Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`plurality of display modes permit an operator to interact with a single display screen in each ofthe
`
`plurality of display modes. See alse Schmandt, 4 202.
`
`Further, Requester submits that the claimed easel mode would have been obvious in view
`
`of Kamikakai alone. Specifically, this casel mode would have been an obvious design choice
`
`variation of Kamikakai’s frame mode, since a user would have only had to rotate the entire device
`
`by approximately 90° from Kamikakai’s frame mode to transition to the easel mode. Schmandt, {|
`
`203. Kamikakai’s main display component (display part 3°) and base (main bady 2”) are at
`
`roughlythe samerelative angle in frame modeas in the claimed easel mode. To reach easel mode
`
`from Kamikakat’s frame mode, a user need only turn the entire computer approximately 90° until
`
`the base and display rest on edge in a substantially vertical manner. Schmandt, [ 203. Moroever,
`
`Kamikakai’s laptop would support such an easel mode, since it can support this same base-display
`
`angle in frame mode, as well as any other arbitary rotary positions, as explained above. fg.,
`
`Kamikakai, 3:52-64, 4:10-5:27; Schmandt, 9 203.
`
`The obviousness of this easel mode is further evidenced by the multitude of references
`
`disclosing this easel-mode like position. See, e.g., Lane, FIG. 28, Valikangas, FIG. 4A; CN °170,
`
`FiG. 19; Shimura, Figure 5; Hisano, 9 [0054], [0098], FIG. 9: Podwainy, 4:16—26, FIG. 4,
`
`Schweizer, 1:49--2:4, FIGS. 2, 4, 6. Thus, given howlittle is required to transition Kamikakai’s
`
`computer from the frame mode to the easel made, and given how well known this easel mode was
`
`in the art before the alleged priority date of the °844 patent, it would have been an obvious design
`
`choice variation to Kamikakai’s existing display modes. Schmandt, 4 204.
`
`it also would have been obvious to a POSITAto have inverted displayed content when
`
`transitioning from easel mode to frame mode to ensure displayed content is presented right-side
`
`up to a user, given the numerous prior art references that 1} recognize the need to do s0 when
`
`116
`
`HP Inc. - Exhibit 1005 - Page 3989
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`HP Inc. - Exhibit 1005 - Page 3989
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`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`changing the orientation of the display, and that 2} provide various means for doing so. See, e.g,
`
`Lane’s position-indicating mechanism 38 and associated software for automatically reorienting
`
`displayed content (6:23-6:2); Valikangas, Abstract: Shimura’s manual reverse switch 106,
`
`Nobuchi’s display changing position 7/17, and the various references discussed above in Section
`
`VHLC. discussing automatic, sensor-based content reorienting; Schmandt, @ 205; alse see, infra,
`
`element 10.6 in Section X.D. The display orientation in frame mode also is the same orientation
`
`as would be presented in Kamikakai’s existing laptop mode (the display is in roughly the same
`
`orientation with respect to gravity in both modes), making the content inversion when transitioning
`
`from easel to frame mode even more obvious. fd
`
`The Kamikehkai-Shimura computer permits an operator to interact with a single display
`screen in each ofthe plurality of display modes.
`
`As can be seen from FIGS. 3, and 9, the Kamikakai device permits an operator to imteract
`
`with a single display screen (“display panel 5”) of the portable computer in each of the plurality
`
`of display modes since the display screen is accessible (faces the operator) in all of the display
`
`modes. f.g., Kamikakai, FIGS. 3, 8, 9, 3:39-46, 5:48-6:13, 6:28-50, 7:4-18.
`
`As can be seen from Figures 1, 4, and 5 above, an operator can interact with a single display
`
`screen (“display means 105”) in each of the plurality of display modes. F.g., Shirnura, Figures. 1,
`
`4,5 (reproduced below), 7 [0014] Gaptop made), 7 [0016] (pen input mode), § [0017] (easel mode).
`
`pa
`
`pana, ~~]
`
`HP Inc. - Exhibit 1005 - Page 3990
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`HP Inc. - Exhibit 1005 - Page 3990
`
`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`KRamikakars Frame Mode
`Kamikakars Laptop Mode
`
`
`
`
`
`
`
`>
`
`FIG.
`
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`Kamikakai, FIGS. 3, 9 Qvith annotations).
`
`Shimura’s Rasel Made
`
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`Shimura, Figure 5 Gvith annotations}.
`
`[10.2] 4 base including a keyboard,
`
`Kamikakai discloses this limitation. Specifically, Kamikakai discloses that the portable
`
`computer (portable information processing apparatus 1”) comprises a base (‘main body 2”}
`
`including a keyboard (“keyboard 6°). E.g., Kamikakai, 3:39-43 (reproduced below}, FIG. 3
`
`(reproduced below with annotation).
`
`iis
`
`HP Inc. - Exhibit 1005 - Page 3991
`
`HP Inc. - Exhibit 1005 - Page 3991
`
`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`As shown m FIGS. 3 through 8, a portable information
`processing apparatus | generally meludes a main body 2, a
`display part 3 which can open and close with respect to the
`main body 2, and a connection part 4. "Phe mais body 2
`includes a keyboard 6 for mypudiine data. On the other band,
`
`Kamikakai, 3:39-43.
`
`Kamikakai, FIG. 3 (with annotation).
`
`[10.3] a main display component rotatably coupled to the base and including the single display | screen which displays content;
`
`Karnikakai discloses this limitation. Specifically, Karmikakai discloses that the portable
`
`computer (portable information processing apparatus 1°) comprises a display component
`
`(“display part 3°} including the single display screen (‘display panel 5”) that displays content.
`
`fig., Kamikakai, 3:43-46 (reproduced below), FIGS. 3, 9.
`
`includes a keyboard 6 for mputting data, On the other hand,
`the display part 3 includes a liquid crystal display panel 3,
`and a pen input part LM which is formed onthe surlace of the
`liguud erystal display panel 8.
`
`Kamikakai, 3:43-46.
`
`119
`
`HP Inc. - Exhibit 1005 - Page 3992
`
`HP Inc. - Exhibit 1005 - Page 3992
`
`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`
`
`Kamikakai, FIG. 3 (with annotations).
`
`Kamikakat’s display component also is rotatably coupled to the base via a hinge assembly
`
`(“connection part 4”). E.g., Kamikakai, 3:52-64, 4:10-42, FIG. 3, 5-9.
`
`The display part 3 and the main body 2 are connected via
`ihe conmection part 4. The connection part 4 is huked to
`related ends or cdaes, af the displaypart 3 and the main body
`2 which confront cack other in a folded or closedstateof the
`display part 3. The connection part 4 inchides a first rotary
`part 7 and a second yotary part &. The lirst rotary part 7 is
`linked to the main body 2, and enables terming of the main
`hody 2 when a rotary masypulation force greater than or
`equal io a predetermined value is apphed on the main body
`2. On the other hand, the second rotary part 8 is linked to the
`display part 3, and enables turning of the display pari 3 when
`a rotary mantpulation force greater than or eqnal
`to a
`predetcrmined valuc is applied on the display part 3.
`
`Kamikakai, 3:52-64.
`
`120
`
`HP Inc. - Exhibit 1005 - Page 3993
`
`HP Inc. - Exhibit 1005 - Page 3993
`
`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`Annotated FIG. 8 of Kamikakai
`
` 4, ,Ze ‘,
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`Kamikakai, FIG. & (with annotations).
`
`:
`
`| [10.4] a hinge assembly disposed at least partially within the base and the main display §
`| component that defines an axis of rotation about which both the base and the main display |
`| component are rotatable to transition the portable computer between at least the laptop mode |
`and the easel mode,
`:
`| wherein the transition between the laptop mode and the easel mode allows the operatorto |
`| operate the portable computer while viewing the single display screen in eachofthe plurality |
`| of display modes, wherein
`
`Together, Kamikakai and Shimura teach this limitation.
`
`A Hinge Assembly Disposed At Least Partially Withia the Base and Main Display
`
`Kamikakai discloses that the portable computer comprises a hinge assembly (connection
`
`part 4”). As shown in FIGS. 3, 44, and 4F of Kamikakat, this hinge assemblyis disposed at least
`
`partially within the base (“main body 2”) and the main display component (display part 3”).
`
`HP Inc. - Exhibit 1005 - Page 3994
`
`HP Inc. - Exhibit 1005 - Page 3994
`
`

`

`24844862
`
`Patent No.:
`Request for Ex Parte Reexamination
`
`ete.‘ftxLt
`wee,bhWS
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`hootLfwatpoe#tefenpoet
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`aws,
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`
`HP Inc. - Exhibit 1005 - Page 3995
`
`se
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`FIG. 3 Gvith annotations).
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`
`Kamikakai, FIG. 4A Gvith annotations).
`
`HP Inc. - Exhibit 1005 - Page 3995
`
`
`
`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`
` .
`
`—C
`
`d
`
`2
`
`Kamikakai, FIG. 4F (with annotations).
`
`As shown tn FIGS. 4A and 4F, the hinge assemblyis clearly disposed at least partially
`
`within the base and the display component, as the base and display component surround the hinge
`
`assembly on three sides. Schmandt, 7 213.
`
`Kamukakai’s Description of the Preferred Embodiments confirms that the hinge assembly
`
`ig at least partially disposed within the base (main body 2”) since “[al] part of the [hinge
`
`assembly’s| rotary shaft 21 1s mounted on the main body 2 via a mounting part 22.” Kamikakai,
`
`411-12. Kamikakai’s Description of the Preferred Embodiments also confirms that the hinge
`
`assemblyis at least partially disposed within the main display component (“display part 37} since
`
`“Taj part of the [hinge assembly’s] rotary shaft 24 is mounted on the display part 3 via a mounting
`
`part 25.” Kamikakai, 4:28--29,
`
`HP Inc. - Exhibit 1005 - Page 3996
`
`HP Inc. - Exhibit 1005 - Page 3996
`
`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`Kamikakal’s Hinge Assembls
`
`rig. GA
`
`Kamikakai, FIG. OA Gvith annotations).
`
`The Hinge Assembly Defines an Axis of Rotation About Which Both the Base and the
`Main Display Component are Rotatable
`
`Although the clair limitation recites “av axis of rotation” (844 Patent, 18:38-39), in
`
`district court litigation, Patent Owner contends the recited “hinge assembly ...” reads on the
`
`accused product's dual-axis hinge assembly. FirstAmended Complaint (Ex. 1032), 155 (p. 75}.
`
`Assuming the broadest reasonable interpretation (BRJ) of this claim limitation encompasses Patent
`
`Owner’s advanced construction in district court litigation, then Kamikakai’s dual-hinge assembly
`
`satisfies this claim limitation. Specifically, Ramikakai’s hinge assembly defines anaxis ofrotation
`
`(the axts defined bythe second rotary part 8) about which the main display component is rotatable
`
`relative to the hinge assembly (connection part 4”) and defines an axis of rotation (the axis defined
`
`by first rotary part 7) about which the base is rotatable relative to the hinge assembly. fog.,
`
`Kamikakai, 3:52-64, FIGS. 5-9; Schmandt, © 215.
`
`HP Inc. - Exhibit 1005 - Page 3997
`
`HP Inc. - Exhibit 1005 - Page 3997
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`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`The display part 3 and the main body 2 are connected via
`the connection part 4. The connection pari 4 is linked to
`related ends or edges, af the display part 3 and the mam body
`2 which confront each other m 4 folted or closed state of the
`diaplay part 3. The connection part 4 inchades a first rotary
`part 7 and a second rotary part 8. The first rotary part 7 is
`linked to the main bady 2, and enables turning of the maim
`bedy 2 when a rotary manyyulation force greater than or
`equal to a predetermined value is applied on the main body
`2. On the other hand, ihe second rotary part § is linkedfo the
`display part 3, and enables turning of the display part 3 when
`a rotary manipalation force greater than or equal
`to a
`predetermined value is applied on the display part 3.
`
`Kamikakai, 3:52-64.
`
`Thus, under Patent OQwner’s apparent construction of the recited “hinge assembly defines
`
`an axis of rotation about which the base and main display component rotate relative to one
`
`another,” this element is met by Kamikakai’s hinge assembly. That is, if Patent Owner attempts to
`
`read this claim limitation so broadly as to cover the dual-axis hinge assembly of Lenovo’s accused
`
`ThinkPad X1 Yoga product, then Kamikakai’s similar dual-axis hinge assemblysatisfies the claim
`
`limitation.
`
`The Portable Computer is Rotatuhle About the Axis of Rotation te Transition Between
`At Least the Laptop and EaselModes
`
`As discussed above for element 10.1, Kamikakai’s display component and base are
`
`rotatable about the axes of rotation of Kamikakai’s hinge assemblyhinge to transition Kamikakat’s
`
`computer to any arbitrary rotary angle between 0° and 360°, which includes Kamikakai’s laptop
`
`and frame modes, and, when implementing Kamikakai’s computer with Shimura’s easel mode,
`
`inherently includes this easel mode. Aig, Kamikakat, 3:52-64, 4:10-5:27, Schmandt, 217. That
`
`is, easel mode takes on just one of these arbitrary rotary angles to which Kamikakai’s display
`
`component and base can rotate. According the °844 Patent, this angle is the same as and/or similar
`
`HP Inc. - Exhibit 1005 - Page 3998
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`HP Inc. - Exhibit 1005 - Page 3998
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`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`to the angle in frame mode. °844 Patent, 16:5-8. Thus, by transitioning to the frame mode,
`
`Kamikakai’s display component and base have effectively rotated about the axes of rotation to the
`
`easel mode's angle; all that is required to transition to easel mode is to turn the entire computer
`
`until itis in the upright, inverted “V” configuration of the claimed easel mode, as described above
`
`for element 10.1.
`
`The Operator Can Operate the Computer Whale Viewing the Single Display Screen in
`Each of the Plarality ofDisplay Modes
`
`Further, the operator is able to operate the portable computer while viewing the single
`
`display screen in each of the plurality of display modes. For example, the operatoris able to utilize
`
`the keyboardto operate the portable computerin the laptop mode (Kamukakai, FIG. 3) andis able
`
`to utilize the touch-sensitive pen input part 10 to operate the portable computer in the frame mode
`
`Ud, FIGS. 8-9). Ag, id., 3:42-43, 643-50; Schmandt, | 218.
`
`mam body 2, and a connection part 4. The main body 2
`tichudes a keyboard 6 for inputting data. On the other hand,
`
`Kamikakai, 3-42-43.
`
`&. fo addition, the pen ypu part 10 is casily accessible by
`ihe user, because the area cecupied by the portable infor-
`mation processing apparatus Eoin this state is not much
`differeat from that mwthe folded state of the display part 3
`and the portable information processing apparatus 1 can
`easily be maintained in a stable state.Accordingly, the user
`can easily inpul data from the pen input part 16 by manipu-
`lating a pen (not shown) with respect to the pen inpul part.
`
`Kamikakai, 6:43-S0.
`
`HP Inc. - Exhibit 1005 - Page 3999
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`HP Inc. - Exhibit 1005 - Page 3999
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`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`Kamikakai, FIG. 9 (with annotations).
`
`A POSITAalso would have understood that Kamikakai, as modified in view of Shimura,
`
`also “allows the operator to operate the portable computer while viewing the single display screen”
`
`in easel mode, since Shimura’s screen is accessible in easel mode. That is, when implementing
`
`Kamikakai’s computer with Shimura’s easel mode, Kamikakai’s touch screen (pen input part
`
`10°} would be accessible to an operator in the easel mode just like Shimura’s is in easel mode.
`
`Further, an operator could operate Kamikakai’s computer in the easel mode by touching
`
`Kamikakai’s touch screen, just like they would in Kamikakai’s frame mode. Schmandt, 7 219.
`
`Additionally, it would have been obvious to a POSITAto include an external mouselike Shimura’s
`
`external mouse 130 to provide another way for a user to operate the Kamikakai computer in the
`
`easel mode. Schmandt, { 219.
`
`| oriented towards the user and the kevboard oriented to receiv
`
`[10.5] the laptop mode is configured to displayto a user on the main display component a first
`content mode having a first content display orientation with the main display component
`¢ input from the user
`
`nant bh ~~4
`
`HP Inc. - Exhibit 1005 - Page 4000
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`HP Inc. - Exhibit 1005 - Page 4000
`
`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`Together, Kamikakat and Shimura teach this limitation. As explained above for element
`
`10.1, Kamikakai teaches the laptop mode.
`
`A Laptop Made with the Main Display Oriented Tawards User and the Keyboard
`Oriented to Receive Inputfrom User
`
`As shown in FIG. 3 of Kamikakai below, Kamikakai’s main display component is oriented
`
`towards the user and the keyboard is oriented to receive input from the user in the laptop mode.
`
`1G, 3
`
`Kamikakai’s Lante
`
`Kamikakai, FIG. 3 (with annotations).
`
`The Laptop Mode is Configured to Display a First Content Mode Having a First Content
`Display Orientation
`
`While Kamikakai does not explicitly disclose its laptop mode displaying a first content
`
`mode having a first content display orientation, a POSITA would have understood that Ramikakai
`
`necessarily displays content in the laptop mode, and does so in a certain orientation (e.g., one in
`
`which content is presented right-side up to an operator). Schmandt, | 222. Otherwise, Kamikakai’s
`
`display would effectively be useless. Schmandt, { 222.
`
`Moreover, Shimura explicitly discloses a first content mode with a first content orientation.
`
`As shown in Figure | of Shimura below, Shimura’s laptop mode is configured to display a first
`
`HP Inc. - Exhibit 1005 - Page 4001
`
`HP Inc. - Exhibit 1005 - Page 4001
`
`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`coment mode having a first content display orientation (normal mode’) as indicated by display
`
`example 120. See also, Shimura, {| [0012].
`
` ¥
`|
`
`atermast
`
`Shimura, FIG.
`
`1 (with annotations).
`
`Thus, a POSITA would have been motivated to implement Kamikakai’s laptop mode to
`
`display content using a first display orientation so that the content is presented right-side up to an
`
`operator, jast as expressly shown in Shimura. Schmandt, € 224. Onits face, the claim limitation
`
`does not recite that the first content mode requires anything more than this first content display
`
`orientation. Thus, Kamiakai and Shimura satisfy it. However, to the extent Patent Owner argues
`
`that this claim limitation somehow requires that the first content mode include or display a
`
`particular fvpe of content, this would have been obvious in further viewof Ledbetter, as explained
`
`below in Section X.D., see also, Ledbetter, #4] [0055-57], Schmandt, 4 224.
`
`Thus, Karnikakai, as implemented with Shimura’s easel made, inclides a laptop mode
`
`configured to display to a user on the main display componenta first content mode having a first
`
`129
`
`HP Inc. - Exhibit 1005 - Page 4002
`
`HP Inc. - Exhibit 1005 - Page 4002
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`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`content display orientation with the main display component oriented towards the user and the
`
`keyboard onented to receive input from the user. Schmandt, {| 225.
`
`|
`
`:
`
`[10.6] the easel mode is configured to display to the user on the main display component a J
`econd content mode having a second content display orientation with the main display |
`component oriented towards the user and the keyboard oriented awayfrom the user, wherein |
`he first and second content display orientations are 180 degrees relative to each other, and
`| wherein the portable computer is operable in the easel mode to enable the userto interact with §
`| displayed content without interacting with the keyboard; and
`
`Together, Kamikakat and Shimura teach this limitation. As discussed above for element
`
`10.1, a POSTPA would have implemented the Kamikakai configurable computer with an easel
`
`mode as taught by Shimura.
`
`An EaselMode with the Main Display Oriented Towards the User and the Kephoard
`Oriented Away fromthe User such that the Portable Computer is Operable in the Easel
`Mode to Enable the User to Interact with Displayed Content Without Interacting with
`the Keyboard
`
`As shownin Figure 5 of Shimurabelow, in easel modethe display is oriented towards (.e.,
`
`is facing) the user and the keyboard is oriented away from the operator, on the backside of the
`
`COMPputer.
`
`130
`
`HP Inc. - Exhibit 1005 - Page 4003
`
`HP Inc. - Exhibit 1005 - Page 4003
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`

`

`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
`
`Annotated FIG. 5 of Shimura
`
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`Shimura, FG. 5 Gwvith annotations).
`
`Finally, when implemented with the easel mode, Kamikakai’s computer would enable the
`
`user to interact with displayed content in this easel mode without interacting with the keyboard,
`
`either through Kamikakai’s touch screen (“pen input part 10°) or Shimura’s mouse, as explained
`
`above for element 10.4 in this Section (X.C.}.
`
`The Easel Mode is Configured to Display a Second Content Mode Having «a Second
`Content Display Orientation that is Inverted (Rotated 180} Relative to the First Content
`Display Orientation
`
`Shimura also discloses that its easel mode is configured to display a second content mode
`4
`having a second content display orientation (reverse mode”), as shown by display example 121
`Oo
`in Figure 5. Specifically, in reverse mode, the displayed content “can be rotated 180°” with respect
`
`to the first content display orientation (normal made”). £.2., Shimura, #4] [0012], [0017].
`
`HP Inc. - Exhibit 1005 - Page 4004
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`HP Inc. - Exhibit 1005 - Page 4004
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`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
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`Shimura, FIG. § Owith annotations).
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`Thus, when implementing an easel mode in Kamikakai’s computer, a POSITA would have
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`been motivated to similarly display content in Shimura’s second content display orientation in the
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`easel mode to ensure that it is presented right-side up to an operator, since the display would be
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`upside down in easel mode relative to Kamikakai’s other modes, fust like it is for Shimura’s
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`computer. Schmandt, { 230. Specifically, Kamikakai’s computer would be hinge-side-up in easel
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`miode, just like in Shimura’s casel mode, while Kamikakai’s computer is hinge-side-downin laptop
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`and frame modes, as Hlustrated in Ramikakai’s annotated drawings below.
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`HP Inc. - Exhibit 1005 - Page 4005
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`HP Inc. - Exhibit 1005 - Page 4005
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`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
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`Side-Down in Laptop and Frame Modes
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` Kamikakai’s Laptop Mode
`Eig. 3
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`Kamikakars Frame Mode
`FIG, 9
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`Kamikakai, FIGS. 3, 9 (with annotations).
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`Kamikakai’s Display Component Would
`be Hinge-Side-Un in Easel Mode
`Kamikakai’s Easel Mode
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`Kamikakai, FIG. 9 (@otated, with annotations).
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`Thus, because the main display component is inverted in easel mode, a POSITA would
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`have understoad that content would need to be displayed in Shimura’s inverted second content
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`orientation in order to be presented right-side-upto a user in easel made.
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`Moreover, even absent Shimura’s express teaching on inverting content, such content
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`inversion would have been obvious to a POSITA giventhe state of the prior art. Schmandt, #1 232.
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`HP Inc. - Exhibit 1005 - Page 4006
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`HP Inc. - Exhibit 1005 - Page 4006
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`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
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`Specifically, before the “844 Patent’s alleged priority date, it was very well known in the art to
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`rotate content based on the orientation of a display to ensure the content is displayed right-side up
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`to a user. For example, Valikangas, Hisano, Tsun, Schweizer, and Shigeo all disclose inverting
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`displayed content (.e., rotating/reorienting it by 180°) when opening a display by more than 180°
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`to a position where it is upside downrelative to a conventional laptop mode. See, e.g, Valikangas,
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`Abstract, p. 5; Hisano, {ff [0098-99], Tsuji, 4 [0049], [0055], [0059-61], [0074], FIG. 14;
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`Schweizer, 5:23-35; Shigeo, Abstract, #4] [0004], [0014-16], FIGS. 2, 4(b); supra, Sections VILF.
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`aod VHLC. In fact, Schweizer confirms that this kind of content reonenting involves “noinventive
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`activity.” Schweizer, 5:20-26. These references even teach that such content inversion can be done
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`automatically using sensors, such as using hinge angle sensors that measure the angle between the
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`base ard the display and/or by using accelerometers. See, ¢.g., Hisano, 9] [0098-99]; Tsuji, 7]
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`fO049], FOOS55], [0089-61], [0074 FIG. 14, Schweizer, 5:23-35; Shigeo, Abstract, €]
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`[0004],
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`[0014-161], FEGS. 2, 4(b); supra, Sections VILF and VIILC.
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`Moreover, the °844 Patent itself acknowledges that it was known to use accelerometers
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`{albeit to transition between landscape and portrait orientations). °844 Patent, 8:44-48. The
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`Background section of one of Apple Inc.’s provisional patent applications that pre-dates the °844
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`Patent’s alleged priority date by more than nine months, confirms that it was well known to “use
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`one or more accelerometers to automatically adjust the orientation of the information on the
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`screen.” Ording, | [0007].
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`Thus, given how well-known this content reorienting was in the art, it would have been
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`obvious to a POSITAto have provided a means for inverting the content in Kamikakai’s computer
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`when implementing Shimura’s easel mode to ensure the content is present to a user right-side up
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`in the display’s upside-down configuration in easel mode. Further, a POSITA would have been
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`HP Inc. - Exhibit 1005 - Page 4007
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`HP Inc. - Exhibit 1005 - Page 4007
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`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
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`able to implement this content inversion without any undue experimentation given that it would
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`have been well within the skill of a POSITAat the alleged priority date, as evidenced by the
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`rnultitude of references disclosing such content reorienting. Schmandt, | 234.
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`On its face, the claim limitation does not recite that the first and second content modes
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`differ other than that the content display orientations differ by 180 degrees. Thus, Kamtkakai and
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`Shimura satisty it. To the extent patent owner argues that the first and second content modes
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`somehowrequire different types of content (such that the clairn requires that the laptop and easel
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`modes be configured to display different content), the claim limitation would still be obvious in
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`further view of Ledbetter because, as explained in greater detail below in Section X.D., Ledbetter
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`teaches displaying different Apes of content for different device configurations. f.g., see
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`Ledbetter, #4] [0055-57].
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`Thus, Rarmikakat, as implemented in view of Shimura’s easel mode teachings, would have
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`included an easel mode configuredto display to the user on the main display component a second
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`content mode having a second content display orientation with the main display component
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`oriented towards the user and the keyboard oriented away from the user, wherein the first and
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`second content display orientations are 180 degrees relative to each other, and whereinthe portable
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`computer is operable in the easel mode to enable the user to interact with displayed content without
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`interacting with the keyboard. Schmandt, 4 236.
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`:
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`| [10.7] a navigation control accessible in each of the plurality of display modes and configured
`| to permit a user to manipulate at least one of operating parameters of the portable computer |
`| and the content displayed on the single display screen
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`In District Court litigation, Patent Qwner contends the recited “navigation control” reads
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`on the accused product’s touch screen. First Amended Complaint (Ex. 1032}, 4 160 (pp. 77-78}.
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`Assuming the broadest reasonable interpretation (BRDofthis claim limitation encompasses Patent
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`HP Inc. - Exhibit 1005 - Page 4008
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`HP Inc. - Exhibit 1005 - Page 4008
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`Patent No.: 8,624,844
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`Owner's advanced construction in District Court litigation, then Kamikakat’s pen input part 10
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`satisfies this claim limitation since it too is a touch screen that is accessible in each of the plurality
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`of Kamikakai’s display modes. See, e.g., supra, elements 10.4 and 10.6 of this Section OCC.).
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`Moreover, both Kamikakai and Shimura’s touch-sensitive display screens (pen input part 10 and
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`display means 105, respectively) are accessible in each of their plurality of display modes—
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`collectively, their laptop modes, Shimura’s easel mode, Kamikakai’s frame mode, and Shimura’s
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`pen input mode. #.g., Shimura, Figures 1, 4-5, Abstract. {[0004-45], [OO11], [0016]; Kamikakai,
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`2:49-§4, 3:21-23, 6:43-7:18, FIGS. 3, 8-9.
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`While neither Kamikakai sor Shimura explicitly disclose that their touch-sensitive screens
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`are configured to permit a user to manipulate operating parameters and content displayed on the
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`single display screen, a POSITA would have understood that, being input devices, these touch-
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`sensitive screens would have been configured to permit a user to manipulate displayed content and
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`operating parameters, since this is what input devices did before the alleged priority date and
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`continue to do. Schrandt, [ 238. The ’844 Patent itself acknowledges that then-existing “portable
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`computers [were] able to accept user inputs via a touch screen.” ’844 Patent, 1:32-33; alse see,
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`e.g, Pogue, $B3-586 (explaining how auser can navigate documents, manipulate data and adjust
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`settings via the touch screen}, Schmandt, 4 238.
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`A POSITA would have expected that interacting with (.e., touching) this type of input
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`device (a touch-sensitive screen} would have changedthe displayed content just like it would have
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`with any other type of input device (e.g., mouse, keyboard, scroll wheel, etc.). For example,
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`whether selecting content, navigating forward and/or backward (e.g, on a web page), and/or
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`opening and/or closing a windowor application with a touch-sensitive screen or another input
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`device, a POSITA would have understood that using any input device to perform these actions
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`HP Inc. - Exhibit 1005 - Page 4009
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`HP Inc. - Exhibit 1005 - Page 4009
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`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
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`would have caused the computer to change the displayed content fe.¢., to open or close a file,
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`window, or application, to go back to a previous web page or go forward to a new one, etc.).
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`Schmandt, | 239. Moreover, because it was well known for user to be able to adjust operating
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`parameters—like volume (see, e.g., Nishtyama, 4:27-29, 5:51-56}—viaan input device, it would
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`have been obvious to a POSEPA for Kamikakai’s and Shimura’s computers to have enabled a user
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`to adjust operating parameters via their touch-sensitive screens. Schmandt, 47 239.
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`Thus, under Patent Qwner’s apparent construction of the recited “navigation control” this
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`element is met by Kamikakai’s pen input part 10. That is, if Patent Owner attempts to read this
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`claim limitation so broadly as to cover the touch-sensitive screen of Lenovo's accused ThinkPad
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`Xi Yoga product and/or other products, then Kamikakai and/or Shimura’s similar touch-sensitive
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`screens satisfy the claim limitation.
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`| (10.8) wherein the plurality of modes includes a frame mode in which the main display §
`| component is oriented towards the operator,
`the base contacts a substantially horizontal |
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`surface, and the keyboard faces the substantially horizontal surface
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`Kamikakai discloses this limitation. As shown in FIG. 8 of Kamuikakai, the base (main
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`body 2”) contacts a substantially horizontal surface with the keyboard (keyboard 6”) facing down
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`towards the surface. The main display component (display part 3°) is onented towards the
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`operator with the single display screen (“pen input part 10”) facing up. In addition, and as required
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`by the Board in the non-instituted IPR proceeding, Kamikakai’s main display componentis at a
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`nonzero angle relative to the base.
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`ire Lod ma}
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`HP Inc. - Exhibit 1005 - Page 4010
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`HP Inc. - Exhibit 1005 - Page 4010
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`

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`Patent No.: 8,624,844
`Request for Ex Parte Reexamination
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