UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`META PLATFORMS, INC.,
`Petitioner
`
`v.
`
`THALES VISIONIX, INC.,
`Patent Owner
`__________________
`
`U.S. PATENT NO. 7,725,253
`
`IPR2022-01308
`__________________
`
`PATENT OWNER’S OBJECTIONS TO
`PETITIONER’S DEMONSTRATIVE EXHIBITS
`
`December 5, 2023
`
`
`
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`META PLATFORMS, INC.,
`Petitioner
`
`v.
`
`THALES VISIONIX, INC.,
`Patent Owner
`__________________
`
`U.S. PATENT NO. 7,725,253
`
`IPR2022-01308
`__________________
`
`PATENT OWNER’S OBJECTIONS TO
`PETITIONER’S DEMONSTRATIVE EXHIBITS
`
`December 5, 2023
`
`
`
`
`
`Paper No. 46
`
`Pursuant to the Order Setting Oral Argument, Paper No. 39, Patent Owner
`
`Thales Visionix, Inc. (“Patent Owner”) objects as follows to the demonstrative
`
`exhibits filed by Petitioner Meta Platforms, Inc. (“Petitioner”), Ex. 1041.
`
` Slide 26: Patent Owner objects to Petitioner’s demonstrative slide 26 as
`
`improper new argument because Petitioner’s annotated figure is not
`
`present in any of the Papers in the record, and the slide incorrectly
`
`represents this new annotated figure as a figure provided in the Petition
`
`and referred to by Patent Owner in Patent Owner’s Response.
`
` Slides 51-52: Patent Owner objects to Petitioner’s demonstrative slides
`
`51-52 as improper new argument because Petitioner did not discuss LED
`
`selection as applied to claims 12-13 of the ’632 patent in any Papers; the
`
`discussion of LED selection in the cited Papers applies to claim 11.
`
` Slide 54: Patent Owner objects to Petitioner’s demonstrative slide 54 as
`
`improper new evidence and argument because Petitioner did not cite to the
`
`“i” entry in Table 1 in any of the Papers in connection with claim 2 of the
`
`’632 patent, and did not advance any argument about two “Table 1” and
`
`“Table 4” software modules.
`
` Slide 56: Patent Owner objects to Petitioner’s demonstrative slide 56 as
`
`improper new evidence because the cited portion of the patent was not
`
`referenced in any Papers.
`
`1
`
`
`
` Slides 62-63: Patent Owner objects to Petitioner’s demonstrative slides
`
`62-63 as improper new argument, because Petitioner did not rely on a
`
`Paper No. 46
`
`“HiBall Trigger” in any of the Papers.
`
`Copies of the objected-to slides are attached.
`
`Date: December 5, 2023
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ D. Shayon Ghosh
`Meredith Martin Addy (Reg. No. 37,883)
`ADDYHART P.C.
`10 Glenlake Parkway
`Suite 130
`Atlanta, GA 30328
`312.320.4200
`312.264.2547 (fax)
`meredith@addyhart.com
`
`Lead Counsel for Patent Owner Thales
`Visionix Inc.
`
`Robert P. Hart (Reg. No. 35,184)
`Gregory B. Gulliver (Reg. No. 44,138)
`Brandon C. Helms (Reg. No. 61,742)
`ADDYHART P.C.
`401 N. Michigan Avenue
`Suite 1200-1
`Chicago, IL 60611
`Thales-Meta-IPRs@addyhart.com
`
`Backup Counsel for Patent Owner Thales
`Visionix Inc.
`
`
`David M. Krinsky (Reg. No. 72,339)
`WILLIAMS & CONNOLLY LLP
`680 Maine Avenue SW
`Washington, DC 20024
`
`2
`
`
`
`Paper No. 46
`
`T: (202) 434-5000
`F: (202) 434-5029
`dkrinsky@wc.com
`
`Lead Counsel for Real-Party-in-Interest
`Gentex Corp. and Backup Counsel for Patent
`Owner Thales Visionix Inc.
`
`Adam D. Harber (pro hac vice)
`Melissa B. Collins (pro hac vice)
`D. Shayon Ghosh (Reg. No. 75,865)
`Arthur J. Argall III (Reg. No. 73,005)
`WILLIAMS & CONNOLLY LLP
`680 Maine Avenue SW
`Washington, DC 20024
`T: (202) 434-5000
`F: (202) 434-5029
`Gentex-IPR@wc.com
`
`Backup Counsel for Real-Party-in-Interest
`Gentex Corp. and Patent Owner Thales
`Visionix Inc.
`
`
`3
`
`
`
`
`
`
`
`The Petition Identified Two Separate “Subsystems”
`
`Paper 29 (Patent Owner's Response) at 48; Paper 01 (Petition) at 59; Ex. 1010 (Horton) Figure 3
`Grounds IV (Horton) and V (Horton + Welch 1997)
`See also -01304 Ground III (Horton), Claim 1
`
`K I R K L A N D & E L L I S
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE 26
`
`
`
`Claims 12-13: LED Selection Related To Relative Geometric
`Configuration And Location Of Sensing Elements In The HiBall
`
`Ex. 1007 (Welch-2001) at 13 (left) and 6-7 (right); -01304, Paper 34 (Petitioner’s
`Reply) at 12 (section heading) and 13-14 (“The selection of which LED to flash”)
`Ground I: Welch-2001 + Welch-1997
`K I R K L A N D & E L L I S
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE 51
`
`
`
`Claims 12-13: LED Selection Related To Relative Geometric
`Configuration And Location Of Sensing Elements In The HiBall
`
`Ex. 1007 (Welch-2001) at 13; -01304, Paper 34 (Petitioner’s Reply) at
`12 (section heading) and 13-14 (“The selection of which LED to flash”)
`K I R K L A N D & E L L I S
`
`Ground I: Welch-2001 + Welch-1997
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE 52
`
`
`
`Claim 2: Horton’s Code Is Comprised Of Two Inextricably Linked
`Software Modules That Are Each Coupled To Sensors
`
`Table 4 Module That Reads Accelerometers
`Calls Table 1 Module That Sets Number Of Accelerometers
`
`Ex. 1010 (Horton) at cols. 11 and 12; -01304, Paper 34 (Petitioner’s Reply) at 23 (“Table 1”)
`Ground III: Horton
`K I R K L A N D & E L L I S
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE 54
`
`
`
`Claim 6: Directed To Iterative Refinement Of Configuration
`Information
`
`’632
`
`Ex. 1001 (’632 Patent) at 24:34-40
`K I R K L A N D & E L L I S
`
`Ground III: Horton
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE 56
`
`
`
`Claim 30: Trigger For HiBall Sensor Is Tied To The LED Trigger,
`Which Is “Related To An Expected Sensor Measurement”
`
`’632
`
`Ex. 1001 (’632 Patent) at cl. 30; -01305, Paper 2 (Petition) at 19 (“Once the view and LED are
`selected, the CIB flashes the selected LED and the HiBall takes a single measurement.”)
`Ground I: Welch-2001 + Welch-1997
`K I R K L A N D & E L L I S
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE 62
`
`
`
`Claim 30: LED Selection Is Based On Predicted Pose, and HiBall
`Trigger Is Directly Connected To LED Selection Trigger
`
`Ex. 1007 (Welch-2001) at 13 and Fig. 6; -01305, Paper 2 (Petition) at 19 (“Once the view and
`LED are selected, the CIB flashes the selected LED and the HiBall takes a single measurement.”)
`Ground I: Welch-2001 + Welch-1997
`K I R K L A N D & E L L I S
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE 63
`
`
`
`Paper No. 46
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned hereby certifies that a true
`
`and correct copy of the foregoing was served on December 5, 2023, by delivering a
`
`copy via electronic mail on the following counsel of record for the Petitioner:
`
`Meta-Thales-IPR@kirkland.com
`
`Date: December 5, 2023
`
`/s/ D. Shayon Ghosh
`D. Shayon Ghosh
`Reg. No. 75,865
`
`4
`
`
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