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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`VERANCE CORP.,
`
`Petitioner,
`v.
`MZ AUDIO SCIENCES, LLC,
`
`Patent Owner.
`
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`
`
`CASE: IPR2022-01544
`Patent No. 7,289,961 B2
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`PETITIONER’S DEMONSTRATIVES FOR ORAL ARGUMENT
`
`
`
`Verance Corp. v. MZ Audio Sciences, LLC
`
`IPR2022-01544
`U.S. Patent No. 7,289,961 B2
`
`Petitioner Verance’s Demonstratives
`
`Oral Hearing
`January 25, 2024
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`
`
`Grounds
`Ground
`
`1
`
`2
`
`3
`
`Basis
`
`§ 103
`
`§ 103
`
`§ 103
`
`Reference(s)
`
`Srinivasan, Cabot and Kudumakis
`
`Challenged
`Claims
`1-10
`
`Srinivasan, Cabot, Kudumakis and Hobson
`
`2-3, 5, 7-8, 10
`
`Kudumakis, Tilki and Cabot
`
`1-10
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`
`
`Srinivasan-Cabot-Kudumakis Combination
`
`Claims 6 and 9 are independent device claims
`
`Ex. 1001, ’961 Patent, cl. 9
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`3
`
`
`
`Srinivasan-Cabot-Kudumakis Combination
`
`Srinivasan, FIGURE 2
`
`Petition at 33;
`Reply at 4
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`4
`
`
`
`Srinivasan-Cabot-Kudumakis Combination
`
`Petition at 12;
`Srinivasan at 7:64-8:5; Reply at 3
`
`Srinivasan at 11:33-50;
`Petition at 34-35; Reply at 4
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`
`
`Srinivasan-Cabot-Kudumakis Combination
`
`Cabot at Abstract;
`Petition at 12; Reply at 3
`
`Cabot, FIGURE 2b
`Petition at 17
`
`Cabot at Introduction;
`Petition at 15-16;
`Reply at 6-7
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`6
`
`
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`Srinivasan-Cabot-Kudumakis Combination
`
`Cabot’s Testing Procedure:
`• Pristine laboratory conditions
`• Headphones to block other noises
`• Listening to both original and modified signals
`• Prior training to familiarize with differences
`• Unlimited switching back-and-forth
`• No signals other than fundamental and 3rd harmonic
`• Prior to training, subject “refused to believe that
`there was a difference.”
`
`Reply at 6
`Cabot at 570-571;
`Petition at 15-18;
`
`Cabot at 570;
`Petition at 22; Reply at 7
`
`Cabot at Conclusion;
`Petition at 12, 23; Reply at 7
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
`
`
`
`Srinivasan-Cabot-Kudumakis Combination
`
`Dr. Scordilis (Petitioner’s Expert) Deposition Transcript, Ex. 2011, 18:1-19;
`Reply at 7
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`
`
`Srinivasan-Cabot-Kudumakis Combination
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Petition at 23;
`Lipshitz, Ex. 1031, at 1031, 584;
`Risset, Ex. 1028, at 114
`Dr. Scordilis, Ex. 1003 at ¶¶ 122, 125, 151;
`Reply at 7-8
`
`9
`
`
`
`Srinivasan-Cabot-Kudumakis Combination
`
`Petition at 19
`
`(1)
`
`(2)
`
`(3)
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`Reply at 12
`
`10
`
`
`
`Srinivasan-Cabot-Kudumakis Combination
`
`(1)
`
`(2)
`
`(3)
`
`Reply at 12
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
`
`
`
`Srinivasan-Cabot-Kudumakis Combination
`
`Combination’s improved operation over Srinivasan:
`• Maintain Low Perceptibility
`Improved Security and Robustness
`•
`• Location of watermark changes throughout signal
`• Lower frequencies less susceptible to common signal distortions and malicious
`attacks – Low pass filtering
`• Enabling Use Narrowband Voice Applications
`• Telephony and videoconferencing
`
`Petition at 27;
`Scordilis at ¶¶ 119-132;
`Cox, Exhibit 1020;
`Wu, Exhibit 1021;
`Cheng, Exhibit 1023
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`12
`
`
`
`Kudumakis-Tilki-Cabot Combination
`Tilki’s Differential Phase Quantization Encoding:
`
`Petition at 53;
`Tilki at 331
`
`Tilki at 332-333 (Encoding);
`Petition at 54; Scordilis at ¶¶ 94-95
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`13
`
`
`
`Kudumakis-Tilki-Cabot Combination
`Tilki’s Simulation Example:
`
`Tilki at 332, Simulation Result;
`Petition at 54-55
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`14
`
`Tilki’s Figure 1;
`Petition at 56
`
`
`
`Kudumakis-Tilki-Cabot Combination
`
`Combination’s improved operation:
`• Fast and simplified encoding (Tilki)
`Improved Security and Robustness
`•
`• Location of watermark changes throughout signal (Kudumakis, Cabot)
`• Lower frequencies less susceptible to common signal distortions and malicious
`attacks (Cabot, Kudumakis)
`• Low perceptibility (Cabot, Tilki)
`• Maintaining sufficient data rate for watermarking applications
`• Use of multiple fundamental frequencies (claim 2)
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`15
`
`Petition at 27, 68
`Scordilis at ¶¶ 188-206, 219-220;
`Reply at 18-20
`
`
`
`Kudumakis-Tilki-Cabot Combination
`
`Changing the phase of harmonic with respect to fundamental
`• Select third harmonic and fundamental (Cabot)
`
`• Selected frequency components can be further apart
`
`• POSA: BS in EE, plus 2 years of experience
`
`• Kudumakis Figure 1 – 3:11-30, 4:21-25
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`16
`
`Reply 20-22, 18-19
`Petition at 7, 64;
`Scordilis at ¶¶ 188-206, 219-220;
`Reply at 18-20
`
`
`
`Ground 2 - Hobson
`
`Claim 2 of ’961 patent
`
`• Embedding watermarks in digital images by changing phase of frequency components
`• Watermarks embedded in multiple portions of the image to provide redundancy
`Petition at 51;
`Hobson at 3:49-57;
`Scordilis at ¶¶ 183-185
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`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`17
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`
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`Hobson is Analogous Art
`
`’961 patent at 8:65-9:1
`Reply at 16
`
`’961 patent at 1:25-55
`Reply at 13-14
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`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`18
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`
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`Hobson is Analogous Art
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`Reply at 14-15
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`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`19
`
`
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`Robustness-Perceptibility-Data Capacity Tradeoffs
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`• Well known attributes of watermarking that can be traded off
`
`Scordilis at ¶¶ 105-115
`
`Scordilis at ¶ 116
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`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`20
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`
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`’961 Patent’s Claims Lack Specific Recitations
`
`• Claims do not recite a particular audibility requirement
`
`• Some embodiments of ’961 patent produce audible artifacts
`
`Reply at 8-9, 22-23
`’961 patent at 7:53-56
`
`• Claims do not recite a specific bitrate requirement …
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`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`21
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`Reply at 10
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`
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`Srinivasan-Cabot-Kudumakis Combination
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`Kudumakis at 6:1-2
`Petition at 20; Reply at 12; Scordilis at ¶ 88
`
`Kudumakis at 4:26-31
`Petition at 27; Reply at 12; Scordilis at ¶¶ 88, 134
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`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`22
`
`Kudumakis at 2:26-31
`Petition at 19; Reply at 12;
`Scordilis at ¶¶ 86, 127
`
`
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`Srinivasan-Cabot-Kudumakis Combination
`
`Reply at 26-27
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`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`23
`
`
`
`Testimony of Dr. Scordilis
`
`Reply at 26
`Dr. Scordilis Deposition Transcript, Ex. 2011, 14:17-21
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`24
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`
`
`Testimony of Dr. Scordilis
`
`Reply at 26-27
`Dr. Scordilis Deposition Transcript, Ex. 2011, 17:13-18:9
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`25
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`
`
`Testimony of Dr. Scordilis
`
`Dr. Scordilis Deposition Transcript,
`Ex. 2011, 74:3-20
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`26
`
`
`
`Testimony of Dr. Scordilis
`
`Reply at 25-26
`Dr. Scordilis Deposition Transcript, Ex. 2011, 74:21-75:10
`
`PETITIONER’S DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`27
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a true copy of the foregoing
`
`PETITIONER’S DEMONSTRATIVES FOR ORAL ARGUMENT was served in
`
`its entirety this 22nd day of January, 2024 by electronic mail on the Patent Owner
`
`via its attorneys of record:
`
`Sarah E. Spires, Steven W. Hartsell, Ryan A. Hargrave
`SKIERMONT DERBY LLP
`MZAudioSciences_SDTeam@skiermontderby.com
`
`
`Dated: January 22, 2024
`
`
`Perkins Coie LLP
`1201 Third Avenue Suite 4900
`Seattle, WA 98101-3099
`
`
`Respectfully submitted,
`
` /Meghan Bright/
`Meghan Bright
`Patent Paralegal
`
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`-1-
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