throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
`———————
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`———————
`
`LG ELECTRONICS, INC., LG ELECTRONICS U.S.A., INC.,
`Petitioner
`
`U.S. Patent No. 9,247,174
`
`_____________________
`
`DECLARATION OF ANDREW LIPPMAN,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION FOR
`INTER PARTES REVIEW
`
`EX. 1003
`LG Electronics, Inc. / Page 1 of 149
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`

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`Dr. Lippman Declaration
`
`
`Inter Partes Review of U.S. 9,247,174
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`
`
`TABLE OF CONTENTS
`Introduction ...................................................................................................... 4 
`I. 
`Qualifications and Professional Experience .................................................... 6 
`II. 
`III.  Level of Ordinary Skill in the Art ................................................................... 9 
`IV.  Relevant Legal Standards .............................................................................. 10 
`V. 
`The ’174 Patent .............................................................................................. 12 
`A.  Overview of the ’174 Patent ................................................................ 12 
`B. 
`Prosecution History of the ’174 Patent ............................................... 18 
`VI.  Claim Construction ........................................................................................ 19 
`A. 
`“panel” ................................................................................................. 21 
`B. 
`“at least one” ....................................................................................... 21 
`Identification of how the Claims are Unpatentable ....................................... 22 
`A.  Ground 1: Claims 1-14 are obvious over Woods. ............................... 23 
`1. 
`Summary of Woods ................................................................. 23 
`2. 
`Claim 1 ..................................................................................... 28 
`3. 
`Claim 2 ..................................................................................... 91 
`4. 
`Claim 3 ..................................................................................... 95 
`5. 
`Claim 4 ..................................................................................... 97 
`6. 
`Claim 5 ................................................................................... 102 
`7. 
`Claim 6 ................................................................................... 108 
`8. 
`Claim 7 ................................................................................... 113 
`9. 
`Claim 8 ................................................................................... 117 
`10. 
`Claim 9 ................................................................................... 121 
`
`VII. 
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`2
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`Dr. Lippman Declaration
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`Inter Partes Review of U.S. 9,247,174
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`B. 
`
`C. 
`
`
`11. 
`Claim 10 ................................................................................. 123 
`Claim 11 ................................................................................. 127 
`12. 
`Claim 12 ................................................................................. 127 
`13. 
`Claim 13 ................................................................................. 127 
`14. 
`Claim 14 ................................................................................. 127 
`15. 
`Ground 2: Claims 6, 8, and 14 are obvious over Woods in view of
`Istvan. ................................................................................................ 128 
`1. 
`Summary of Istvan ................................................................. 128 
`2. 
`Reasons to Combine Woods and Istvan ................................ 129 
`3. 
`Claim 6 ................................................................................... 133 
`4. 
`Claim 8 ................................................................................... 136 
`5. 
`Claim 14 ................................................................................. 140 
`Ground 3: Claims 1-14 are obvious over Woods in view of Machida.
` ........................................................................................................... 140 
`1. 
`Summary of Machida ............................................................ 140 
`2. 
`Reasons to Combine Woods and Machida ............................ 142 
`3. 
`Claims 1-14 ............................................................................ 146 
`D.  Ground 4: Claims 6, 8, and 14 are obvious over Woods in view of
`Machida and Istvan. .......................................................................... 148 
`1. 
`Claims 6, 8, and 14 ................................................................ 148 
`VIII.  Conclusion ................................................................................................... 149 
`
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`3
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`Dr. Lippman Declaration
`
`
`Inter Partes Review of U.S. 9,247,174
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`I.
`
`I, Andrew Lippman, do hereby declare as follows:
`INTRODUCTION
`1.
`
`I am making this declaration at the request of LG Electronics, Inc. in
`
`the matter of the Inter Partes Review of U.S. Patent No. 9,247,174 (“the ’174
`
`
`
`patent”) to Sirpal et al.
`
`2.
`
`I am being compensated for my work in this matter at my standard
`
`hourly rate. I am also being reimbursed for reasonable and customary expenses
`
`associated with my work and testimony in this investigation. My compensation is
`
`not contingent on the outcome of this matter or the specifics of my testimony.
`
`3.
`
`I have been asked to provide my opinions regarding whether claims 1-
`
`14 (“the Challenged Claims”) of the ’174 patent are unpatentable as they would
`
`have been obvious to a person having ordinary skill in the art (“POSITA”) at the
`
`time of the alleged invention, in light of the prior art. It is my opinion that all of the
`
`elements of the Challenged Claims would have been obvious to a POSITA.
`
`In the preparation of this declaration, I have studied:
`
`the ’174 patent, Ex.1001;
`
`the prosecution history of the ’174 patent (“’174 File History”),
`
`4.
`
`a.
`
`b.
`
`Ex.1002;
`
`c.
`
`U.S. Patent Publication No. 2010/0262938 to Woods et al. (“Woods”),
`
`Ex.1005;
`
`
`
`4
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`Dr. Lippman Declaration
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`Inter Partes Review of U.S. 9,247,174
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`d.
`
`U.S. Patent Publication No. 2002/0060750 to Istvan et al. (“Istvan”),
`
`
`
`Ex.1006;
`
`e.
`
`“CurioView: TV Recommendations Related to Content Being Viewed,”
`
`Hideki Sumiyoshi, IEEE International Symposium on Broadband Multimedia
`
`System and Broadcasting 2010 (“CurioView”), Ex.1007;
`
`f.
`
`U.S. Patent Publication No. 2007/0047920 to Machida et al.
`
`(“Machida”), Ex.1008;
`
`g.
`
`U.S. Patent Publication No. 2011/0219395 to Moshiri et al.
`
`(“Moshiri”), Ex.1009;
`
`h. WO2013133915 to Cherry et al. (“Cherry”), Ex.1010;
`
`i.
`
`U.S. Patent Publication No. 2012/0054794 to Kim et al. (“Kim”),
`
`Ex.1011;
`
`5.
`
`In forming the opinions expressed below, I have considered: the
`
`documents listed above; the relevant legal standards, including the standard for
`
`obviousness; and my own knowledge and experience based upon my work in the
`
`field of televisions as described below, and any additional authoritative documents
`
`as cited in the body of this declaration.
`
`6.
`
` Unless otherwise noted, all emphasis in any quoted material has been
`
`added.
`
`
`
`5
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`Dr. Lippman Declaration
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`II. QUALIFICATIONS AND PROFESSIONAL EXPERIENCE
`7. My qualifications and professional experience are described in my
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`Inter Partes Review of U.S. 9,247,174
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`
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`Curriculum Vitae, a copy of which can be found in Exhibit 1004. The following is
`
`a brief summary of my relevant qualifications and professional experience.
`
`8.
`
`I earned my undergraduate degree in Electrical Engineering from MIT
`
`in 1971. I earned a Master of Science degree in Computer Graphics from MIT in
`
`1978. I earned a Ph.D. in Electrical Engineering from the École Polytechnique
`
`Fédérale de Lausanne (Switzerland) in 1995. My thesis was on scalable video, a
`
`technique for representing visual data in a fluid and variable networking and
`
`processing environment, similar to what we call streaming today.
`
`9.
`
`I am currently a Senior Research Scientist at the Massachusetts
`
`Institute of Technology (“MIT”) and Associate Director of the MIT Media
`
`Laboratory, an approximately $80 million per year research and teaching facility at
`
`MIT, which I helped establish in the early 1980s.
`
`10. At MIT, I have supervised over 50 Masters and Ph.D. theses in the
`
`Media Arts and Sciences program and have taught courses such as Digital Video
`
`and MIT’s freshman physics seminar. Through the course of my career, I have
`
`directed and served as principal investigator of research projects supported by the
`
`Defense Advanced Research Projects Agency (DARPA), the Office of Naval
`
`Research (ONR), The National Science Foundation (NSF), and over 50 industrial
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`
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`6
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`companies. I have never precisely calculated my net research volume, but it is in
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`excess of $50 million.
`
`11.
`
`I am named as an inventor on six patents in the area of video and
`
`digital processing and have served on the advisory boards for technology
`
`companies in fields ranging from video conferencing to music analysis. I have
`
`authored or coauthored over 65 published papers in the fields of interactivity,
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`communications, video coding, and television. I served on the editorial board of
`
`the Image Communication Journal between 1989 and 2003. I have served as an
`
`expert witness in patent cases since 2001, addressing diverse features of interactive
`
`television, electronic program guides, and user interaction.
`
`12.
`
`I have worked generally on video interaction systems since the 1970s.
`
`In the early 1970s, I developed font representations that permitted high quality
`
`display of text on standard broadcast television receivers. In 1978, I directed a
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`DARPA-funded project called the “Movie-Map” that used computing and optical
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`video and image storage to create an “experiential map” that featured “surrogate
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`travel,” the ability to recreate the visual experience of traveling through a real
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`place, a city. This is similar to Google’s Street-View and mapping systems.
`
`13.
`
`In the 1980s, I was principal investigator of Office of Naval Research
`
`funded programs in video and graphics computer systems for interactive learning
`
`dedicated to maintenance and repair. I also developed networked video
`
`
`
`7
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`communications systems that included scripting languages for specifying
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`Inter Partes Review of U.S. 9,247,174
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`audiovisual content and representing it on various monitoring terminals.
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`14.
`
`In 1991, I created the “Media Bank” program at MIT, the purpose of
`
`which was to allow a diverse set of networked devices to access appropriate forms
`
`of content for which they had the bandwidth and processing power to display. This
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`entailed maintaining state information about terminal devices at a server and using
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`that to determine the best representation of the audiovisual material to deliver to
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`them. In addition, it included and developed cryptographic distribution methods
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`that ensured secure delivery of information on the network. Related to this work, I
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`also supervised Masters theses on networked distribution of video and coding
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`specifically for diverse uses on the Internet. My colleagues and I created
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`demonstrations of interactive television systems for news that combined the
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`evening newscast with additional data from print sources so the viewer could learn
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`more about the story than was available in the live broadcast.
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`15. Also in 1991, I created the Television of Tomorrow program at MIT.
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`This program addressed the digital representation and delivery of video at diverse
`
`scales and through diverse networks. This program built on work on scalable
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`representations of images that were standards-independent and interactive.
`
`16.
`
`In 1993, I was invited to be a member of Robert Kahn’s “Cross
`
`Industry Working Group” the goal of which was to develop the ideas for a
`
`
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`8
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`National Information Infrastructure. At DARPA, Kahn had initiated the research to
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`Inter Partes Review of U.S. 9,247,174
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`develop the Arpanet and the Internet. Throughout this period, my students and I
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`worked on distributed interactive systems for consumer use (television, electronic
`
`newspapers, learning) including the basic technology of the network and the client-
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`server interactions.
`
`17.
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`I was a member of the Motion Picture Experts Groups, an ISO
`
`standards committee effort that defined the standards for common distribution of
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`“MP3” music and storage and distribution of “MPEG Video.” I co-wrote the paper
`
`defining the requirements for the MPEG-2 standard with Okubo and McCann in
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`1995. MPEG standards remain the predominant encoding for distribution of digital
`
`video to this day. I was also the principal investigator on industry-funded programs
`
`addressing digital motion pictures — the “Movies of the Future” program at MIT,
`
`and high definition television, “Television of Tomorrow.” At MIT, I created the
`
`“Digital Life” consortium, the purpose of which was to explore and develop ideas
`
`relevant to an Internet-connected society.
`
`III. LEVEL OF ORDINARY SKILL IN THE ART
`18.
`
`I understand there are multiple factors relevant to determining the
`
`level of ordinary skill in the pertinent art, including (1) the levels of education and
`
`experience of persons working in the field at the time of the invention; (2) the
`
`sophistication of the technology; (3) the types of problems encountered in the field;
`
`
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`9
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`and (4) the prior art solutions to those problems.
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`Inter Partes Review of U.S. 9,247,174
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`19. A person of ordinary skill in the art (“POSITA”) in the field of the
`
`’174 patent, as of its earliest possible filing date of August 17, 2012, would have
`
`been someone knowledgeable and familiar with the television display technology
`
`that is pertinent to the ’174 patent. A POSITA would have had a bachelor’s degree
`
`in Electrical Engineering, Software Engineering, or Computer Engineering, or
`
`equivalent training, and approximately two years of experience working in the
`
`field of television systems and networking, human-computer interaction, or related
`
`technologies. Lack of work experience can be remedied by additional education,
`
`and vice versa.
`
`20. For purposes of this Declaration, in general, and unless otherwise
`
`noted, my statements and opinions, such as those regarding my experience and the
`
`understanding of a POSITA generally (and specifically related to the references I
`
`consulted herein), reflect the knowledge that existed in the field as of the priority
`
`date of the ’174 patent. Unless otherwise stated, when I provide my understanding
`
`and analysis below, it is consistent with the level of a POSITA prior to the priority
`
`date of the ’174 patent.
`
`IV. RELEVANT LEGAL STANDARDS
`21.
`
`I am not an attorney. In preparing and expressing my opinions and
`
`considering the subject matter of the ’174 patent, I am relying on certain basic
`
`
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`10
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`legal principles that counsel have explained to me. These principles are discussed
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`below.
`
`22.
`
`I understand that prior art to the ’174 patent includes patents and
`
`printed publications in the relevant art that predate the priority date of the alleged
`
`invention recited in the ’174 patent. For purposes of this Declaration, I am
`
`applying August 17, 2012 as the earliest possible priority date of the ’174 patent.
`
`23.
`
`I have been informed that a claimed invention is unpatentable under
`
`35 U.S.C. § 103 if the differences between the invention and the prior art are such
`
`that the subject matter as a whole would have been obvious at the time the
`
`invention was made to a person having ordinary skill in the art to which the subject
`
`matter pertains. I have also been informed by counsel that the obviousness analysis
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`takes into account factual inquiries including the level of ordinary skill in the art,
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`the scope and content of the prior art, and the differences between the prior art and
`
`the claimed subject matter.
`
`24.
`
`I have been informed by counsel that the Supreme Court has
`
`recognized several rationales for combining references or modifying a reference to
`
`show obviousness of claimed subject matter. Some of these rationales include the
`
`following: (a) combining prior art elements according to known methods to yield
`
`predictable results; (b) simple substitution of one known element for another to
`
`obtain predictable results; (c) use of a known technique to improve a similar device
`
`
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`11
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`(method, or product) in the same way; (d) applying a known technique to a known
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`device (method, or product) ready for improvement to yield predictable results; (e)
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`choosing from a finite number of identified, predictable solutions, with a
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`reasonable expectation of success; and (f) some teaching, suggestion, or motivation
`
`in the prior art that would have led one of ordinary skill to modify the prior art
`
`reference or to combine prior art reference teachings to arrive at the claimed
`
`invention.
`
`V. THE ’174 PATENT
`A. Overview of the ’174 Patent
`25. The ’174 patent is directed to an “intelligent television and methods
`
`for displaying content.” Ex.1001, abstract. The ’174 patent states that “[t]here is a
`
`need for an Intelligent TV with intuitive user interfaces and with seamless user
`
`interaction capability.” Ex.1001, 2:1-2. The purported solution to this need is an
`
`“application panel interface” that provides to a user information about the content
`
`currently being displayed on the television. The “application panel interface”
`
`includes a “first content panel” to display a first type of information. In response to
`
`directional inputs from a user, the “application panel interface” instead displays a
`
`“second content panel” that displays a different type of information. Claim 1 of the
`
`’174 patent is shown below with colored highlighting that corresponds to the
`
`highlighting in the figures accompanying the discussion below.
`
`
`
`12
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`26. The claimed “application panel interface” is described in an example
`
`of the ’174 patent specification as an application content panel 1412: “The
`
`application panel 1412 may provide access to contextually relevant functionality
`
`based on the currently viewing/recently viewed material.” Ex.1001, 30:42-44. The
`
`application panel 1412 “may be displayed in such a manner as to provide a user the
`
`ability to view content displayed in content view area 1408,” (Ex.1001, 30:22-23)
`
`i.e., the “content currently being displayed via the television,” shown in Fig. 16A
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`
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`13
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`below.
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`application panel
`
`content view area
`
`Ex.1001, Fig. 16A (annotated).
`
`
`
`27.
`
`“The application panel 1412 may comprise ... a content area 1608.”
`
`Ex.1001, 32:47-49. As explained in the ’174 patent, “[t]he panel content area 1608
`
`is panel view specific, i.e., when the panel view in focus changes, the panel content
`
`area 1608 updates to the corresponding panel view that is currently in focus.”
`
`Ex.1001, 32:65-33:1. The view that is in focus is determined based on the menu
`
`item highlighted in the navigation bar 1604: “[T]he panel navigation bar 1604 may
`
`include fixed tab regions (also called tabs or panel views herein) 1620A-1620F
`
`corresponding to navigable menus and further comprising Info, New,
`
`Recommended, Genre, Favorites, and Search.” Ex.1001, 32:55-59. For example, a
`
`
`
`14
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`first “type” of content panel may be the “Info” type, and a second “type” of content
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`Inter Partes Review of U.S. 9,247,174
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`panel may be the “Recommended” type. The different types of content panels
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`displayed within content area 1608 are thus referred to as “panel content types.”
`
`Ex.1001, 34:3-4. An example of the claimed “first content panel” of a first type
`
`(Info) is identified in the annotated figure below.
`
`application panel
`
`content view area
`
`navigation bar
`
`“first content
`panel”
`
`Ex.1001, Fig. 16A (annotated).
`
`
`
`28.
`
`In the example above, when the user has selected “tab 1620A
`
`corresponding to info ... [a]n indicator, such as indicator 1640, may display which
`
`panel view 1620A-C is selected or has the current focus.” Ex.1001, 33:58-61. The
`
`user may use directional keys to navigate the navigation bar and place the focus on
`
`a different menu item: “Using the left and right arrows on the D-Pad navigates
`
`
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`15
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`between the various panel views 1620.” Ex.1001, 34:25-27. When the user
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`navigates from the info tab (1620A) to the “recommended” tab 1620C, the
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`information within content panel 1608 changes accordingly, as shown in the figure
`
`below.
`
`application panel
`
`content view area
`
`navigation bar
`
`“second content
`panel”
`
`Ex.1001, Fig. 16A (annotated).
`
`
`
`29. The ’174 patent illustrates the concept of changing the type of
`
`“content panel” being displayed through directional inputs in Figs. 20C and 21A,
`
`as shown below.
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`16
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`content view area
`
`application panel
`
`navigation bar first content
`panel
`
`
`
`
`
`
`Ex.1001, Fig. 20C (annotated).
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`17
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`second content
`panel
`
`content view area
`
`application panel
`
`navigation bar
`
`
`
`
`
`Ex.1001, Fig. 21A (annotated).
`
`
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`30. However, as I will explain below, the concept of presenting the user
`
`with an application panel and navigating a menu bar with directional inputs such
`
`that the information in a content panel within the application panel changes was
`
`not new as of the time the ’174 patent was filed. Indeed, the Woods reference—
`
`described in detail below—shows that these claimed concepts were already known.
`
`B.
`Prosecution History of the ’174 Patent
`31. The ’174 patent was filed on August 16, 2013. It claims priority to a
`
`
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`series of provisional applications, the earliest of which was filed on August 17,
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`Inter Partes Review of U.S. 9,247,174
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`2012.
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`32. The Office issued a non-final rejection on October 9, 2014, which
`
`rejected the claims as being anticipated by U.S. Patent Publication No.
`
`2012/0174039 to Rhoads (“Rhoads”). Ex.1002, 216-27. In response, the Applicant
`
`added claim limitations related to the “application panel interface.” Ex.1002, 188-
`
`93. In the next Office Action, the Examiner stated that “Independent claims 1 and
`
`16 (and their dependent claims), as amended, present a unique combination of
`
`elements that are not taught or suggested by the art of record, available to the
`
`Examiner at this time, when considering the claims as a whole.” Ex.1002, 135
`
`(emphasis added). The Office then issued a Notice of Allowance on September 4,
`
`2015. Ex.1002, 106-09.
`
`33. However, for the reasons I will explain below, the concept of an
`
`“application panel interface” as well as the other claim limitations of the ’174
`
`patent were not new.
`
`VI. CLAIM CONSTRUCTION
`34.
`
`It is my understanding that in order to properly evaluate the ’174
`
`patent, the terms of the claims must first be interpreted. It is my understanding that
`
`for the purposes of this inter partes review, the claims are to be construed under
`
`the so-called Phillips standard, under which claim terms are given their ordinary
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`and customary meaning as would be understood by one of ordinary skill in the art
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`in light of the specification and prosecution history, unless the inventor has set
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`forth a special meaning for a term. I have also been informed that claim terms only
`
`need to be construed to the extent necessary to resolve the obviousness inquiry.
`
`35.
`
`I have reviewed the entirety of the ’174 patent, as well as its
`
`prosecution history. In my opinion, for purposes of applying the prior art presented
`
`herein to evaluate patentability, the claim terms do not require express
`
`construction. I have applied the so-called Phillips standard, which requires that
`
`claim terms are given their ordinary and customary meaning as would have been
`
`understood by a POSITA in light of the specification and prosecution history,
`
`unless the inventor has set forth a special meaning for a term.
`
`36.
`
`In fact, the ’174 patent provides explicit definitions for various terms
`
`and phrases, including various claim terms of the Challenged Claims. For example,
`
`from column 4, line 60 to column 11, line 35, the ’174 patent lists certain terms
`
`and provides explicit definitions and context for these terms, which include various
`
`claim terms of the Challenged Claims. My analysis of the prior art presented herein
`
`takes into account and is consistent with the definitions and context provided in the
`
`’174 patent for terms in the Challenged Claims. Two examples of claim term
`
`definitions are described below.
`
`
`
`20
`
`
`
`EX. 1003
`LG Electronics, Inc. / Page 20 of 149
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`

`

`Dr. Lippman Declaration
`
`
`Inter Partes Review of U.S. 9,247,174
`
`A.
`“panel”
`37. Claims, 1-4 and 8-12 each recite the phrase “panel.”
`
`38.
`
`I note that in the ’174 patent, the inventor provided a special meaning
`
`for the term “panel.”
`
`
`
`
`
`Ex.1001, 7:36-44.
`
`39. Accordingly, in view of the special meaning provided by the inventor,
`
`the phrasing of “panel” includes “a user interface displayed in at least a portion of
`
`the display.”
`
`B.
`“at least one”
`40. Claims 1, 2, 10, and 11 each recite the phrase “at least one.”
`
`41.
`
`I note that in the ’174 patent, the inventor provided a special meaning
`
`for the term “at least one.”
`
`
`
`21
`
`
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`EX. 1003
`LG Electronics, Inc. / Page 21 of 149
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`

`

`Dr. Lippman Declaration
`
`
`Inter Partes Review of U.S. 9,247,174
`
`
`
`
`
`Ex.1001, 4:60-67.
`
`42. Accordingly, in view of the express definition provided in the ’805
`
`patent, a claim limitation that recites a list of “at least one” items is met by
`
`teaching any item in that list alone or together with any other items in that same
`
`list.
`
`VII. IDENTIFICATION OF HOW THE CLAIMS ARE UNPATENTABLE
`43.
`
`I have been asked to provide my opinion as to whether the Challenged
`
`Claims of the ’174 Patent would have been obvious in view of the prior art. The
`
`discussion below provides a detailed analysis of how the prior art references
`
`identified below teach the elements of the Challenged Claims of the ’174 patent.
`
`As part of my analysis, I have considered the scope and content of the prior art and
`
`any differences between the alleged invention and the prior art. I describe in detail
`
`below the scope and content of the prior art, as well as any differences between the
`
`alleged invention and the prior art, on an element-by-element basis for each
`
`Challenged Claims of the ’174 patent.
`
`
`
`22
`
`
`
`EX. 1003
`LG Electronics, Inc. / Page 22 of 149
`
`

`

`Dr. Lippman Declaration
`
`
`Inter Partes Review of U.S. 9,247,174
`
`44. As described in detail below, the alleged invention of the Challenged
`
`
`
`Claims would have been obvious in view of the teachings of the identified prior art
`
`references as well as the knowledge of a POSITA.
`
`A. Ground 1: Claims 1-14 are obvious over Woods.
`1.
`Summary of Woods
`45. The primary reference that I rely upon is U.S. Patent Publication No.
`
`2010/0262938 to Woods et al. (“Woods”), which was filed on September 30, 2009
`
`and published on October 14, 2010.
`
`46. Like the ’174 patent, Woods relates to “systems and methods for
`
`navigating a media guidance application with multiple perspective views.”
`
`Ex.1005, [0003]. The media guidance application may be, for example, an
`
`“interactive television program guide.” Ex.1005, [0034]. To provide an efficient
`
`technique for navigating media selections, Woods describes an interface that
`
`allows a user to navigate a menu bar to change the type of information being
`
`displayed about the content currently showing on the television. See e.g. Ex.1005,
`
`Fig. 10.
`
`47. Through the interactive guide, a “user may indicate a desire to access
`
`media information by selecting a selectable option provided in a display screen
`
`(e.g., a menu option, a listings option, an icon, a hyperlink, etc.) or pressing a
`
`dedicated button (e.g., a GUIDE button) on a remote control or other user input
`
`
`
`23
`
`
`
`EX. 1003
`LG Electronics, Inc. / Page 23 of 149
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`

`

`Dr. Lippman Declaration
`
`interface or device.” A user may access media from “television broadcasters, such
`
`Inter Partes Review of U.S. 9,247,174
`
`as NBC, ABC, HBO, etc.” and “on-demand programs (as in video-on-demand
`
`(VOD) systems), Internet content (e.g., streaming media, downloadable media,
`
`Webcasts, etc.), and other types of media or video content.” Ex.1005, [0034],
`
`[0036], [0064]. To access media, a user may bring up a guide menu as shown
`
`below in Fig. 9.
`
`Ex.1005, Fig. 9.
`
`48.
`
`“When the user first enters screen 900, processing circuitry 306 may
`
`highlight or bring into focus the program listings corresponding to the currently
`
`tuned program or program being currently accessed.” Ex.1005, [0155]. “The user
`
`
`
`24
`
`
`
`
`
`
`
`EX. 1003
`LG Electronics, Inc. / Page 24 of 149
`
`

`

`Dr. Lippman Declaration
`
`may navigate within portions of the media guidance objects to select a desired
`
`Inter Partes Review of U.S. 9,247,174
`
`program listing corresponding to a media asset.” Ex.1005, [0156]. When a user
`
`selects a program listing from the guide in screen 900—for example the currently
`
`tuned program—the interactive television guide brings up screen 1000, shown in
`
`Fig. 10 below. See Ex.1005, [0170]-[0171].
`
`Ex.1005, Fig. 10.
`
`49. Display screen 1000 includes regions 1010 and 1020, which are
`
`displayed to the left of a media region 1030. Region 1010 is a menu bar that “may
`
`display [a] list of indicators of functions associated with the media asset
`
`corresponding to the program listing selected from screen 900 (FIG. 9).” Ex.1005,
`
`
`
`25
`
`
`
`
`
`
`
`EX. 1003
`LG Electronics, Inc. / Page 25 of 149
`
`

`

`Dr. Lippman Declaration
`
`[0171]. “[R]egion 1020 may display a list of options or items relating to the
`
`Inter Partes Review of U.S. 9,247,174
`
`
`
`indicator of the function in focus in functions menu bar 1010.” Ex.1005, [0175]. In
`
`the example of Fig. 10, the indicator in the option bar is focused on “cast” 1012
`
`and thus region 1020 displays information related to the cast of the currently tuned
`
`program. The “media region 1030 may provide a display of ... the currently tuned
`
`television program.” Ex.1005, [0174]. The panels 1010, 1020 and media region
`
`1030 are identified below, in annotated Fig. 10.
`
`panels
`
`media region
`
`“Media region 1030 may
`provide a display of…
`the currently tuned
`television program”
`Ex.1005, [0174]
`
`menu bar
`
`a “list of options and items” for “CAST”
`Ex.1005, Fig. 10 (modified and annotated).
`
`50. Like the ’174 patent, Woods’ interactive television program guide
`
`
`
`26
`
`
`
`
`
`EX. 1003
`LG Electronics, Inc. / Page 26 of 149
`
`

`

`Dr. Lippman Declaration
`
`allows the user to navigate the menu bar through directional inputs. Fig. 10
`
`Inter Partes Review of U.S. 9,247,174
`
`illustrates

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