`U.S. Patent No. 10,971,140
`
`Oral Argument, March 11, 2024
`
`Apple Inc. v. Zentian Limited
`Case No. IPR2023-00037
`
`Petitioner’s Demonstrative Exhibits – Not Evidence
`
`Petitioner’s DX-1
`
`IPR2023-00037
`Apple EX1036 Page 1
`
`
`
`Claim 1 and Proposed Ground I
`
`- Ground 1: Claims 1-3, 5, and 7-8
`Jiang (Ex. 1004) in view of Chen (Ex. 1005)
`-
`
` Claim 1:
`
`Pet. (Paper 1), 6, 12-44, 66
`
`Petitioner’s DX-2
`
`
`
`Petition’s Combination of Jiang-Chen
`
`- Petition Mapped:
`
`Pet. 17-18; Pet Reply, 1
`
`Pet. 30; Pet Reply, 1-2
`
`Pet. 24; Pet Reply, 1
`
`Jiang, Fig. 6; Pet. 41
`
`Chen, Fig. 4
`
`Institution Decision (Paper 10), 18; Schmandt Dec. (Ex. 1003), ¶¶ 76-77, 83; Pet. Reply (Paper 21), 16, 26-27
`
`Petitioner’s DX-3
`
`
`
`Zentian’s Arguments: Claims 1(d)-1(e)
`
`- Zentian Argues:
`- “No one processor in one cluster can directly or
`adjacently access all of the data stored across the four
`memories 104(a)-(d).”
`POR, 33-34
`
`- Apple’s Response:
`- Not Required (in the claim or the combination)
`- No need in the combination for a processor to be able to
`access all data from all cluster memories
`- Zentian Is Requiring Bodily Incorporation
`
`Pet. Reply, 2-3
`
`Patent Owner Response (POR) (Paper 19), 33-34; Pet. Reply, 26-27
`
`Petitioner’s DX-4
`
`
`
`Zentian’s Sur-Reply Argument:
`Claims 1(d)-1(e)
`
`PO Sur-Reply,1-2
`
`PO Sur-Reply (Paper 27), 2
`
`Petitioner’s DX-5
`
`
`
`Schmandt’s Opinions Regarding the
`Results of Jiang’s Tree Search
`
`Schmandt Depo. Tr. (Ex. 2017), 101:4-23
`
`PO Sur-Reply, 2
`
`Schmandt Depo. Tr., 102:17–103:3
`
`Petitioner’s DX-6
`
`
`
`Motivations to Combine
`
`Clusters
`enable
`expansion
`
`Schmandt Dec., ¶¶ 59,
`71-72, citing Hon, 24-25
`
`Pet. Reply, 12, citing Chen,
`10:14-35; Schmandt Dec.,
`¶¶ 73-74
`
`Commercially
`available
`processors
`
`Relaxed Pruning
`Threshold
`Enabled
`
`Increased
`Processing Power
`for a Given Cost
`
`Known Technique
`Improving Similar
`Devices
`
`Fewer recognition
`errors at lower
`financial cost
`
`Schmandt Dec., ¶¶ 67, 74, 76,
`citing Jiang, 2:19-46, 11:16-24
`
`Pet. Reply, 12, citing
`Chen, 11:33-41;
`Schmandt Dec., ¶ 67
`
`“Equally applicable
`to any type of
`parallel processing
`computer system”
`
`Schmandt Dec., ¶¶ 59, 67, 71-72, 74, 76, 83; Pet., 17-19, 24-25; Pet. Reply, 12-14, 19-22
`
`Petitioner’s DX-7
`
`
`
`Chen’s Memory Access
`
`- Zentian Argues:
`- Extensive communication
`between computational
`components required
`
`POR, 14
`
`- Petition Mapped:
`- Jiang’s algorithm replicated
`across each processor
`Pet. Reply, 1
`
`- No communication between
`some of Chen’s processors and
`memories
`
`POR, 16
`
`- Switching nodes 106a-d allow
`“direct and symmetrical
`access” by all processors of
`each cluster to shared
`memory
`Pet. Reply, 17, 27
`
`Jiang, Fig. 6; Pet. 41
`
`- Adjacent and non-adjacent
`clusters are communicatively
`connected
`Pet. Reply, 17
`
`Institution Decision (Paper 10), 8; Schmandt Dec., ¶¶ 76-77, 83; POR, 5; Pet.
`Reply, 5-6, 9, citing Anderson Depo. Tr. (Ex. 1035), 9:20-10:12, 11:12-17
`
`Petitioner’s DX-8
`
`
`
`Zentian’s Unclaimed and Undescribed
`Implementation Details
`- Avoiding Memory Conflicts
`
`NO DISCLOSURE
`
`NO DISCLOSURE
`
`NO DISCLOSURE
`
`NO DISCLOSURE
`
`- Task Sharing
`
`- Resolving Bottlenecks
`
`- Messaging Strategy
`
`- Bandwidth and Latency Issues
`
`Single Sentence
`of Disclosure:
`
`‘140 Patent, 4:1-6
`
`Pet. Reply, 4
`
`Petitioner’s DX-9
`
`
`
`Zentian’s Alleged Reprogramming Effort
`
`- Chen’s Shared Memory Model
`
`Pet. Reply, 26-27
`
`Chen, Fig. 4 (Annotated)
`
`Pet., 15-17, 22-25; Pet. Reply, 25-27
`
`Petitioner’s DX-10
`
`
`
`Level of Skill of a POSITA
`
`- The Parties Agree:
`
`Institution Decision, 8; Pet., 5; Pet. Reply, 8
`
`Petitioner’s DX-11
`
`
`
`Level of Skill of a POSITA – No Disputes
`
`- Zentian DOES NOT:
`- Dispute the Level of Skill
`
`- Provide an Alternative Level of Skill
`
`Anderson Depo. Tr., 9:10-12
`
`POR, 6
`
`- Argue that Mr. Schmandt Does Not Meet the Level of Skill
`
`Anderson Depo. Tr., 12:1-6
`
`Institution Decision, 8; POR, 6; Pet. Reply, 8-9, citing Anderson Depo. Tr. (Ex. 1035), 9:20-10:12, 11:12-17
`
`Petitioner’s DX-12
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
