissue of the wearer’s wrist (light
`pink) and detected by photodiodes 9
`(yellow). APPLE-1003, [31]:
`
`APPLE-1004, Detail of FIG. 4
`(annotated)
`
`
`
`
`
`32. Accordingly, the combination of
`Iwamiya and Sarantos renders obvious
`a “physiological monitoring device.”
`
`
`33. In the combination, Iwamiya
`discloses “light emitting units 6” that
`are each “composed of a light emitting
`diode (LED).” APPLE-1004, 6:7-11,
`6:32-39. The light emitting units 6 are
`shown in green in the following
`annotated FIG. 3 from Iwamiya:
`
`
`
`APPLE-1004, Detail of FIG. 4
`(annotated)
`
`
`(Pet. 8-9)
`Accordingly, the combination of
`Iwamiya and Sarantos renders obvious
`a “physiological monitoring device.”
`
`(Pet. 9)
`In the combination, Iwamiya discloses
`“light emitting units 6” that are each
`“composed of a light emitting diode
`(LED).” APPLE-1004, 6:7-11, 6:32-
`39, 15:30-33, FIGS. 3-4, FIG. 12. The
`light emitting units 6 are shown in
`green in the following annotated FIG. 3
`from Iwamiya:
`
`3
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
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`
`
`APPLE-1004, Detail of FIG. 3
`(annotated)
`
`
`
`
`
`34. The light emitting units 6 “emit
`observation light of a specific
`wavelength band to optically observe a
`skin tissue of a human body.” Id., 6:7-
`11. The emitted observation light is in
`a first shape characterized by the
`specific location of each light emitting
`unit, e.g., the “3 o'clock” and “9
`o'clock” positions as shown in FIGS. 3
`and 4 of Iwamiya. See id., 6:7-11,
`FIGS. 3-4.
`
`
`35. In the combination, Iwamiya
`describes that the physiological sensor
`includes “an annular light guide unit 7
`that guides the observation light
`emitted from the light emitting units 6
`and annularly diffuses and irradiates
`the observation light with respect to a
`skin H.” APPLE-1004, 6:7-14, Fig. 4.
`The annular light guide unit 7 includes
`“a light guiding ring portion 11”
`formed “using a material such as
`transparent glass or a transparent resin
`with a high light transmitting
`property.” Id., 6:40-45. The annular
`light guide unit 7 also includes “a
`
`
`
`APPLE-1004, Detail of FIG. 3
`(annotated)
`
`
`(Pet. 10-11)
`The light emitting units 6 “emit
`observation light of a specific
`wavelength band to optically observe a
`skin tissue of a human body.” Id., 6:7-
`11. The emitted observation light is in
`a first shape characterized by the
`specific location of each light emitting
`unit, e.g., the “3 o'clock” and “9
`o'clock” positions as shown in FIGS. 3
`and 4 of Iwamiya. See id., 6:7-11,
`6:32-39, 15:30-33, FIGS. 3-4, FIG. 12;
`APPLE-1003, [34].
`
`(Pet. 11)
`In the combination, Iwamiya describes
`that the physiological sensor includes
`“an annular light guide unit 7 that
`guides the observation light emitted
`from the light emitting units 6 and
`annularly diffuses and irradiates the
`observation light with respect to a skin
`H.” APPLE-1004, 6:7-14, Fig. 4. The
`annular light guide unit 7 includes “a
`light guiding ring portion 11” formed
`“using a material such as transparent
`glass or a transparent resin with a high
`light transmitting property.” Id., 6:40-
`45. The annular light guide unit 7 also
`includes “a diffusion/irradiation ring
`4
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`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
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`diffusion/irradiation ring portion 12”
`that is “formed in almost a ring shape,
`using a clouded or milky resin with a
`light diffusing property.” Id., 6:40-42,
`7:4-6. The following annotated FIGS. 2
`and 4 from Iwamiya show top and
`cross-section views of physical
`monitoring device the annular light
`guide unit 7 (annotated in teal).
`
`portion 12” that is “formed in almost a
`ring shape, using a clouded or milky
`resin with a light diffusing property.”
`Id., 6:40-42, 7:4-6. The following
`annotated FIGS. 2 and 4 from Iwamiya
`show top and cross-section views of
`physical monitoring device the annular
`light guide unit 7 (annotated in teal).
`APPLE-1003, [35]:
`
`
`
`
`
`APPLE-1004, Detail of
`FIG. 2 (annotated)
`
`
`APPLE-1004, Detail of
`FIG. 2 (annotated)
`
`
`
`
`
`APPLE-1004, Detail of
`FIG. 4 (annotated)
`
`
`
`
`
`
`
`APPLE-1004, Detail of
`FIG. 4 (annotated)
`
`
`(Pet. 10-11)
`Annular light guide unit 7 changes the
`shape of the light emitted from
`individual light emitting units 6 to an
`annular shape (a second shape) and
`causes the light to irradiate an annular
`portion of tissue. Id., 11:55-12:36. As
`shown in the following annotated FIG.
`4 from Iwamiya, the light from the
`light emitting units (the orange arrows)
`irradiates “an irradiation area E” in the
`user tissue “having a ring shape”
`
`36. Annular light guide unit 7 changes
`the shape of the light emitted from
`individual light emitting units 6 to an
`annular shape (a second shape) and
`causes the light to irradiate an annular
`portion of tissue. Id., 11:55-12:36. As
`shown in the following annotated FIG.
`4 from Iwamiya, the light from the
`light emitting units (the orange arrows)
`irradiates “an irradiation area E” in the
`user tissue “having a ring shape”
`(shown in yellow). Id., 7:61-65:
`
`5
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`(shown in yellow). Id., 7:61-65;
`APPLE-1003, [36]:
`
`APPLE-1004, Detail of FIG. 4
`(annotated)
`
`
`
`
`
`
`37. As previously discussed (see [1.0],
`supra), Iwamiya’s physiological sensor
`in Figure 4 is a wristwatch. See, e.g.,
`APPLE-1004, 6:22-31. Therefore,
`annular light guide unit 7 is positioned
`between light emitting units 6 and
`tissue on the wrist, as shown in
`annotated FIG. 4 below:
`
`
`
`APPLE-1004, Detail of FIG. 4
`(annotated)
`
`
`(Pet. 12)
`As previously discussed (see [1.0],
`supra), Iwamiya’s physiological sensor
`in Figure 4 is a wristwatch. See, e.g.,
`APPLE-1004, 6:22-31. Therefore,
`annular light guide unit 7 is positioned
`between light emitting units 6 and
`tissue on the wrist, as shown in
`annotated FIG. 4 below:
`
`APPLE-1004, Detail of FIG. 4
`(annotated)
`
`
`
`
`
`
`
`APPLE-1004, Detail of FIG. 4
`(annotated)
`
`
`(Pet. 12)
`
`6
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`38. In the combination, Iwamiya
`describes that the physical monitoring
`device includes a plurality of
`photodiodes. APPLE-1004, 14:36-41
`(disclosing “plural light receiving units
`9”), 8:20-23 (stating that each unit is
`“composed of a silicon photo diode”).
`The photodiodes are configured to
`detect light after the light passes
`through tissue and output a signal
`responsive to the detected light, which
`is used to determine a physiological
`parameter of a user. See APPLE-1004,
`9:28-32 (“the observation light emitted
`from the light emitting unit 6 is
`irradiated onto the skin H and the
`scattered light thereof is received by
`the light receiving unit 9” which
`“outputs a current signal according to
`the amount of received light”), 8:61-
`9:7 (describing “convert[ing] a current
`signal output from the light receiving
`unit 9” into a “voltage signal” and then
`displaying resulting biological
`information).
`
`
`39. The following annotated FIG. 4
`from Iwamiya shows that the light
`(shown as orange arrows) emitted by
`the light emission units 6 (in green) is
`reflected by the tissue H (in pink) and
`received by the photodiodes 9 (in
`yellow).
`
`In the combination, Iwamiya describes
`that the physical monitoring device
`includes a plurality of photodiodes.
`APPLE-1004, 14:36-41 (disclosing
`“plural light receiving units 9”), 8:20-
`23 (stating that each unit is “composed
`of a silicon photo diode”). The
`photodiodes are configured to detect
`light after the light passes through
`tissue and output a signal responsive to
`the detected light, which is used to
`determine a physiological parameter of
`a user. See APPLE-1004, 9:28-32 (“the
`observation light emitted from the light
`emitting unit 6 is irradiated onto the
`skin H and the scattered light thereof is
`received by the light receiving unit 9”
`which “outputs a current signal
`according to the amount of received
`light”), 8:61-9:7 (describing
`“convert[ing] a current signal output
`from the light receiving unit 9” into a
`“voltage signal” and then displaying
`resulting biological information);
`APPLE-1003, [38].
`
`(Pet. 13-14)
`The following annotated FIG. 4 from
`Iwamiya shows that the light (shown as
`orange arrows) emitted by the light
`emission units 6 (in green) is reflected
`by the tissue H (in light pink) and
`received by the photodiodes 9 (in
`yellow). APPLE-1003, [39]:
`
`APPLE-1004, Detail of FIG. 4
`
`
`
`
`
`7
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`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`APPLE-1004, Detail of
`FIG. 4 (annotated)
`
`
`40. In the combination, Iwamiya
`describes a “light shielding frame 18”
`surrounding the photodiodes 9.
`APPLE-1004, 8:38-47, FIG. 4. As
`shown in FIG. 4 from Iwamiya, the
`light shielding frame 18 (shown in
`pink) is positioned between the
`photodiodes 9 (in yellow) and the
`tissue (in pink):
`
`(annotated)
`
`
`(Pet. 14)
`In the combination, Iwamiya describes
`a “light shielding frame 18”
`surrounding the photodiodes 9.
`APPLE-1004, 8:38-47, FIG. 4;
`APPLE-1003, [40]. As shown in FIG. 4
`from Iwamiya, the light shielding
`frame 18 (shown in pink) is positioned
`between the photodiodes 9 (in yellow)
`and the tissue (in light pink):
`
`
`
`APPLE-1004, Detail of FIG. 4
`(annotated)
`
`
`41. Also in the combination, Sarantos
`discloses a wrist-worn reflectance-
`based physiological sensor that has a
`dark-colored coating 2276 to block
`light. APPLE-1005, 5:55-58, Fig. 22.
`Saranto's also discloses that light
`source 2208 emits light through a
`window into a user’s skin, wherein the
`light is reflected from the skin and back
`to the sensor and detected by
`photodetector elements 2212. APPLE-
`1005, 17:16-25. The light travels
`through openings 2226 in the dark-
`colored coating 2276 applied to
`window 2278. Id.. Specifically,
`
`
`
`APPLE-1004, Detail of FIG. 4
`(annotated)
`
`
`(Pet. 14-15)
`Also in the combination, Sarantos
`discloses a wrist-worn reflectance-
`based physiological sensor that has a
`dark-colored coating 2276 to block
`light. APPLE- 1005, 5:55-58, Fig. 22;
`APPLE-1003, [41]. Saranto's also
`discloses that light source 2208 emits
`light through a window into a user’s
`skin, wherein the light is reflected back
`to the sensor and detected by
`photodetector elements 2212. APPLE-
`1005, 17:16-25. The light travels
`through openings 2226 in the dark-
`colored coating 2276 applied to
`window 2278. Id.; APPLE-1003, [41].
`
`8
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`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`Sarantos discloses that “in-mold label
`2276 may be black or otherwise
`rendered opaque to light to prevent
`light from entering or exiting the PPG
`sensor through the window 2278 except
`through window regions 2226.”
`APPLE-1005, 17:1-16. Sarantos
`explains that various masking
`techniques may be used to block stray
`light from reaching the photodetector
`elements 2212, including “a painted or
`silk-screened mask” applied to the
`window 2278. Id.
`
`
`42. A POSITA would have been
`motivated to employ an in-mold label
`or other black or opaque material as
`disclosed by Sarantos in the light
`shielding frame 18 of Iwamiya to serve
`the purpose indicated by the
`component’s name: shielding the
`photodiodes 9 from stray light (one of
`the dominant noise sources), and
`thereby ensuring accuracy of the
`sensor. See, e.g., APPLE-1004, 8:38-
`47, FIG. 4; APPLE- 1005, 5:55-58,
`17:1-25, FIG. 22. A POSITA would
`have understood that a dark- colored
`coating, such as that described by
`Sarantos, would have served this
`purpose by not only blocking light but
`also by limiting reflections, which
`could lead to stray light being incident
`on the photodiodes 9.
`It also would
`have been obvious to a POSITA to use
`a dark-colored coating for light
`shielding frame 18 because dark-
`colored coatings and materials were
`well-known to effectively block light.
`
`Specifically, Sarantos discloses that
`“in-mold label 2276 may be black or
`otherwise rendered opaque to light to
`prevent light from entering or exiting
`the PPG sensor through the window
`2278 except through window regions
`2226.” APPLE-1005, 17:1-16.
`Sarantos explains that various masking
`techniques may be used to block stray
`light from reaching the photodetector
`elements 2212, including “a painted or
`silk- screened mask” applied to the
`window 2278. Id.
`
`(Pet. 15-16)
`A POSITA would have been motivated
`to employ an in-mold label or other
`black or opaque material as disclosed
`by Sarantos in the light shielding frame
`18 of Iwamiya to serve the purpose
`indicated by the component’s name:
`shielding the photodiodes 9 from stray
`light, and thereby ensuring accuracy of
`the sensor. APPLE-1003, [42]; see,
`e.g., APPLE-1004, 8:38-47, FIG. 4;
`APPLE-1005, 5:55-58, 17:1-25, FIG.
`22. A POSITA would have understood
`that a dark-colored coating, such as that
`described by Sarantos, would have
`served this purpose by not only
`blocking light but also by limiting
`reflections, which could lead to stray
`light being incident on the photodiodes
`9.
`It also would have been obvious
`to a POSITA to use a dark-colored
`coating for light shielding frame 18
`because dark- colored coatings and
`materials were well-known to
`effectively block light. APPLE- 1003,
`[42]; see, e.g., APPLE-1005, 17:1-10.
`9
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`See, e.g., APPLE-1005, 17:1-10. A
`POSITA would have known that a light
`shielding frame 18 or holder portion 43
`as disclosed by Iwamiya can be of
`various proportions, and a thin surface
`is a coating. See id. Because using
`dark-colored coatings in light blocks
`was so well-known, and Iwamiya and
`Sarantos are both wrist-worn
`reflectance-based physiological
`sensors, a POSITA would have
`reasonably understood the combination
`of Iwamiya with Sarantos to be
`successful with no unexpected results.
`Id.
`
`43. As previously discussed (see [1.4]),
`in the combination, the “light shielding
`frame 18” of Iwamiya employs a dark-
`colored coating, such as that described
`by Sarantos. Iwamiya further describes
`an “an optical filter 17” that “is
`mounted on the lower side of a light
`shielding frame 18” between the
`photodiodes 9 and the tissue H.
`APPLE-1004, 8:39-42. This
`configuration is shown in the following
`detail of FIG. 4 from Iwamiya:
`
`A POSITA would have known that a
`light shielding frame 18 or holder
`portion 43 as disclosed by Iwamiya can
`be of various proportions, and a thin
`surface is a coating. See id. Because
`using dark- colored coatings in light
`blocks was so well-known, and
`Iwamiya and Sarantos are both wrist-
`worn reflectance-based physiological
`sensors, a POSITA would have
`reasonably understood the combination
`of Iwamiya with Sarantos to be
`successful with no unexpected results.
`Id.
`
`(Pet. 16-17)
`As previously discussed (see [1.4]), in
`the combination, the “light shielding
`frame 18” of Iwamiya employs a dark-
`colored coating, such as that described
`by Sarantos. Iwamiya further describes
`an “an optical filter 17” that “is
`mounted on the lower side of a light
`shielding frame 18” between the
`photodiodes 9 and the tissue H.
`APPLE-1004, 8:39-42; APPLE-1003,
`[43]. This configuration is shown in the
`following detail of FIG. 4 from
`Iwamiya:
`
`APPLE-1004, Detail of
`FIG. 4 (annotated)
`
`APPLE-1004, Detail of
`FIG. 4 (annotated)
`
`10
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`(Pet. 17)
`
`44. Iwamiya describes that the “optical
`filter 17 is configured to transmit light
`of a specific wavelength band of 900
`nm or more,” and thus is configured to
`allow at least a portion of light
`reflected from the tissue to pass
`through to the photodiodes 9. APPLE-
`1004, 8:42-44.
`
`
`In the combination, FIG. 3 of Iwamiya
`shows reflection layers 13 and 15
`(annotated in dark blue) that prevent
`light within annular light guide 7 from
`leaking outside of the annular light
`guide. APPLE-1004, 6:62-7:3, 7:41-49,
`FIG. 3:
`
`Iwamiya describes that the “optical
`filter 17 is configured to transmit light
`of a specific wavelength band of 900
`nm or more,” and thus is configured to
`allow at least a portion of light
`reflected from the tissue to pass
`through to the photodiodes 9. APPLE-
`1004, 8:42-44; APPLE-1003, [44].
`
`(Pet. 18)
`In the combination, FIG. 3 of Iwamiya
`shows reflection layers 13 and 15
`(annotated in dark blue) that prevent
`light within annular light guide 7 from
`leaking outside of the annular light
`guide. APPLE-1004, 6:62-7:3, 7:41-49,
`FIG. 3; APPLE-1003, [45]:
`
`
`
`
`
`APPLE-1004, Detail of
`FIG. 3 (annotated)
`
`45. By preventing the light from
`leaking outside of the light guide 7, the
`reflection layers 13 and 15 act as light
`blocks that prevent light emitted from
`light emitting unit 6 from directly
`reaching the photodiodes 9 without
`first reaching the tissue. APPLE-1004,
`6:62-7:3, 7:41-49, FIG. 3.
`
`APPLE-1004, Detail of
`FIG. 3 (annotated)
`
`
`(Pet. 18)
`By preventing the light from leaking
`outside of the light guide 7, the
`reflection layers 13 and 15 act as light
`blocks that prevent light emitted from
`light emitting unit 6 from reaching the
`photodiodes 9 without first reaching
`the tissue. APPLE-1004, 6:62-7:3,
`7:41-49, FIG. 3; APPLE-1003, [46].
`
`
`11
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`(Pet. 19)
`
`46. In the combination, Iwamiya
`discloses a central processing unit
`(CPU) 20 that controls the disclosed
`biological information detecting
`apparatus. APPLE- 1004, 8:61- 9:7.
`The CPU receives a current signal from
`the photodiodes of Iwamiya, processes
`it into a voltage signal, and then
`determines and displays a
`physiological parameter of the user,
`such as a heart rate, based on the
`signal. APPLE-1004, 8:61-9:7, 9:36-
`43.
`
`
`47. In the combination, Iwamiya
`discloses a sensor that detects
`“biological information,” which
`includes oxygen saturation, and
`provides the example of a “pulse
`wave” or heart rate, wherein oxygen
`saturation comprises heart rate sensing
`at different wavelengths. APPLE-1004,
`8:61-9:7.
`
`
`48. Also in the combination, Sarantos
`discloses measuring blood oxygenation
`levels. APPLE-1005, 13:40-14:22. To
`the extent not disclosed by Iwamiya, a
`POSITA would have been motivated to
`determine oxygen saturation using
`Iwamiya’s physiological sensor, based
`on the teachings of Sarantos, in order to
`expand the range of physiological
`parameters measured by Iwamiya’s
`sensor, thereby improving the
`functionality and utility of the sensor.
`
`In the combination, Iwamiya discloses
`a central processing unit (CPU) 20 that
`controls the disclosed biological
`information detecting apparatus.
`APPLE- 1004, 8:61- 9:7. The CPU
`receives a current signal from the
`photodiodes of Iwamiya, processes it
`into a voltage signal, and then
`determines and displays a
`physiological parameter of the user,
`such as a heart rate, based on the
`signal. APPLE-1004, 8:61-9:7, 9:36-
`43; APPLE-1003, [47].
`
`(Pet. 19)
`In the combination, Iwamiya discloses
`a sensor that detects “biological
`information,” which includes oxygen
`saturation, and provides the example of
`a “pulse wave” or heart rate, wherein
`oxygen saturation comprises heart rate
`sensing at different wavelengths.
`APPLE-1004, 8:61-9:7; APPLE-1003,
`[48].
`
`(Pet. 19)
`Also in the combination, Sarantos
`discloses measuring blood oxygenation
`levels. APPLE-1005, 13:40-14:22;
`APPLE-1003, [49]. To the extent not
`disclosed by Iwamiya, a POSITA
`would have been motivated to
`determine oxygen saturation using
`Iwamiya’s physiological sensor, based
`on the teachings of Sarantos, in order
`to expand the range of physiological
`parameters measured by Iwamiya’s
`sensor, thereby improving the
`
`12
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`See, e.g., APPLE- 1005, 13:40-14:22.
`A POSITA would have reasonably
`expected success in adapting
`Iwamiya’s sensor to this purpose
`because wrist-worn pulse oximetry
`sensors, such as that described in
`Sarantos, were well-known in the art.
`See, e.g., APPLE-1005, 13:40-14:22,
`FIG. 2.
`
`
`49. Venkatraman teaches a portable
`biometric monitoring device with a
`touchscreen display that can be worn
`on the wrist like a watch. APPLE-
`1006, 12:16-21, 15:19-26, 52:23-53:18.
`In particular, Venkatraman describes a
`“biometric monitoring device[] ...
`adapted to be worn or carried on the
`body of a user ... including [an] optical
`heart rate monitor” designed to “be a
`wrist-worn or arm-mounted accessory
`such as a watch or bracelet.” APPLE-
`1006, 37:29-33. Venkatraman’s
`monitoring device is “small in size so
`as to be unobtrusive for the wearer”
`and “designed to be able to be worn
`without discomfort for long periods of
`time and to not interfere with normal
`daily activity.” APPLE-1006, 14:28-
`36. Venkatraman device also includes a
`digital display with “uses capacitive
`touch detection” to display data
`acquired or stored locally on the
`wristwatch. APPLE- 1006, 53:19-
`55:51.
`
`
`functionality and utility of the sensor.
`APPLE-1003, [49]; see, e.g., APPLE-
`1005, 13:40-14:22. A POSITA would
`have reasonably expected success in
`adapting Iwamiya’s sensor to this
`purpose because wrist-worn pulse
`oximetry sensors, such as that
`described in Sarantos, were well-
`known in the art. APPLE-1003, [49];
`see, e.g., APPLE-1005, 13:40-14:22,
`FIG. 2.
`
`(Pet. 19-20)
`Venkatraman teaches a portable
`biometric monitoring device with a
`touchscreen display that can be worn
`on the wrist like a watch. APPLE-
`1006, 12:16-21, 15:19-26, 52:23-53:18.
`In particular, Venkatraman describes a
`“biometric monitoring device[] ...
`adapted to be worn or carried on the
`body of a user ... including [an] optical
`heart rate monitor” designed to “be a
`wrist-worn or arm-mounted accessory
`such as a watch or bracelet.” APPLE-
`1006, 37:29-33. Venkatraman’s
`monitoring device is “small in size so
`as to be unobtrusive for the wearer”
`and “designed to be able to be worn
`without discomfort for long periods of
`time and to not interfere with normal
`daily activity.” APPLE-1006, 14:28-
`36. Venkatraman device also includes a
`digital display with “uses capacitive
`touch detection” to display data
`acquired or stored locally on the
`wristwatch. APPLE- 1006, 53:19-
`55:51; APPLE-1003, [50].
`
`(Pet. 20-21)
`13
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`50. Venkatraman further discloses
`transmitting information wirelessly
`from its monitoring device to a
`secondary device such as a
`smartphone. APPLE- 1006, 31:1-16,
`57:20-53. Venkatraman also discloses
`that such a configuration allows the
`secondary device to act as a user
`interface for the wrist-worn wearable
`physiological device. APPLE-1006,
`57:42-44. Venkatraman further
`discloses that the secondary device
`(i.e., smartphone) can show various
`metrics regarding the user’s health, and
`receive inputs through a touch-screen
`display. APPLE-1006, 37:41-63,
`55:29-51, 57:20-58:9.
`
`
`51. See [1.0].
`
`
`52. As previously discussed (see
`[1.0]-[1.1]), in the combination,
`Iwamiya’s physiological sensor shown
`in Figure 4 is a wristwatch. APPLE-
`1004, 5:54-67, 6:22-31. Therefore,
`light emitting units 6 emit light
`proximate a user’s wrist. Id..
`
`
`Venkatraman further discloses
`transmitting information wirelessly
`from its monitoring device to a
`secondary device such as a
`smartphone. APPLE-1006, 31:1-16,
`57:20-53. Venkatraman also discloses
`that such a configuration allows the
`secondary device to act as a user
`interface for the wrist-worn wearable
`physiological device. APPLE-1006,
`57:42-44. Venkatraman further
`discloses that the secondary device
`(i.e., smartphone) can show various
`metrics regarding the user’s health, and
`receive inputs through a touch-screen
`display. APPLE-1006, 37:41-63,
`55:29-51, 57:20-58:9; APPLE-1003,
`[51].
`
`(Pet. 21)
`See [1.0].
`
`(Pet. 21)
`As previously discussed (see [1.0]-
`[1.1]), in the combination, Iwamiya’s
`physiological sensor shown in Figure 4
`is a wristwatch. APPLE-1004, 5:54-67,
`6:22-31. Therefore, light emitting units
`6 emit light proximate a user’s wrist.
`Id.; APPLE-1003, [53].
`
`(Pet. 21)
`See [1.2].
`
`(Pet. 22)
`As discussed above regarding claim
`54. As discussed above regarding claim
`element [1.6] with reference to Figures
`element [1.6] with reference to Figures
`3 and 4 of Iwamiya, reflection layers
`3 and 4 of Iwamiya, reflection layers
`13 and 15 are a light block. APPLE-
`13 and 15 are a light block. APPLE-
`1004, 6:62-7:3; see [1.6], supra. Figure
`1004, 6:62-7:3; see [1.6], supra;
`14
`
`See [1.2].
`
`53.
`
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`2 of Iwamiya shows reflection layers
`13 and 15 each having a circular shape
`as they are formed on outer surfaces of
`light guiding ring portion 11 and
`diffusion/irradiation ring portion 12,
`respectively, which together form
`annular light guide unit 7. APPLE-
`1004, 6:62-7:3, 7:41-49, FIGS. 2-4:
`
`APPLE-1003, [55]. Figure 2 of
`Iwamiya shows reflection layers 13 and
`15 each having a circular shape as they
`are formed on outer surfaces of light
`guiding ring portion 11 and
`diffusion/irradiation ring portion 12,
`respectively, which together form
`annular light guide unit 7. APPLE-
`1004, 6:62-7:3, 7:41-49, FIGS. 2-4,
`APPLE-1003, [55]:
`
`APPLE-1004, Detail of
`FIG. 2 (annotated)
`
`
`
`
`
`55. As previously discussed (see [1.3]),
`in the combination, Iwamiya describes
`that light emitted from light emitting
`units 6 travels through light diffusing
`material (annular light guide unit 7)
`and then passes into skin tissue that is
`encircled by the light block (reflection
`layers 13 and 15). APPLE-1004, 6:7-
`14, 12:3-17, FIGS. 3-4. Reflection
`layers 13 and 15, which form the light
`block, encircle a portion of patient
`tissue, shown in Iwamiya FIG. 4 as
`irradiation area E. APPLE-1004, FIGS.
`3-4.
`
`
`56. Iwamiya describes that the
`physiological monitoring device
`
`
`
`APPLE-1004, Detail of
`FIG. 2 (annotated)
`
`
`(Pet. 22)
`As previously discussed (see [1.3]), in
`the combination, Iwamiya describes
`that light emitted from light emitting
`units 6 travels through light diffusing
`material (annular light guide unit 7)
`and then passes into skin tissue that is
`encircled by the light block (reflection
`layers 13 and 15). APPLE-1004, 6:7-
`14, 12:3-17, FIGS. 3-4; APPLE-1003,
`[56]. Reflection layers 13 and 15,
`which form the light block, encircle a
`portion of patient tissue, shown in
`Iwamiya FIG. 4 as irradiation area E.
`APPLE-1004, FIGS. 3-4; APPLE-
`1003, [56].
`
`(Pet. 23)
`Iwamiya describes that the
`physiological monitoring device
`
`15
`
`MASIMO 2094
`Apple v. Masimo
`IPR2022-01291
`
`

`

`
`
`
`
`includes a plurality of photodiodes
`configured to detect light reflected by
`the encircled tissue. APPLE-1004, 6:7-
`14,