Inter Partes Review
`U.S. Patent No. 11,016,564
`
`Oral Argument, April 24, 2024
`
`Apple Inc. v. Chian Chiu Li
`Case No. IPR2023-00560
`
`Petitioner’s Demonstrative Exhibits – Not Evidence
`
`Petitioner’s DX-1
`
`
`U.S. Patent No. 11,016,564
`
`Oral Argument, April 24, 2024
`
`Apple Inc. v. Chian Chiu Li
`Case No. IPR2023-00560
`
`Petitioner’s Demonstrative Exhibits – Not Evidence
`
`Petitioner’s DX-1
`
`
`
`Grounds
`1. Ground 1: Claims 1–5, 8, 9, 11, 12, 14–16, 18, and 20
`} Ryu (Ex. 1004) in view of Hodge (Ex. 1005)
`
`2. Ground 2: Claims 1, 6, 8, 10, 14, and 19
`▸ Ryu in view of Hodge, in further view of Stallings (Ex. 1006)
`
`Petition, at 4–5
`
`Petitioner’s DX-2
`
`
`
`Key Limitations
`’564 Patent, Claim 1
`} 1. A method for presenting information at an electronic device, comprising:
` 1) detecting an act made by a user involving physical contact with the electronic device or physical
`movement of the electronic device when a display of the electronic device has an idle screen or a screen
`in standby mode, inactive, mode, or screen-saver mode;
` 2) performing gaze detection only after detecting the act;
` 3) ascertaining whether the user looks at a direction toward the electronic device;
` 4) determining whether the user is recognized via a recognition mechanism; and
` 5) presenting a plurality of content items when the user is recognized via the recognition mechanism
`and it is ascertained that the user looks at a direction toward the electronic device.
`
`’564 Patent, at Claim 1 (Ex. 1001) (annotated)
`
`Petitioner’s DX-3
`
`
`
`Key Limitations
`’564 Patent, Claim 8
`} 8. A method for presenting information at an electronic device, comprising:
` 1) monitoring the electronic device or physical movement of the electronic device to sense an act
`made by a user when a display of the electronic device has an idle screen or a screen in standby mode,
`inactive mode, or screen-saver mode;
` 2) performing gaze detection only after sensing the act;
` 3) determining whether the user is recognized via a recognition mechanism;
` 4) detecting whether the user looks at a direction toward the electronic device; and
` 5) presenting a plurality of content items when the user is recognized via the recognition mechanism
`and it is detected that the user looks at a direction toward the electronic device.
`
`’564 Patent, at Claim 8 (Ex. 1001) (annotated)
`
`Petitioner’s DX-4
`
`
`
`Key Limitations
`’564 Patent, Claim 14
`} 14. An electronic device comprising: a processor, a recognition mechanism, and a memory or memory
`unit coupled to the processor, the processor operable when executing certain instructions to:
` 1) detect an act made by a user involving physical contact with the electronic device or physical
`movement of the electronic device when a display of the electronic device has an idle screen or a screen
`in standby mode, inactive mode, or screen-saver mode;
` 2) perform gaze detection only after detecting the act;
` 3) determine whether the user looks at a direction toward the electronic device;
` 4) determine whether the user is recognized via the recognition mechanism; and
` 5) present a plurality of content items when it is determined that the user looks at a direction toward
`the electronic device and the user is recognized via the recognition mechanism.
`
`’564 Patent, at Claim 14 (Ex. 1001) (annotated)
`
`Petitioner’s DX-5
`
`
`
`Apple’s Combination of Ryu and Hodge
`} Ryu teaches every limitation of the independent claims except for
`determining whether the user is recognized, which Hodge teaches.
`
`Ryu (Ex. 1004), at Fig. 8
`
`Hodge (Ex. 1005), at [0116] (annotated)
`
`Petition, at 7, 9, 13, 15–33, 41–43, 44–51
`
`Petitioner’s DX-6
`
`
`
`Motivation to Combine Ryu and Hodge
`
`} The combination would have improved the security and privacy of Ryu’s
`device.
`
`} The functionality of Ryu would have been improved by making the device
`able to distinguish between authorized and unauthorized users.
`
`} These modifications only involved simple programming techniques because
`both Ryu and Hodge use similar camera capture systems for gaze detection.
`
`Petition, at 9–15, 28, 50; Bederson Dec. (Ex. 1003), at ¶¶ 50–53, 65–67
`
`Petitioner’s DX-7
`
`
`
`Sole Dispute Relates to the “Only After” Limitation
`
`} PO argues the Challenged Claims must be incapable of performing gaze
`detection in any scenario except touching or physically moving the device.
`
`} PO’s support is “another exemplary embodiment” of Ryu that includes sensor
`1102, which may include both a proximity and motion sensor.
`
`Patent Owner Response, at 2–5, 6–8; Petitioner Reply, at 2–3
`
`Petitioner’s DX-8
`
`
`
`Apple Did Not Rely on Ryu’s Figure 11 Embodiment
`
`} Apple relied on Ryu’s Figure 1
`embodiment and sensor 101.
`
`} Sensor 101 does not include a
`proximity sensor.
`
`} Apple never mapped sensor 1102.
`
`Petition, at 17–20; Institution Decision, at 7–8; Petitioner’s Reply, at 9–10
`
`Petitioner’s DX-9
`
`Petition, at 17 (annotated)
`
`
`
`Ryu’s Fig. 11 Embodiment is a Different Embodiment
`
`} Sensor 1102 is part of Figure 11.
`
`} Figure 11 is “another exemplary
`embodiment.”
`
`Ryu (Ex. 1004), at 21:37–38 (annotated)
`
`Institution Decision, at 7–8; Petitioner’s Reply, at 9–10
`
`Petitioner’s DX-10
`
`
`
`Ryu’s Fig. 11 Embodiment is a Different Embodiment
`
`} Sensor 1102 “may include a
`proximity sensor and a motion
`sensor.”
`
`} This is the only embodiment where
`Ryu discloses proximity detection
`with no touch.
`
`} PO submits no evidence that
`sensors 101 and 1102 operate
`similarly.
`
`Ryu (Ex. 1004), at 22:30–33 (annotated)
`
`Institution Decision, at 7–8; PO Response, at 6–7; Petitioner’s Reply, at 9–10
`
`Petitioner’s DX-11
`
`
`
`Separately, PO Reads the Claims Too Narrowly
`
`} None of the ’564 Patent’s gaze detection scenarios preclude the device from
`also performing proximity detection.
`
`} Consistent with the ’564 Patent’s express teachings, the “only after” limitation
`does not preclude the electronic device from also performing proximity
`detections.
`
`} There is no dispute that Ryu, as modified in view of Hodge as proposed by Apple,
`teaches the “only after” limitation when properly construed.
`
`PO Response, at 2–5; Petitioner’s Reply, at 2–6, 6–8, 8–11
`
`Petitioner’s DX-12
`
`
`
`The ’564 Patent’s Four Gaze Detection Scenarios
`} The ’564 Patent teaches four gaze detection scenarios:
`
`} Scenario #1 – Gaze detection is performed continuously (’564 Patent (Ex. 1001), 4:29–6:30)
`
`} Scenario #2 – Gaze detection is performed after a user approaches the device (proximity event)
`(Id., at 6:31–35)
`
`} Scenario #3 – Gaze detection is deactivated when sensor 24 detects the device’s position is
`unstable (Id., at 6:43–46)
`
`} Scenario #4 – Gaze detection is performed when sensor 24 detects the device is shaken or
`physically moved in a number of ways (Id., at 6:58–7:14)
`
`Petitioner Reply, at 3
`
`Petitioner’s DX-13
`
`
`
`The ’564 Patent Expressly Teaches its Device Can Perform any
`of the Four Gaze Detection Scenarios Described
`} “[P]hysical movement of a user may be considered as a
`user input to control the device[.]” ’564 Patent (Ex. 1001),
`at 6:35–36.
`
`} “Besides shaking . . . tapping, scribbling or sliding on a
`touch-sensitive screen, or tapping on [a] certain area of
`the device . . . may also be incorporated as a first step[.]”
`Id. at 7:13–20; see also id. at 6:58–59.
`
`} Which of these applies “may depend on a specific app or
`program to specify what kind of physical move may be
`taken as an input for the device. If there is more than one
`option, a user may select [the] method which may seem
`more convenient and effective.” Id. at 7:20–24.
`
`’564 Patent (Ex. 1001), at Fig. 1
`
`Petitioner Reply, at 4; Supplemental Bederson Dec. (Ex. 1010), ¶¶ 4–7.
`
`Petitioner’s DX-14
`
`
`
`Nothing in the Claims Precludes the Capability to Perform
`Proximity Detections
`} Nothing in the Challenged Claims excludes the capability to also perform
`proximity detections.
`
`} The “only after” limitation places a temporal requirement on the claims
`regarding when a certain sequence of events must take place.
`
`} See Boesen v. Garmin Int’l, Inc., 455 F. App’x 974, 977 (Fed. Cir. 2011)
`} “Both independent claims 1 and 10 are open ended ‘comprising’ claims . . . The
`district court correctly explained that as long as the [accused] navigation system
`can—and does—perform the claimed input method, it is of no consequence that it
`can also perform other input methods.”
`
`Petitioner Reply, at 6–8.
`
`Petitioner’s DX-15
`
`
`
`There Is No Dispute That Ryu In View Of Hodge Renders
`Obvious The Properly Construed Challenged Claims
`
`} PO admits that Ryu teaches performing gaze detection after detecting the
`claimed act, as required by the Challenged Claims.
`
`} PO has not challenged Petitioner’s motivation to combine Ryu and Hodge as
`proposed in the Petition.
`
`PO Response, at 6; Petitioner Reply, at 8, 14–15
`
`Petitioner’s DX-16
`
`
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