`Apple Inc.
`v.
`Zentian Limited
`Patent 7,979,277
`
`Patent Owner’s Demonstratives
`
`Presented March 12, 2024
`
`1
`
`
`
`Argument Roadmap
`
`v Petitioner’s theory requires Brown’s pipelining
`v Brown’s pipelining cannot be combined with feedback-
`based pruning
`v Petitioner’s theory requires Jiang’s pruning
`v Jiang’s pruning is feedback-based pruning
`v Petitioner’s new modification is untimely and refuted
`
`2
`
`
`
`Argument Roadmap
`
`v Petitioner’s theory requires Brown’s pipelining
`v Brown’s pipelining cannot be combined with feedback-
`based pruning
`v Petitioner’s theory requires Jiang’s pruning
`v Jiang’s pruning is feedback-based pruning
`v Petitioner’s new modification is untimely and refuted
`
`3
`
`
`
`Petitioner’s theory requires Brown’s pipelining
`
`Sur-reply at 4, Ex. 2016 at 5:15-20
`
`4
`
`
`
`Petitioner’s theory requires Brown’s pipelining
`
`Search stage for frame N and calculation stage for frame N+1 must
`happen “at the same time,” without delay
`
`Sur-reply at 4, Ex. 1003 ¶ 209
`
`5
`
`
`
`Petitioner’s theory requires Brown’s pipelining
`
`Each stage of recognition must be “synchronized with the frame
`generation rate,” i.e., real time
`
`Sur-reply at 4-5, Ex. 2016 at 6:1-8, 6:24-5:2, Ex. 1003 ¶¶ 207, 209
`
`6
`
`
`
`Argument Roadmap
`
`v Petitioner’s theory requires Brown’s pipelining
`v Brown’s pipelining cannot be combined with feedback-
`based pruning
`v Petitioner’s theory requires Jiang’s pruning
`v Jiang’s pruning is feedback-based pruning
`v Petitioner’s new modification is untimely and refuted
`
`7
`
`
`
`Brown’s pipelining cannot be combined
`with feedback-based pruning
`
`Undisputed: Brown’s pipelining cannot be combined with feedback-
`based pruning
`
`Ravishankar, Ex. 1012, at 91
`
`Krishna, Ex. 2018, at 69
`
`Sur-reply at 9-11, Ex. 2020 ¶¶ 52-56
`
`8
`
`
`
`Brown’s pipelining cannot be combined
`with feedback-based pruning
`
`Petitioner’s new “one frame delay” pipeline is irrelevant
`
`Pet. Reply at 15
`
`Schmandt Depo II, Ex. 2021 at 55:1-9
`
`Sur-reply at 9-11, Ex. 2020 ¶¶ 52-56
`
`9
`
`
`
`Argument Roadmap
`
`v Petitioner’s theory requires Brown’s pipelining
`v Brown’s pipelining cannot be combined with feedback-
`based pruning
`v Petitioner’s theory requires Jiang’s pruning
`v Jiang’s pruning is feedback-based pruning
`v Petitioner’s new modification is untimely and refuted
`
`10
`
`
`
`Jiang’s pruning is “part of the combination”
`
`Schmandt, Ex. 1003, ¶ 194
`
`Schmandt, Ex. 1003, ¶ 213
`
`Schmandt, Ex. 2016 at 15:4-9
`
`Sur-reply at 11-18
`
`11
`
`
`
`Jiang’s pruning is necessary to the combination
`
`Jiang, Ex. 1004, 2:16-27
`
`Sur-reply at 11-18; Ex. 2016 at 6:1-8, 6:24-5:2; Ex. 2020 ¶ 40
`
`12
`
`
`
`Argument Roadmap
`
`v Petitioner’s theory requires Brown’s pipelining
`v Brown’s pipelining cannot be combined with feedback-
`based pruning
`v Petitioner’s theory requires Jiang’s pruning
`v Jiang’s pruning is feedback-based pruning
`v Petitioner’s new modification is untimely and refuted
`
`13
`
`
`
`Jiang’s pruning is feedback-based pruning
`
`Sur-reply at 18-26; Ex. 1050 at 3; Ex. 2020 ¶¶ 57-71
`
`14
`
`
`
`Jiang’s pruning is feedback-based pruning
`
`Sur-reply at 18-26; Ex. 2020 ¶¶ 61-63; Ex. 1005 at 8:16-20, 8:44-51, 8:52-64, 8:25-43
`
`15
`
`
`
`Jiang’s pruning is feedback-based pruning
`
`Sur-reply at 18-26; Ex. 2018 at 40-42
`
`16
`
`
`
`Jiang’s pruning is feedback-based pruning
`
`Krishna, Ex. 2018, at 42
`
`Mathew I, Ex. 1050, at 11
`
`Sur-reply at 18-26; Ex. 1050 at 11; Ex. 2018 at 42, Ex. 2020 ¶ 68
`
`17
`
`
`
`Argument Roadmap
`
`v Petitioner’s theory requires Brown’s pipelining
`v Brown’s pipelining cannot be combined with feedback-
`based pruning
`v Petitioner’s theory requires Jiang’s pruning
`v Jiang’s pruning is feedback-based pruning
`v Petitioner’s new modification is untimely and refuted
`
`18
`
`
`
`Petitioner’s Reply modification is untimely and refuted
`
`“Rather than explaining how its original petition was
`correct, Continental’s subsequent arguments amount to an
`entirely new theory of prima facie obviousness absent from
`the petition. Shifting arguments in this fashion is foreclosed
`by statute, our precedent, and Board guidelines.”
`
`Wasica v. Con’tl Auto Sys., 853 F.3d 1272, 1286-87 (Fed. Cir. 2017)
`
`Sur-reply at 26-31
`
`19
`
`
`
`Petitioner’s Reply modification is untimely and refuted
`
`Sur-reply at 26-31; Ex. 2021, at 43:3-7, 41:2-6, 38:11-16
`
`20
`
`
`
`Petitioner’s Reply modification is untimely and refuted
`
`Sur-reply at 26-31; Ex. 2018 at 42, 69, 108, 142-145
`
`21
`
`
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