U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
`
`
`
`
`SAMSUNG ELECTRONICS CO., LTD.;
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioner
`
`v.
`
`SLYDE ANALYTICS, LLC
`Patent Owner.
`
`
`
`
`DECLARATION OF BENJAMIN B. BEDERSON
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 10,198,085
`
`
`
`
`
`
`
`
`Petitioner Samsung Ex-1002, 0001
`
`

`

`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`I.
`
`INTRODUCTION ......................................................................................... 1
`
`A. Qualifications ....................................................................................... 1
`
`B. Materials Considered ......................................................................... 16
`
`II.
`
`LEGAL STANDARDS................................................................................ 21
`
`A. Anticipation ....................................................................................... 22
`
`B.
`
`C.
`
`D.
`
`Obviousness ....................................................................................... 22
`
`Level of Ordinary Skill in the Art ...................................................... 25
`
`Claim Construction ............................................................................ 27
`
`III.
`
`SUMMARY OF GROUNDS....................................................................... 28
`
`IV. THE ’085 PATENT ..................................................................................... 28
`
`A. Overview of the ’085 Patent .............................................................. 28
`
`B.
`
`Prosecution History of the ’085 Patent .............................................. 32
`
`V.
`
`TECHNOLOGY BACKGROUND ............................................................. 36
`
`A.
`
`B.
`
`C.
`
`D.
`
`Incorporating features of other types of electronic devices into
`wristwatches....................................................................................... 37
`
`Battery life and power mode switching ............................................. 41
`
`Detecting movement of electronic devices using accelerometers ..... 46
`
`Techniques for defining and interpreting movement patterns ........... 54
`
`VI. THE PRIOR ART IN THE APPLIED INVALIDITY GROUNDS ............ 64
`
`A. Yeung (U.S. Patent Publication No. 2009/0164219) (Ex-1005) ....... 64
`
`B.
`
`C.
`
`D.
`
`Ruiz (U.S. Patent No. 8,228,292) (Ex-1006) ..................................... 66
`
`Alameh (U.S. Patent Publication No. 2011/0148752) (Ex-1007) ..... 72
`
`Joselli (M. Joselli and E. Clua, “gRmobile: A Framework for
`Touch and Accelerometer Gesture Recognition for Mobile
`Games,” 2009 VIII Brazilian Symposium on Games and Digital
`Entertainment, Rio de Janeiro, Brazil, 2009, pp. 141-150) (Ex-
`1008) .................................................................................................. 74
`
`E.
`
`Yano (U.S. Patent No. 8,615,375) (Ex-1009) .................................... 78
`
`VII. CLAIM CONSTRUCTION ......................................................................... 79
`
`ii
`
`Petitioner Samsung Ex-1002, 0002
`
`

`

`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`VIII. DETAILED EXPLANATION OF THE UNPATENTABILITY
`GROUNDS .................................................................................................. 80
`
`A. Ground 1: Claims 1-10 Are Obvious over Yeung in View of
`Ruiz. ................................................................................................... 80
`
`1.
`
`A POSITA would have been motivated to combine
`Yeung’s teachings with Ruiz’s teachings and would have
`had a reasonable expectation of success .................................. 80
`
`2.
`
`Claim 1 .................................................................................... 94
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`g.
`
`Element 1[pre]: A method for switching a
`wristwatch from a first power mode to a second
`power mode, comprising: .............................................. 94
`
`Element 1[a]: using an accelerometer for detecting
`a wristturn, and .............................................................. 99
`
`Element 1[b]: switching said wristwatch from said
`first power mode to said second power mode when
`a wristturn has been detected, ..................................... 104
`
`Element 1[c]: wherein said step of detecting a
`wristturn comprises: .................................................... 105
`
`Element 1[c.1]: detecting that an orientation of the
`wristwatch is in a starting position, wherein said
`step of detecting that the orientation is in the
`starting position comprises detecting that the
`orientation of the wristwatch is held within a first
`range for a defined time; ............................................. 106
`
`Element 1[c.2]: detecting that an orientation of the
`wristwatch is then in a final position, wherein said
`step of detecting that the orientation is in the final
`position comprises detecting that the orientation is
`in a second range different from said first range, ........ 112
`
`Element 1[c.3]: in response to a detection that the
`orientation of the wristwatch is in the second
`range, detecting that the wristwatch remains
`substantially immobile during a predetermined
`duration and that a duration between the starting
`position and the final position is in a predefined
`range. ........................................................................... 116
`
`iii
`
`Petitioner Samsung Ex-1002, 0003
`
`

`

`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`3.
`
`Dependent claims 2-10 .......................................................... 121
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`f.
`
`g.
`
`Dependent Claim 2: The method of claim 1,
`wherein said first range is an angle range from 25°
`to 155° relatively to the horizontal. ............................. 121
`
`Dependent Claim 3: The method of claim 1,
`wherein said second range is an angle range from
`−25° to −75° relatively to the horizontal. .................... 126
`
`Dependent Claim 4: The method of claim 1,
`wherein said step of detecting that the wristwatch
`remains substantially immobile during a
`predetermined duration comprises: detecting that
`an orientation of the wristwatch is held in a range
`from −25° to −60° relatively to the horizontal
`during said predetermined duration............................. 129
`
`Dependent Claim 5: The method of claim 1,
`wherein said defined time is 50 ms ............................. 130
`
`Dependent Claim 6: The method of claim 1,
`wherein comprising a step of in response to a
`detection that the orientation of the wristwatch is
`held within this second range for a defined time,
`[1] registering that an orientation of the wristwatch
`is in the final position; [2] wherein said duration
`between the starting position and the final position
`is provided by measuring a duration between the
`starting position and the registering of the final
`position. ....................................................................... 132
`
`Dependent Claim 7: The method of claim 6,
`wherein said defined time is 50 ms. ............................ 137
`
`Dependent Claim 8: The method of claim 1,
`wherein said step of detecting that the orientation
`of the wristwatch is in a second range comprises:
`detecting that a duration between the wristwatch
`being held in the first range and the wristwatch
`being held in the second range is in a predefined
`third range. .................................................................. 138
`
`iv
`
`Petitioner Samsung Ex-1002, 0004
`
`

`

`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`h.
`
`i.
`
`Dependent Claim 9: The method of claim 1,
`wherein said step of detecting that the orientation
`of the wristwatch is then in a second range
`comprises detecting that a display of the
`wristwatch is oriented towards a face of the user........ 140
`
`Dependent Claim 10: The method of claim 1,
`wherein said steps of detecting that the orientation
`of the wristwatch is in a first range and then in a
`second range comprise: in response of a detection
`of the orientation of the wristwatch is in the second
`range, checking if the orientation of the wristwatch
`was in the first range during a previous step. .............. 141
`
`B.
`
`Ground 2: Claims 1-4, 5, and 8-10 are obvious over Yeung in
`view of Alameh and further in view of Joselli................................. 143
`
`1.
`
`A POSITA would have been motivated to combine
`Yeung’s teachings with Alameh’s and Joselli’s teachings
`and would have had a reasonable expectation of success ..... 143
`
`2.
`
`Claim 1 .................................................................................. 150
`
`a.
`
`b.
`
`c.
`
`d.
`
`e.
`
`Element 1[pre]: A method for switching a
`wristwatch from a first power mode to a second
`power mode, comprising: ............................................ 150
`
`Element 1[a]: using an accelerometer for detecting
`a wristturn, and ............................................................ 150
`
`Element 1[b]: switching said wristwatch from said
`first power mode to said second power mode when
`a wristturn has been detected, ..................................... 150
`
`Element 1[c]: wherein said step of detecting a
`wristturn comprises: .................................................... 151
`
`Element 1[c.1]: detecting that an orientation of the
`wristwatch is in a starting position, wherein said
`step of detecting that the orientation is in the
`starting position comprises detecting that the
`orientation of the wristwatch is held within a first
`range for a defined time; ............................................. 151
`
`v
`
`Petitioner Samsung Ex-1002, 0005
`
`

`

`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`f.
`
`g.
`
`Element 1[c.2]: detecting that an orientation of the
`wristwatch is then in a final position, wherein said
`step of detecting that the orientation is in the final
`position comprises detecting that the orientation is
`in a second range different from said first range, ........ 154
`
`Element 1[c.3]: in response to a detection that the
`orientation of the wristwatch is in the second
`range, detecting that the wristwatch remains
`substantially immobile during a predetermined
`duration and that a duration between the starting
`position and the final position is in a predefined
`range. ........................................................................... 156
`
`3.
`
`Dependent Claims 2-4, 6, 8-10 .............................................. 159
`
`a.
`
`b.
`
`c.
`
`d.
`
`Dependent Claim 2: The method of claim 1,
`wherein said first range is an angle range from 25°
`to 155° relatively to the horizontal. ............................. 159
`
`Dependent Claim 3: The method of claim 1,
`wherein said second range is an angle range from
`−25° to −75° relatively to the horizontal. .................... 160
`
`Dependent Claim 4: The method of claim 1,
`wherein said step of detecting that the wristwatch
`remains substantially immobile during a
`predetermined duration comprises: detecting that
`an orientation of the wristwatch is held in a range
`from −25° to −60° relatively to the horizontal
`during said predetermined duration............................. 161
`
`Dependent Claim 6: The method of claim 1,
`wherein comprising a step of in response to a
`detection that the orientation of the wristwatch is
`held within this second range for a defined time,
`[1]registering that an orientation of the wristwatch
`is in the final position; [2] wherein said duration
`between the starting position and the final position
`is provided by measuring a duration between the
`starting position and the registering of the final
`position. ....................................................................... 161
`
`vi
`
`Petitioner Samsung Ex-1002, 0006
`
`

`

`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`e.
`
`f.
`
`g.
`
`Dependent Claim 8: The method of claim 1,
`wherein said step of detecting that the orientation
`of the wristwatch is in a second range comprises:
`detecting that a duration between the wristwatch
`being held in the first range and the wristwatch
`being held in the second range is in a predefined
`third range. .................................................................. 163
`
`Dependent Claim 9: The method of claim 1,
`wherein said step of detecting that the orientation
`of the wristwatch is then in a second range
`comprises detecting that a display of the
`wristwatch is oriented towards a face of the user........ 164
`
`Dependent Claim 10: The method of claim 1,
`wherein said steps of detecting that the orientation
`of the wristwatch is in a first range and then in a
`second range comprise: in response of a detection
`of the orientation of the wristwatch is in the second
`range, checking if the orientation of the wristwatch
`was in the first range during a previous step. .............. 165
`
`C.
`
`Ground 3: Claims 5 and 7 are obvious over Yeung-Alameh-
`Joselli further in view of Yano ........................................................ 166
`
`1.
`
`A POSITA would have been motivated to combine the
`Yeung-Alameh-Joselli combination with Yano and would
`have had a reasonable expectation of success ....................... 166
`
`2.
`
`Dependent Claims 5 and 7 ..................................................... 170
`
`a.
`
`Dependent Claim 5: The method of claim 1,
`wherein said defined time is 50 ms ............................. 170
`
`Dependent Claim 7: The method of claim 6, wherein said
`defined time is 50 ms .................................................. 170
`
`IX. CONCLUSION .......................................................................................... 172
`
`
`
`vii
`
`Petitioner Samsung Ex-1002, 0007
`
`

`

`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`I.
`
`INTRODUCTION
`
`1.
`
`I have been retained by Samsung Electronics Co., Ltd. and Samsung
`
`Electronics America, Inc. (collectively, “Samsung” or “Petitioner”), as an
`
`independent expert in this proceeding before the Patent Trial and Appeal Board
`
`(“PTAB” or “Board”). I understand that Samsung is requesting that the Board
`
`institute an inter partes review (“IPR”) proceeding of U.S. Patent No. 10,198,085
`
`(“the ’085 Patent”) (Ex-1001), currently assigned to Slyde Analytics LLC (“Patent
`
`Owner” or “PO”).
`
`2.
`
`I am not and have never been an employee of Samsung. I am being
`
`compensated at my usual and customary rate of $600 per hour. No part of my
`
`compensation depends on the outcome of this proceeding, and I have no other
`
`interest in this proceeding.
`
`3.
`
`I have been asked to provide my independent analysis of the ’085 Patent
`
`in light of the prior art publications cited below. I have also been asked to consider
`
`the state of the art and prior art available as of October 18, 2011. Based on the prior
`
`art discussed in this declaration, it is my opinion that Claims 1-10 of the ’085 Patent
`
`are unpatentable for the reasons provided below.
`
`A. Qualifications
`
`4.
`
`I am currently Professor Emeritus of Computer Science at the
`
`University of Maryland (“UMD”). From 2014 to 2018, I was the Associate Provost
`
`1
`
`Petitioner Samsung Ex-1002, 0008
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`

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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`of Learning Initiatives and Executive Director of the Teaching and Learning
`
`Transformation Center at the UMD. I am a member and previous director of the
`
`Human-Computer Interaction Lab (“HCIL”), the oldest and one of the best known
`
`Human-Computer Interaction (“HCI”) research groups in the country. I am the co-
`
`founder of the J.S. Bryant School, a therapeutic high school planned to open in 2025.
`
`I was also co-founder and Chief Scientist of Zumobi, Inc. from 2006 to 2014, a
`
`Seattle-based startup that is a publisher of content applications and advertising
`
`platforms for smartphones. I am also co-founder and co-director of the International
`
`Children’s Digital Library (“ICDL”), a web site launched in 2002 that provides the
`
`world’s largest collection of freely available online children’s books from around
`
`the world with an interface aimed to make it easy for children and adults to search
`
`and read children’s books online. I was also cofounder and Chief Technology
`
`Officer of Hazel Analytics, a data analytics company to improve food safety and
`
`better public health whose product sends alerts in warranted circumstances. In
`
`addition, I have for more than 25 years consulted for numerous companies in the
`
`area of user interfaces, including Hillcrest Labs, Lockheed Martin, Logitech,
`
`Microsoft, NASA Goddard Space Flight Center, the Palo Alto Research Center, and
`
`Sony.
`
`5.
`
`For more than 30 years, I have studied, designed, and worked in the
`
`field of computer science and Human-Computer Interaction (HCI). My experience
`
`2
`
`Petitioner Samsung Ex-1002, 0009
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`

`

`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`includes 30 years of teaching and research, with research interests in HCI and the
`
`software and technology underlying today’s interactive computing systems. This
`
`includes the design and implementation of hardware and software systems including
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`graphical user interfaces with capacitive and other touch screen sensors, and
`
`interactive applications on a range of devices, including embedded systems,
`
`controllers, smart phones, and PDAs.
`
`6.
`
`At UMD, I am focused primarily on the area of HCI, a field that relates
`
`to the development and understanding of computing systems to serve users’ needs.
`
`Researchers and practitioners in this field are focused on making universally usable,
`
`useful, efficient, and appealing systems to support people in their wide range of
`
`activities. My approach is to balance the development of innovative technology that
`
`serves people’s practical needs. Example systems following this approach that I
`
`have built include Cortex-I (1992 embedded computer vision system that sensed
`
`licensed plates with custom motor, camera and controller), Audio Augmented
`
`Reality (1995 embedded system for sensing a user’s location and playing audio
`
`suited to that location), Fisheye Menus (2000 software for sensing movement within
`
`and selection of linear list of items in a menu), PhotoMesa (2001 software for end
`
`users to browse personal photos), DateLens (2002 software for end users to use their
`
`mobile devices to efficiently access their calendar information), SlideBar (2005
`
`linear sensor to control scrolling), LaunchTile (2005 “home screen” software for
`
`3
`
`Petitioner Samsung Ex-1002, 0010
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`

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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
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`mobile devices to allow users to navigate apps in a zoomable environment),
`
`SpaceTree (2001 software for end users to efficiently browse very large hierarchies),
`
`ICDL (as described above), and StoryKit (a 2009 iPhone app for children to create
`
`stories).
`
`7.
`
`Throughout the 1990s and 2000s, I worked on a range of “zoomable
`
`user interfaces,” which are systems that support the multi-scale and spatial
`
`organization of and magnification-based navigation among multiple documents or
`
`visual objects. I built several different “ZUI” systems over the years, including
`
`Pad++, Jazz and Piccolo. In those systems, I used a range of solutions to allow users
`
`to control zooming through the information space. The most common approach for
`
`systems with three button mice was to use the middle button for zooming in and the
`
`right button for zooming out. See Ex-1023, p. 18. The user would hold the button
`
`down, and the system would smoothly animate zooming in or out – so that the user
`
`controlled how much the system zoomed based on the duration that the button was
`
`pressed. See id., pp. 20, 22.
`
`8.
`
`In 1995 and 1996, I supervised graduate student David Rogers and
`
`other students in the development of a user interface approach that allowed a user to
`
`“toss” an object across long distances on their screen with their mouse. See Ex-
`
`1024, p. 1. Motivated by increasingly large computer screens, we recognized a need
`
`to help users move items long distances without necessarily having to drag the item
`
`4
`
`Petitioner Samsung Ex-1002, 0011
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`

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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
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`that entire distance manually. See id. Instead, we calculated the speed and direction
`
`that the user dragged an object with their mouse. When a user released the mouse
`
`button, if the speed was greater than a threshold, our code calculated the path of
`
`where to animate the object based on several factors including the speed and
`
`direction of the mouse at the time of mouse button release. The figure below from
`
`a paper we wrote in 1996 shows the path of a tossed object. This resulted in David
`
`Rogers’s master’s thesis in 1995 and a paper that we submitted to the 1996
`
`Conference on Human Factors in Computing Systems (CHI 1996).
`
`
`
`5
`
`Petitioner Samsung Ex-1002, 0012
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`

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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`Exemplar Figure of Tossing.
`
`9.
`
`In 1999 and 2000, I worked on a mechanism to address the challenge
`
`that users faced when selecting one item from a long menu. As I described in a paper
`
`entitled “Fisheye Menus” that I published in the 2000 Proceedings of the ACM
`
`Symposium on User Interface Software and Technology, existing techniques
`
`typically involved lengthy and slow scrolling techniques. See Ex-1025, p. 8. I
`
`created an alternative solution that fit all of the elements onto a single screen thereby
`
`completely eliminating the need to scroll. See Ex-1025, p. 1. This approach used the
`
`concept of “fisheye distortion” to shrink some of the elements, while keeping the
`
`elements that are under the cursor to be full size so the user could easily see and
`
`select them. See id. This approach as depicted in the figure below and described
`
`further in the paper, was later used in a number of commercial products such as the
`
`Apple MacOS Dock.
`
`6
`
`Petitioner Samsung Ex-1002, 0013
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`

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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`Figure 2.
`
`
`
`10. Starting in 2000, I supervised graduate student Leslie Chipman who
`
`was working on a general solution to improve the user experience of people scrolling
`
`long documents on computers. Our solution relied on a passive haptic physical
`
`linear input device we called the “Slidebar.” See Ex-1026, p. 1. The Slidebar was
`
`designed to sit on either side of the keyboard to be used with the non-dominant hand
`
`for scanning and rough positioning, and then if the user wanted to switch to reading,
`
`the dominant hand could be used for more accurate positioning. See id. With a
`
`physical range of motion of approximately two inches, the full range could be
`
`accessed by moving just the fingers without moving the entire hand. See id. This
`
`7
`
`Petitioner Samsung Ex-1002, 0014
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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
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`took advantage of human proprioception⎯the fact that people have excellent ability
`
`to know where their body is⎯and allowed the user to scroll long documents
`
`completely eyes-free. See id, p. 4. They did not need to look at the device or the
`
`screen to, for example, move a mouse pointer to a graphical scroll bar. Instead, they
`
`could focus on their primary task of reading. This work was published in 2004.
`
`11.
`
`In April 2000, I visited Professors Wayne Westerman and John Elias at
`
`the University of Delaware and gave a talk entitled “Zoomable User Interfaces and
`
`Single Display Groupware.” This resulted in a collaboration with Professor
`
`Westerman, graduate student Hilary Browne, and others where we used their
`
`FingerWorks capacitive Multi-Touch Surface as the input device for a multi-touch
`
`finger painting program for children. See Ex-1027, p. 1. The project used this input
`
`device to support a computer painting program that allowed children to paint with
`
`their fingers by directly touching the sensing surface. In contrast to the mouse input
`
`more typically used in this time period, this approach enabled us to create a more
`
`natural interaction environment. See id. This work, depicted in the figure below,
`
`was published in a September 2000 technical report.
`
`
`
`8
`
`Petitioner Samsung Ex-1002, 0015
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`

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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`
`
`Figure 1.
`
`12.
`
`Throughout the 2000’s, I worked on a range of interfaces for mobile
`
`devices with a focus on interface design for touch interfaces, including those with
`
`capacitive sensors. During this period, it became apparent that some positions on a
`
`screen were easier to access than others, especially when used with a single hand.
`
`To understand this issue, I led a range of studies that resulted in two papers published
`
`in 2006 and 2007. See, e.g., Ex-1028, Ex-1029. The following figure summarizes
`
`the results of one of the studies, and shows that generally speaking, when using a
`
`single hand, the center of the screens were easier for users to touch than the edges of
`
`the screen, and that the corners of the screen were the hardest positions to touch.
`
`9
`
`Petitioner Samsung Ex-1002, 0016
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`

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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`
`
`Ex-1029, Table 2.
`
`13. This work on touch screen mobile devices led to my creation of Zumobi
`
`in 2006, where I was responsible for investigating new software platforms and
`
`developing new user interface designs that provide efficient and engaging interfaces
`
`to permit end users to access a wide range of content on mobile platforms (including
`
`the iPhone and Android-based devices). For example, I designed and implemented
`
`10
`
`Petitioner Samsung Ex-1002, 0017
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`

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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
`
`software called “Ziibii,” a “river” of news for iPhone that used a capacitive sensor
`
`for controlling linear movement through news; software called “ZoomCanvas,” a
`
`zoomable user interface for several iPhone apps; and iPhone apps including “Inside
`
`Xbox” for Microsoft and Snow Report for REI. At the ICDL, I have since 2002
`
`been the technical director responsible for the design and implementation of the web
`
`site, www.childrenslibrary.org (originally at www.icdlbooks.org). In particular, I
`
`have been closely involved in designing the user interface as well as the software
`
`architecture for the web site since its inception in 2002.
`
`14. Throughout my design, development, and study of mobile systems, I
`
`was aware of and considered the impact of my work on the power usage and battery
`
`life of the device. In fact, going back to a miniaturized computer vision system I
`
`built as part of my dissertation, I considered power usage of the systems I built. For
`
`example, a 1995 paper I wrote described a mobile computer system including a
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`movable camera explaining that it takes up less than “a third of a cubic foot” and
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`that the “long-range goal of this project is to demonstrate that major new applications
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`of robotics will become feasible when small, low-cost, machine-vision systems can
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`be mass produced. Ex-1051, 101. We use the term ‘commodity robotics’ to express
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`the expected impact of the possibilities for opening up new application niches in
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`robotics and machine vision, for what has until now been an expensive, and therefore
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`limited, technology.” Id. While the prototype I built was plugged in for power, I
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`11
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`Petitioner Samsung Ex-1002, 0018
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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
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`measured its power usage with the recognition that it would be suitable to develop a
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`battery powered version. “The system is powered from a standard 110-volt AC line,
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`but uses less than 25 watts and could be battery powered.” Id., 103.
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`15.
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`I published a 2010 paper that used an integrated accelerometer in a
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`mobile device that used tilt to select a command along the direction of movement.
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`The middle images in the figure below show how a rectangle could be selected by
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`tilting that would then apply a visual format to text. As I explained in the paper,
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`“[g]estures exceeding 30 degree changes from a continually updated ‘neutral’
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`position were recognized as a command along the direction of movement.” Ex-
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`1035, 21.
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`12
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`Petitioner Samsung Ex-1002, 0019
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`

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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
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`16. Beginning in the mid-1990s, I have been responsible for the design and
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`implementation of numerous other web sites in addition to the ICDL. For example,
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`I designed and built my own professional web site when I was an Assistant Professor
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`of Computer Science at the University of New Mexico in 1995 and have continued
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`to design, write the code for, and update both that site (which I moved to the UMD
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`in 1998, currently at http://www.cs.umd.edu/~bederson/) as well as numerous
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`project web sites, such as Pad++, http://www.cs.umd.edu/hcil/pad++/. I received
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`the Janet Fabri Memorial Award for Outstanding Doctoral Dissertation for my Ph.D.
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`work in robotics and computer vision. I have combined my hardware and software
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`skills throughout my career in HCI research, building various interactive electrical
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`and mechanical systems that couple with software to provide an innovative user
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`experience.
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`13
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`Petitioner Samsung Ex-1002, 0020
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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
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`17. My work has been published extensively in more than 160 technical
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`publications, and I have given about 100 invited talks, including 9 keynote lectures.
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`I have won a number of awards including the Brian Shackel Award for “outstanding
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`contribution with international impact in the field of HCI” in 2007, and the Social
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`Impact Award in 2010 from the Association for Computing Machinery’s (“ACM”)
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`Special Interest Group on Computer Human Interaction (“SIGCHI”). ACM is the
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`primary international professional community of computer scientists, and SIGCHI
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`is the primary international professional HCI community. I have been honored by
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`both professional organizations. I am an “ACM Distinguished Scientist,” which
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`“recognizes those ACM members with at least 15 years of professional experience
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`and 5 years of continuous Professional Membership who have achieved significant
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`accomplishments or have made a significant impact on the computing field.” I am
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`a member of the “CHI Academy,” which is described as follows: “The CHI
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`Academy is an honorary group of individuals who have made substantial
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`contributions to the field of HCI. These are the principal leaders of the field, whose
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`efforts have shaped the disciplines and/or industry and led the research and/or
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`innovation in human-computer interaction.” The criteria for election to the CHI
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`Academy are: (1) cumulative contributions to the field; (2) impact on the field
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`through development of new research directions and/or innovations; and (3)
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`influence on the work of others. I have received two “Test of Time” awards from
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`14
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`Petitioner Samsung Ex-1002, 0021
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`U.S. Patent No. 10,198,085
`Declaration of Benjamin B. Bederson
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`IEEE InfoVis for my 2001 and 2002 work on visualizing hierarchies, including those
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`containing digital photos.1
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`18.
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`I have appeared on radio shows numerous times to discuss issues
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`relating to user interface design and people’s use and frustration with common
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`technologies, web sites, and mobile devices. My work has been discussed and I have
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`been quoted by mainstream media around the world over 120 times, including by
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`the New York Times, the Wall Street Journal, the Washington Post, Newsweek, the
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`Seattle Post Intelligencer, the Independent, Le Monde, NPR’s All Things
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`Considered, New Scientist Magazine, and MIT’s Technology Review.
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`19.
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`I have designed, programmed, and publicly deployed dozens of user-
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`facing software products that have cumulatively had millions of users. My work is
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`cited by several major companies, including Amazon, Apple, Facebook, Google, and
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`Microsoft. I am a named inventor on 14 U.S. patents and 20 U.S. patent applications.
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`The patents are generally directed to user interfaces/experience.
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`20.
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`I am over 18 years of age and, if I am called upon to do so, I would be
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`competent to testify as to the matters set forth herein. I understand that a copy of
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`my current curriculum vitae, which deta