Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 1 of 58 PageID #: 12333
`Case 5:19-cv-00036—RWS Document 348-8 Filed 06/18/20 Page 1 of 58 PageID #: 12333
`
`EXHIBIT 25
`
`EXHIBIT 25
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 2 of 58 PageID #: 12334
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`Invalidity of U.S. Patent No. 6,329,794
`by
`U.S. Patent No. 5,870,685 to Flynn (“Flynn”)
`
`
`The excerpts cited herein are exemplary. For any claim limitation, Defendant may rely on excerpts cited for any other limitation and/or
`additional excerpts not set forth fully herein to the extent necessary to provide a more comprehensive explanation for a reference’s
`disclosure of a limitation. Where an excerpt refers to or discusses a figure or figure items, that figure and any additional descriptions of
`that figure should be understood to be incorporated by reference as if set forth fully therein.
`
`Except where specifically noted otherwise, this chart applies the apparent constructions of claim terms as used by Plaintiff in its
`infringement contentions; such use, however, does not imply that Defendant adopts or agrees with Plaintiff’s constructions in any way.
`
`U.S. Patent No. 6,329,794 (“the ’794 Patent”) claims priority to Japanese Application No. 12-154358, filed May 22, 2000. For purposes
`of these invalidity contentions, Defendant applies the May 22, 2000, priority date for the ’794 Patent. However, Defendant reserves the
`right to contest Plaintiff’s reliance on the May 22, 2000, priority date, should the priority date become an issue in this proceeding.
`
`U.S. Patent No. 5,870,685 to Flynn (“Flynn”) issued on February 9, 1999. Flynn qualifies as prior art with regard to the ’794 Patent at
`least under 35 U.S.C. §§ 102(a) and (b) (pre-AIA).
`
`Flynn identifies the Duracell-Intel Smart Battery Data Specification, Rev. 1.0, (“Duracell Smart Battery Specification”) as part of
`specifying Duracell smart batteries for particular embodiments. See Flynn at 9:38-42. On information and belief the Duracell Smart
`Battery Specification was publicly available at least as early as February 15, 1995. The Duracell Smart Battery Specification therefore
`qualifies as prior art with regard to the ’794 Patent at least under 35 U.S.C. § 102(b) (pre-AIA).
`
`U.S. Patent No. 6,031,999 to Ogawa (“Ogawa”) was filed July 25, 1997, and issued February 29, 2000. Ogawa qualifies as prior art
`with regard to the ’794 Patent at least under 35 U.S.C. §§ 102(a) and (e) (pre-AIA).
`
`U.S. Patent No. 6,501,968 to Ichimura (“Ichimura”) was filed April 17, 1998, and issued December 31, 2002. Ichimura qualifies as
`prior art with regard to the ’794 Patent at least under 35 U.S.C. § 102(e) (pre-AIA).
`
`U.S. Patent No. 6,363,266 to Nonogaki (“Nonogaki”) was filed on March 1, 2000, and issued on March 26, 2002. Nonogaki qualifies
`as prior art with regard to the ’794 Patent at least under 35 U.S.C. § 102(e) (pre-AIA).
`
`
`
`
`1
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 3 of 58 PageID #: 12335
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`U.S. Patent No. 6,609,072 to Yamagata (“Yamagata”) was filed on December 2, 1998, and issued on August 19, 2003. Yamagata
`qualifies as prior art with regard to the ’794 Patent at least under 35 U.S.C. § 102(e) (pre-AIA).
`
`Japanese Unexamined Patent Application Publication JP H7-281798 to Tanaka (“Tanaka”) published October 27, 1995. Tanaka
`qualifies as prior art with regard to the ’794 Patent at least under 35 U.S.C. §§ 102(a) and (b) (pre-AIA).
`
`U.S. Patent No. 5,886,954 to Asami et al. (“Asami”) issued March 23, 1999. Asami therefore qualifies as prior art with regard to the
`’794 Patent at least under 35 U.S.C. §§ 102(a) and (b) (pre-AIA).
`
`Flynn anticipates or otherwise renders obvious claims 1-3, 8-10, and 14 under 35 U.S.C. §§ 102 and 103(a).
`
`Alternatively, Flynn in view of Duracell Smart Battery Specification renders claims 1-3, 8-10, and 14 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ichimura renders claims 1-3, 8-10, and 14 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ogawa renders claims 1-3, 8-10, and 14 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Duracell Smart Battery Specification and further in view of Ogawa renders claims 1-3, 8-10, and 14
`obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ichimura and further in view of Ogawa renders claims 1-3, 8-10, and 14 obvious under 35 U.S.C.
`§ 103(a).
`
`Alternatively, Flynn in view of Nonogaki renders claims 3, 5, and 11 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Duracell Smart Battery Specification and further in view of Nonogaki renders claims 3, 5, and 11 obvious
`under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ichimura and further in view of Nonogaki renders claims 3, 5, and 11 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ogawa and further in view of Nonogaki renders claims 3, 5, 6, 11, and 12 obvious under 35 U.S.C.
`§ 103(a).
`
`
`2
`
`
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 4 of 58 PageID #: 12336
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`Alternatively, Flynn in view of Duracell Smart Battery Specification and further in view of Ogawa and Nonogaki renders claims 3, 5,
`6, 11, and 12 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ichimura and further in view of Ogawa and Nonogaki renders claims 3, 5, 6, 11, and 12 obvious under
`35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Yamagata renders claim 3 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Duracell Smart Battery Specification and further in view of Yamagata renders claim 3 obvious under 35
`U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ichimura and further in view of Yamagata renders claim 3 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ogawa and further in view of Yamagata renders claim 3 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Duracell Smart Battery Specification and further in view of Ogawa and Yamagata renders claim 3
`obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ichimura and further in view of Ogawa and Yamagata renders claim 3 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Asami renders claims 7 and 13 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Duracell Smart Battery Specification and further in view of Asami renders claims 7 and 13 obvious
`under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ichimura and further in view of Asami renders claims 7 and 13 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ogawa and further in view of Asami renders claims 7 and 13 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Duracell Smart Battery Specification and further in view of Ogawa and Asami renders claims 7 and 13
`obvious under 35 U.S.C. § 103(a).
`
`
`
`
`3
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 5 of 58 PageID #: 12337
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`Alternatively, Flynn in view of Ichimura and further in view of Ogawa and Asami renders claims 7 and 13 obvious under 35 U.S.C.
`§ 103(a).
`
`Alternatively, Flynn in view of Tanaka renders claims 5, 7, 11, and 13 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Duracell Smart Battery Specification and further in view of Tanaka renders claims 5, 7, 11, and 13
`obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ichimura and further in view of Tanaka renders claims 5, 7, 11, and 13 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Flynn in view of Ogawa and further in view of Tanaka renders claims 5, 7, 11, and 13 obvious under 35 U.S.C. § 103(a).
`
`
`U.S. Patent
`No. 6,329,794
`Claim 1
`[1(pre)] An
`information
`processing
`device
`comprising:
`
`Flynn
`
`To the extent the preamble is limiting, Flynn discloses an information processing device, such as battery-powered
`mobile station 100.
`
`
`The present invention provides a method and apparatus for controlling the operations of a battery-
`powered mobile station based on the capacity of its battery. In accordance with the present
`invention, the mobile station monitors the capacity of its battery to determine whether it has fallen
`below any one of a plurality of threshold capacity values. When the capacity of the battery falls
`below the highest of these threshold values, the mobile station sends a registration cancellation
`message to the serving system and then disables the transmit operation in order to conserve power.
`Other operations of the mobile station are systematically disabled if the battery capacity falls
`below one or more lower threshold values.
`
`
`Flynn at Abstract.
`
`
`
`
`4
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 6 of 58 PageID #: 12338
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`U.S. Patent
`No. 6,329,794
`
`Flynn
`
`
`
`
`Flynn at Fig. 4.
`
`
`Referring next to FIG. 4, there is shown a simplified block diagram of a mobile station 100 and a
`smart battery 200 interconnected in accordance with the present invention. The mobile station 100
`comprises a microphone 102, a loudspeaker 104, a keyboard or keypad 106, an alphanumeric or
`graphical display 108, a user interface 110, a microprocessor 112, a memory 114, a radio
`frequency (RF) section 116 and an antenna 118. The user interface 110 includes speech and data
`processing circuitry (not specifically shown) such as a codec for performing analog-to-digital
`(A/D) conversion of a transmit speech signal from the microphone 102 and digital-to-analog (D/A)
`conversion of a received speech signal destined for the loudspeaker 104. The user interface 110
`further includes a digital signal processor (DSP) for performing gain/attenuation, filtering,
`compression/decompression, channel coding/decoding and any other desired processing (e.g., in
`accordance with IS-136) of speech and user or control data.
`5
`
`
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 7 of 58 PageID #: 12339
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`Flynn
`
`U.S. Patent
`No. 6,329,794
`
`[1(a)] at least
`two function
`devices
`equipped with
`independent
`functions
`
`
`
`
`Flynn at 8:13-30.
`
`Flynn discloses this limitation. Flynn discloses at least two function devices equipped with independent functions
`(e.g., cellular call receiving function, cellular call transmitting function, SMS function, lighting function, and
`charging function).
`
`
`The present invention provides a method and apparatus for controlling the operations of a battery-
`powered mobile station based on the capacity of its battery. In accordance with the present
`invention, the mobile station monitors the capacity of its battery to determine whether it has fallen
`below any one of a plurality of threshold capacity values. When the capacity of the battery falls
`below the highest of these threshold values, the mobile station sends a registration cancellation
`message to the serving system and then disables the transmit operation in order to conserve power.
`Other operations of the mobile station are systematically disabled if the battery capacity falls
`below one or more lower threshold values.
`
`
`Flynn at Abstract.
`
`
`The present invention relates to the supervision and control of battery power consumption by a
`mobile station in a wireless communications system, such as a cellular radio system and, more
`particularly, to the management of the operations of such a mobile station based on changes in its
`battery capacity.
`
`Flynn at 1:8-13.
`
`
`Referring next to FIG. 4, there is shown a simplified block diagram of a mobile station 100 and a
`smart battery 200 interconnected in accordance with the present invention. The mobile station 100
`comprises a microphone 102, a loudspeaker 104, a keyboard or keypad 106, an alphanumeric or
`graphical display 108, a user interface 110, a microprocessor 112, a memory 114, a radio
`frequency (RF) section 116 and an antenna 118. The user interface 110 includes speech and data
`processing circuitry (not specifically shown) such as a codec for performing analog-to-digital
`
`6
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 8 of 58 PageID #: 12340
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`U.S. Patent
`No. 6,329,794
`
`Flynn
`(A/D) conversion of a transmit speech signal from the microphone 102 and digital-to-analog (D/A)
`conversion of a received speech signal destined for the loudspeaker 104. The user interface 110
`further includes a digital signal processor (DSP) for performing gain/attenuation, filtering,
`compression/decompression, channel coding/decoding and any other desired processing (e.g., in
`accordance with IS-136) of speech and user or control data.
`
`The RF section 116 includes RF processing circuitry (not specifically shown) such as an RF
`transmitter for modulating the transmit speech or data onto an analog carrier signal, up-
`converting the modulated signal to the selected channel frequency and then filtering, amplifying
`(in a power amplifier) and transmitting the signal through the antenna 116. The RF section 116
`further includes an RF receiver for down-converting a modulated signal received through the
`antenna 118 into an intermediate frequency (IF) signal and then filtering and demodulating the IF
`signal for further processing in the DSP. The microprocessor 112 controls the overall operation
`of the mobile station 100 through software and other information which are stored in the memory
`114, including, for example, software for each of the transmit and receive operations on the digital
`control channel (DCCH) and the digital traffic channel (DTCH) as specified in IS-136.
`
`Flynn at 8:13-46; see also id. at 1:53-63, Fig. 4.
`
`To the extent the construction of the term “function devices” from Maxell Ltd. v. Huawei Device USA Inc., Case
`No. 5:16-cv-00178-RWS, Dkt. No. 175 (E.D. Tex. January 31, 2018), is applicable to this case, the above-cited
`portions of Flynn also disclose this limitation under such construction.
`
`Flynn discloses a power supply circuit (e.g., a smart battery 200—including memory 206, ASIC 204, and power
`cells 202—in communication with external power source 300, current meter 120, and microprocessor 112) for
`supplying power to each function device.
`
`If the claimed “capacity detector for detecting a remaining capacity of said battery” is construed under 35 U.S.C. §
`112(6), the corresponding structure includes any device and/or system capable of detecting the capacity of a battery.
`See, e.g., ’794 Patent at 3:34-35. Flynn’s power supply circuit includes a capacity detector (e.g., current meter 120
`and/or ASIC 204 working in conjunction with microprocessor 112) for detecting a remaining capacity of the battery.
`
`7
`
`[1(b)] a power
`supply circuit
`for supplying
`power to each
`of said function
`devices, said
`power supply
`circuit
`
`
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 9 of 58 PageID #: 12341
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`Flynn
`
`
`If the claimed “controller for controlling operation of said function devices based on said remaining capacity” is
`construed under 35 U.S.C. § 112(6), the corresponding structure includes any device and/or system capable of
`controlling, at the least, operation of the function devices. See, e.g., ’794 Patent at 3:35-38, 4:36-55. Flynn’s
`microprocessor 112 is a controller, as claimed.
`
`
`Referring next to FIG. 4, there is shown a simplified block diagram of a mobile station 100 and a
`smart battery 200 interconnected in accordance with the present invention. The mobile station 100
`comprises a microphone 102, a loudspeaker 104, a keyboard or keypad 106, an alphanumeric or
`graphical display 108, a user interface 110, a microprocessor 112, a memory 114, a radio
`frequency (RF) section 116 and an antenna 118.
`
`
`Flynn at 8:13-30; see also id. at Fig. 4.
`
`
`With continuing reference to FIG. 4, the smart battery 200 includes a plurality of chemical cells
`202 for generating electrical current, an application specific integrated circuit (ASIC) 204 for
`managing the operations of the battery 200 and a non-volatile memory 206 for storing information
`about the operation of the battery.…
`
`In the preferred embodiment of the present invention, the ASIC 204 communicates with the
`microprocessor 112 in accordance with the Smart Battery Data Specification which has been
`jointly developed by Duracell Corporation and Intel Corporation ("Duracell/Intel Smart Battery
`Data Specification," Revision 1.0, Feb. 15, 1995). As shown in FIGS. 6A-B, this data specification
`supports a plurality of different commands (messages) which a host device (here, the
`microprocessor 112) can send to a smart battery (here, the smart battery 200) in order to read
`data from, or write data to, the smart battery. For example, the host device can issue the command
`REMAINING CAPACITY ALARM to set or read a capacity threshold value below which the smart
`battery will begin to send intermittent alarm messages to the host device. Similarly, the host device
`can issue the command TEMPERATURE, VOLTAGE or CURRENT to retrieve the internal
`temperature, present voltage or input/output current, respectively, of the smart battery. The host
`
`8
`
`U.S. Patent
`No. 6,329,794
`including a
`battery, a
`capacity
`detector for
`detecting a
`remaining
`capacity of said
`battery, and a
`controller for
`controlling
`operation of
`said function
`devices based
`on said
`remaining
`capacity;
`
`
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 10 of 58 PageID #: 12342
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`U.S. Patent
`No. 6,329,794
`
`Flynn
`device can also use the commands REMAINING CAPACITY and DESIGN CAPACITY to read the
`remaining capacity and design capacity, respectively, of the smart battery.
`
`In other embodiments of the present invention and at different times, the mobile station 100 may
`be connected to a "semi-smart" battery or a "dumb" battery (instead of the smart battery 200). For
`purposes of the present description, the "semi-smart" battery is a battery which includes the cells
`202 and the memory 206 but not the ASIC 204. In this case, the microprocessor 112 communicates
`directly with the memory 206 and can read from, or write data to, the memory 206 using
`conventional microprocessor-memory interface messages (rather than, for example, the set of
`messages defined in the Duracell/Intel Smart Battery Data Specification). The "dumb" battery, on
`the other hand, is a standard battery with no artificial intelligence, that is, it includes only the cells
`202 but not the ASIC 204 or the memory 206. In this other case, the microprocessor 112 will be
`unable to exchange messages or information with the dumb battery.
`
`The present invention allows the microprocessor 112 to control the operations of the mobile station
`100 based on the present battery capacity as compared with one or more predetermined capacity
`levels below which certain mobile station operations should be progressively reduced or disabled.
`For a smart battery according to the Duracell/Intel specification, the microprocessor 112 can
`obtain the present capacity value directly from the smart battery 200 by using the REMAINING
`CAPACITY message (see FIG. 6B). For a semi-smart battery, however, the battery may be initially
`conditioned, that is, completely discharged and then fully recharged from an external power source
`300 (FIG. 4), with the rate of charge (capacity increase) being measured by the microprocessor
`112 using, for example, a current shunt from the external power source 300 to a current meter 120
`in the mobile station 100 (FIG. 4). In this manner, the microprocessor 112 can use the
`measurements recorded by the current meter 120 to obtain a reliable starting present capacity
`value (for the fully charged semi-smart battery) which will be stored in the memory 206 of the
`semi-smart battery as shown in FIG. 7. Thereafter, as current is consumed from the semi-smart
`battery, the microprocessor 112 will periodically update the present capacity value in the memory
`206 to reflect the rate of discharge (capacity decrease) as the mobile station 100 operates in one
`of the three possible modes. For example, every 500 ms the microprocessor 112 can subtract from
`the present capacity value the amount of current consumption during the last 500 ms as
`
`9
`
`
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 11 of 58 PageID #: 12343
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`U.S. Patent
`No. 6,329,794
`
`Flynn
`represented by the normalized value 500×R/3,600,000, where R is the current consumption rate
`in mAH for the present mode of operation as shown in FIG. 5. On the other hand, when the semi-
`smart battery is recharged from the external power source 300, the microprocessor 112 will
`monitor the capacity increase with the current meter 120 and reinitialize the present capacity value
`as described above.
`
`
`Flynn at 9:19-10:42.
`
`Flynn expressly identifies the Duracell Smart Battery Specification as being one of the preferred embodiments of
`the smart battery. See Flynn at 9:36-57. Therefore, the Duracell Smart Battery Specification is incorporated by
`reference into the disclosure of Flynn.
`
`As expressly identified by Flynn, the Duracell Smart Battery Specification discloses a capacity detector—e.g., a
`Duracell/Intell compliant smart battery using the “RemainingCapacityAlarm()” function call of the Smart Battery
`Interface:
`
`
`5.1.2. RemainingCapacityAlarm() (0x01)
`
`Description:
`Sets or gets the Low Capacity threshold value. Whenever the RemainingCapacity() falls below the
`Low Capacity value, the Smart Battery sends AlarmWarning() messages to the SMBus Host with
`the REMAINING_CAPACITY_ALARM bit set. A Low Capacity value of 0 disables this alarm. The
`Low Capacity value is set to 10% of design capacity at time of manufacture. The Low Capacity
`value will remain unchanged until altered by the RemainingCapacityAlarm() function. The Low
`Capacity value may be expressed in either current (ma) or power (10mwH) depending on the
`setting of the BatteryMode()'s CAPACITY_MODE bit (see BatteryMode()).
`
`Purpose:
`The RemainingCapacityAlarm() function can be used by systems that know how much power they
`will require to save their operating state. It enables those systems to more finely control the point
`
`10
`
`
`
`

`

`
`
`
`Units:
`Range:
`Granularity:
`Accuracy
`
`Battery Mode
`CAPACITY_MODE bit = 0
`CAPACITY_MODE bit = 1
`maH @ C/5
`10mwH @ P/5
`0 to 65,535 maH
`0 to 65,535 10mwH
`not applicable
`
`see RemainingCapacity()
`
`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 12 of 58 PageID #: 12344
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`U.S. Patent
`No. 6,329,794
`
`Flynn
`at which they transition into suspend or hibernate state. The Low Capacity value can be read to
`verify the value in use by the Smart Battery's Low Capacity alarm.
`SMBus Protocol: Read or Write Word
`Input/Output: unsigned int -- value below which Low Capacity messages will be sent
`
`
`
`Duracell Smart Battery Specification at p. 8.
`
`Additionally or alternatively, it would have been obvious to a PHOSITA to modify Flynn’s capacity detector to
`include the RemainingCapacityAlarm() function of the Smart Battery Interface as taught by the Duracell Smart
`Battery Specification. A PHOSITA would have been motivated to combine the Duracell Smart Battery Specification
`with Flynn’s system to enhance the battery capacity detection capabilities of the battery powered mobile station, as
`taught by the Duracell Smart Battery Specification. Flynn expressly teaches this combination. See, e.g., Flynn at
`9:18-11:5 and Figs. 6A-6B. Such a combination of prior art elements according to known methods would have
`yielded predictable results thereby improving similar set-top boxes in the same way with a reasonable expectation
`of success.
`
`Alternatively, Ichimura discloses a capacity detector (e.g., a residual battery capacity sensor 105).
`
`
`
`
`11
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 13 of 58 PageID #: 12345
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`U.S. Patent
`No. 6,329,794
`
`
`
`12
`
`Flynn
`
`
`
`Reference will first be made to FIG. 1 to describe the configuration of a battery-powered system
`having a communications function and an additional function, besides the communications
`function, according to an embodiment of the present invention. The system comprises a CPU 101,
`a communications unit 102, an additional function unit 103, a battery unit 104, a residual battery
`energy sensor 105, a secondary-battery charging controller 106, a time setting unit 107, a
`communications unit power-consumption setting unit 108, an additional function unit power-
`consumption setting unit 109, a timekeeping unit 110, a memory unit 111 and indicator 112.
`
`Ichimura at Fig. 1.
`
`
`
`Ichimura at 2:48-61.
`
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 14 of 58 PageID #: 12346
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`U.S. Patent
`No. 6,329,794
`
`Flynn
`The battery unit 104 is the power supply for the overall system and comprises a primary battery (a
`dry cell or the like) or a secondary battery (a lead storage battery, alkaline storage battery, etc.).
`The residual battery energy sensor 105 senses the residual energy of the battery unit 104 and
`notifies the CPU 101. If the battery unit 104 is a secondary battery, the secondary-battery charging
`controller 106 controls the charging of the secondary battery. The time setting unit 107 sets the
`time until which it is desired for the communications unit 102 to be usable. According to this
`embodiment, the time setting unit 107 is constructed as an independent functional block. However,
`the invention is not limited to this arrangement and it is permissible for the time setting unit 107 to
`be included in the communications unit 102.
`
`
`Ichimura at 3:9-22.
`
`It would have been obvious to a PHOSITA to modify Flynn’s device to include a residual battery capacity detector,
`as taught by Ichimura. Flynn teaches a smart battery 200, a current meter 120, and a microprocessor 112 each
`combining separate functionality to determine the residual capacity in the battery. See, e.g., Flynn at 9:19-57, 12:43-
`15:37 (describing battery capacity reading functions among various embodiments with “smart,” “semi-smart,” and
`“dumb” battery alternatives). A PHOSITA would have been motivated to implement Ichimura’s capacity detector
`in addition to or in substitution of Flynn’s capacity detector to yield the predictable result of determining a capacity
`or residual amount of a battery. Such a combination of prior art elements according to known methods would have
`yielded predictable results with a reasonable expectation of success.
`
`Flynn discloses the capacity detector detects at least two different remaining battery capacities (e.g., the low, critical,
`and dead capacity values).
`
`
`In the preferred embodiment of the present invention, three different threshold capacity values are
`defined in the following descending order: low capacity, critical capacity and dead capacity
`(hereinafter collectively referred to as the "alarm" capacity values). The first value, low capacity,
`designates the minimum capacity level for maintaining normal mobile station operations. The
`second value, critical capacity, designates the capacity level at which certain high current-
`consuming operations or components such the power amplifier, display and lighting subsystems
`or the temperature control oscillator (TCXO) can no longer be sustained. Finally, the third value,
`
`13
`
`[1(c)(i)]
`wherein when
`said capacity
`detector detects
`remaining
`battery
`capacities NA
`and NB (where
`NA>NB),
`
`
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 15 of 58 PageID #: 12347
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`U.S. Patent
`No. 6,329,794
`
`Flynn
`dead capacity, designates the capacity level at which almost no mobile station operations (even
`low current consumers) can be supported. At this level, the charging operation may be the only
`operation which is allowed to proceed.
`
`Flynn at 11:6-21.
`
`
`The present invention allows the microprocessor 112 to control the operations of the mobile station
`100 based on the present battery capacity as compared with one or more predetermined capacity
`levels below which certain mobile station operations should be progressively reduced or disabled.
`For a smart battery according to the Duracell/Intel specification, the microprocessor 112 can
`obtain the present capacity value directly from the smart battery 200 by using the REMAINING
`CAPACITY message (see FIG. 6B). For a semi-smart battery, however, the battery may be initially
`conditioned, that is, completely discharged and then fully recharged from an external power source
`300 (FIG. 4), with the rate of charge (capacity increase) being measured by the microprocessor
`112 using, for example, a current shunt from the external power source 300 to a current meter 120
`in the mobile station 100 (FIG. 4). In this manner, the microprocessor 112 can use the
`measurements recorded by the current meter 120 to obtain a reliable starting present capacity
`value (for the fully charged semi-smart battery) which will be stored in the memory 206 of the
`semi-smart battery as shown in FIG. 7. Thereafter, as current is consumed from the semi-smart
`battery, the microprocessor 112 will periodically update the present capacity value in the memory
`206 to reflect the rate of discharge (capacity decrease) as the mobile station 100 operates in one
`of the three possible modes. For example, every 500 ms the microprocessor 112 can subtract from
`the present capacity value the amount of current consumption during the last 500 ms as
`represented by the normalized value 500×R/3,600,000, where R is the current consumption rate
`in mAH for the present mode of operation as shown in FIG. 5. On the other hand, when the semi-
`smart battery is recharged from the external power source 300, the microprocessor 112 will
`monitor the capacity increase with the current meter 120 and reinitialize the present capacity value
`as described above.
`
`
`Flynn at 10:8-42.
`
`
`14
`
`
`
`

`

`Case 5:19-cv-00036-RWS Document 348-8 Filed 06/18/20 Page 16 of 58 PageID #: 12348
`Defendant’s Invalidity Contentions
`Exhibit G3
`
`
`U.S. Patent
`No. 6,329,794
`[1(c)(ii)] said
`controller
`sends a power
`consumption
`reduction
`instruction to
`each function
`device included
`in a set GA if
`NA is detected,
`
`Flynn
`Flynn discloses the controller sends a power consumption reduction instruction to each function device included in
`a set GA if NA is detected (e.g., microprocessor 112 sends a registration cancellation message to the base station,
`and the microprocessor 112 disables at least the transmission of cellular calls, upon the battery capacity falling
`below the low capacity value).
`
`In the preferred embodiment of the present invention, the microprocessor 112 takes one or more
`selected actions when the present capacity value reaches the low, critical and dead capacity values,
`respectively. Thus, if the present capacity value falls below the low capacity value, the
`microprocessor 112 will generate an audible and/or visual alarm to the user via the loudspeaker
`104 and/or the display 108. The alarm would warn the user of a low battery condition and
`optionally provide the user with an indication that, at this battery level, ongoing telephone calls or
`other activities of interest can be only sustained for an enumerated period of time. Furthermore,
`once the low capacity value is reached, the microprocessor 112 immediately sends a registration
`cancellation message to the serving base station so as to prevent the system from directing any
`incoming calls to the mobile station 100. This avoids the risk of the mobile station 100 receiving
`and processing a page message from the system and, in the process, discharging the battery 200
`to the point where all desired operations will cease. The registration cancellation message also
`allows the system to mark the mobile station 100 as being presently unavailable for telephon