Case 6:21-cv-00755-ADA Document 45-7 Filed 02/28/22 Page 1 of 79
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` Exhibit 7
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`Case 6:21-cv-00755-ADA Document 45-7 Filed 02/28/22 Page 2 of 79
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`GENTEX CORPORATION and INDIGO
`TECHNOLOGIES, LLC,
`
`
`Plaintiffs,
`
`THALES VISIONIX, INC.,
`
`
`Involuntary Plaintiff,
`
`
`v.
`
`Case No. 6:21-cv-00755-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`FACEBOOK, INC. and FACEBOOK
`TECHNOLOGIES, LLC,
`
`
`Defendants.
`
`
`
`
`
`DECLARATION OF DR. AARON BOBICK IN SUPPORT OF DEFENDANTS’
`OPENING CLAIM CONSTRUCTION BRIEF
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`

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`Case 6:21-cv-00755-ADA Document 45-7 Filed 02/28/22 Page 3 of 79
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`I.
`II.
`III.
`IV.
`V.
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`TABLE OF CONTENTS
`Background ....................................................................................................................... 1
`Qualifications..................................................................................................................... 2
`Legal Standards ................................................................................................................ 3
`Level of Ordinary Skill in the Art ................................................................................... 5
`The Asserted Patents And Technology Background ..................................................... 5
`A.
`Overview of the Asserted Patents ........................................................................... 5
`1.
`The Family One Patents .............................................................................. 6
`2.
`The Family Two Patents ............................................................................. 7
`VI. Claim Terms In Dispute ................................................................................................... 8
`A.
`Family One Patents (’068 and ’684 Patents) .......................................................... 8
`1.
`“track a position of a first localized feature” .............................................. 8
`2.
`“redisplaying the first object at a second position on the display
`device determined based on the change in the position of the first
`localized feature” ...................................................................................... 14
`Family Two Patents (’632 and ’253 Patents) ........................................................ 17
`1.
`“[expected] / [highest expected]” .............................................................. 17
`2.
`“[characterizes] / [characterizing]” ........................................................... 21
`3.
`“generating a sequence of candidates of pairs of sensing elements
`selected from the set of sensing elements, the sequence based on an
`expected utility of a measurement associated with said elements to
`the estimation subsystem”......................................................................... 28
`Means-Plus-Function Terms ................................................................................. 29
`1.
`“estimation module” ................................................................................. 29
`2.
`“estimation subsystem” ............................................................................. 35
`3.
`“sensor module(s)” .................................................................................... 42
`4.
`“sensor subsystem” ................................................................................... 48
`5.
`“data processing module” ......................................................................... 51
`
`B.
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`C.
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`i
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`Case 6:21-cv-00755-ADA Document 45-7 Filed 02/28/22 Page 4 of 79
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`I.
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`BACKGROUND
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`1.
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`My name is Dr. Aaron Bobick. I am Dean of the School of the James McKelvey
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`Engineering at Washington University in St. Louis and have worked within the Computer
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`Vision industry for more than 30 years.
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`2.
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`I have been retained as an expert in this case by Defendants Facebook, Inc.1 and
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`Facebook Technologies, LLC (collectively “Defendants”) to provide opinions in connection
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`with U.S. Patent Nos. 6,757,068 (the “’068 patent”), 7,301,648 (the “’648 patent”), 8,224,024
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`(the “’024 patent”), 6,922,632 (the “’632 patent”), and 7,725,253 (the “’253 patent”). I
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`understand these patents have been asserted in a lawsuit by Plaintiffs Gentex Corporation
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`(“Gentex”) and Indigo Technologies, LLC (“Indigo”) along with involuntary plaintiff Thales
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`Visionix, Inc. (“Thales”) (collectively, “Plaintiffs”) against Defendants. In my declaration, I
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`will refer to them as the “Asserted Patents.”
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`3.
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`I was asked to consider the meaning of certain terms of the Asserted Patents,
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`including:
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`• “track a position of a first localized feature”
`• “redisplaying the first object at a second position on the display device determined
`based on the change in the position of the first localized feature”
`• “expected” / “highest expected”
`• “characterizes” / “characterizing”
`• “generating a sequence of candidates of pairs of sensing elements selected from
`the set of sensing elements, the sequence based on an expected utility of a
`measurement associated with said elements to the estimation subsystem”
`• “sensor module(s)”
`• “sensor subsystem”
`
`
`1 I understand that effective October 28, 2021, defendant Facebook, Inc. changed its name to
`Meta Platforms, Inc..
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`1
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`Case 6:21-cv-00755-ADA Document 45-7 Filed 02/28/22 Page 5 of 79
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`• “estimation module”
`• “estimation subsystem”
`• “data processing module”
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`4.
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`I have considered these terms as well as certain surrounding language that the
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`parties have identified for construction.
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`II.
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`QUALIFICATIONS
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`5.
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`My educational background, professional achievements, and qualifications as a
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`Computer Scientist and as an expert in interactive computing, computer graphics, computer
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`vision and related technologies are detailed in my curriculum vitae, which is attached hereto as
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`Attachment 1.
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`6.
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`I earned BS degrees in both Computer Science and Mathematics in 1981 and a
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`PhD in Cognitive Science in 1987, all from the Massachusetts Institute of Technology (MIT). I
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`am currently Dean of the James McKelvey School of Engineering at Washington University in
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`St. Louis. Prior to accepting this position, I was the founding Chair of the School of Interactive
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`Computing in the College of Computing of the Georgia Institute of Technology (often called
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`“Georgia Tech”) where I had also served as Director of the Graphics, Visualization and
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`Usability Center. Before joining Georgia Institute of Technology, I served on the faculty of the
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`MIT Media Laboratory.
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`7.
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`Over the last twenty-five years, I have been an active researcher in interactive
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`computing, computer graphics, computer vision and related technologies. I have authored over
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`100 book chapters, journal and conference papers, and technical reports in these areas as
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`detailed in Attachment 1. I have served on the program committee and as an area chair for
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`most of the premier computer vision conferences in the world including serving as Program Co-
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`Chair of the IEEE Computer Vision and Pattern Recognition conference, the premier computer
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`2
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`vision conference in North America. In 2014, I was elected Fellow of the IEEE for my
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`contributions in computer vision. I have taught both undergraduate and graduate courses on
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`multiple subjects including computer vision, interactive virtual environments, and mathematical
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`models for computational perception, at MIT and at the Georgia Institute of Technology.
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`8.
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`My full curriculum vitae in Attachment 1 also includes a list of all of the cases
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`in which I have provided testimony at a hearing or deposition as an expert witness in the past
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`five years.
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`9.
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`In researching my opinions in this declaration, I considered the Asserted Patents,
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`their prosecution histories, the parties’ proposed claim constructions for certain terms in these
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`patents; and all the documents cited in this declaration, as well as my expertise and experience.
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`I am being compensated for my time at my standard hourly consulting rate of $550 per hour.
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`My compensation does not depend on the outcome of this litigation or the opinions I form.
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`III. LEGAL STANDARDS
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`10.
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`Although I am not an attorney, I have been provided with an understanding of
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`certain legal principles relevant to my analysis and opinions in this matter.
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`11.
`
`I understand that a person of ordinary skill in the art (a “POSITA”) is a
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`hypothetical person who is presumed to have known the relevant art at the time of the invention,
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`and that the factors that may be considered in determining the level of ordinary skill in the art
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`may include: (a) type of problems encountered in the art; (b) prior art solutions to those
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`problems; (c) rapidity with which innovations are made; (d) sophistication of the technology;
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`and (e) educational level of active workers in the field. In a given case, every factor may not be
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`present, and one or more factors may predominate. I also understand that the hypothetical
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`person having ordinary skill in the art to which the claimed subject matter pertains would, of
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`necessity, have the capability of understanding the scientific and engineering principles
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`applicable to the pertinent art, and moreover, is a person of ordinary creativity, not an
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`“automaton.”
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`12.
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`I have been informed that patent claims are construed or interpreted from the
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`perspective of a POSITA at the time of the claimed invention. I understand that the most
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`important evidence to consider in construing the claims is the “intrinsic” record. This includes
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`the claim language, the patent’s specification, and the prosecution history. I understand that the
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`POSITA must read the claim terms in the context of the claim and in the context of the entire
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`patent specification. I understand that the patentee may explicitly define a claim term if it differs
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`from the plain and ordinary meaning in the art.
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`13.
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`I further understand that a POSITA may also consider “extrinsic” evidence when
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`interpreting the meaning of claim terms, which are documents and testimony beyond the patent
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`to ensure that a claim is construed consistently with the understanding of those of skill in the
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`art at the time of the claimed invention. I also understand that extrinsic evidence may not be
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`relied on if it deviates from the meaning of the claim provided by the intrinsic evidence.
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`14.
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`I further understand that inventors may draft their claims as a means or step for
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`performing a specified function, but that they must also disclose in the specification the structure
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`that performs the function, or that claim is indefinite. I also understand that there is a
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`presumption that claims are not written in “means-plus-function” format when the word
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`“means” does not appear, but that presumption can be overcome whenever the claim term fails
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`to recite sufficiently definite structure or else recites a function without reciting sufficient
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`structure for performing that function. I also understand that construing a means-plus-function
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`claim requires identifying the claimed function and determining what structure, if any, disclosed
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`in the specification corresponds to the claimed function. I further understand that a term with a
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`computer-implemented function must have a clearly linked structure in the form of an
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`algorithm. I understand that if I cannot identify such an algorithm, the term lacks a clearly linked
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`structure and is therefore indefinite. I further understand that a general purpose computer cannot
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`be the structure for a computer-implemented function because this amounts to purely functional
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`claiming.
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`IV.
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`LEVEL OF ORDINARY SKILL IN THE ART
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`15.
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`In my opinion, a POSITA at the time of the alleged invention described in the
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`Asserted Patents would have had at least a Bachelor’s degree in Computer Science, or an
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`equivalent field, and three to five years of experience working with computer implemented
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`tracking systems. Additional education might compensate for less experience, and vice-versa.
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`Under this definition, I qualified as a person of ordinary skill in the art at the time of the
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`invention.
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`16.
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`I have applied this level of ordinary skill in the art for purposes of this
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`declaration.
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`V.
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`THE ASSERTED PATENTS AND TECHNOLOGY BACKGROUND
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`A.
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`Overview of the Asserted Patents
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`17.
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`The Asserted Patents generally fall into three families: the ’068 and ’648 Patents
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`(“Family One”), the ’632 and ’253 Patents (“Family Two”), and the ’024 Patent (“Family
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`Three”). Within each family, the claims in the Asserted Patents overlap significantly and share
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`largely identical specifications and figures. Defendants allege that the Family One patents have
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`the same priority date of January 28, 2000, the Family Two patents have the same priority date
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`of August 9, 2002, and the single Family Three patent has a priority date of October 4, 2005.
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`Plaintiffs allege that the Family Two patents are entitled to an earlier priority date of June 13,
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`2001, and the single Family Three patent is entitled to an earlier priority date of July 14, 2005.
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`Based on the information currently available to me, my opinions herein would remain the same
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`regardless of which of these priority dates applies.
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`1.
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`The Family One Patents
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`18.
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`The ’068 and ’648 Patents relate to position and/or orientation tracking. See ’068
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`Patent, 1:10-15, 1:36–42. Specifically, the ’068 and ’648 Patents relate to methods and systems
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`for tracking the position of a user’s limb relative to the orientation of a user’s head. Id., 1:46–
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`52. To this end, the ’068 and ’648 Patents discuss mounting an orientation tracker on a user’s
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`head and using another tracker to track the “position of a first localized feature associated with
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`a limb” and tracking the feature relative to the user’s head. Id., 1:46–57, cls. 1, 40, 54–56. The
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`patents state that in one aspect “[t]he localized feature associated with the limb may include a
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`hand-held object or a hand-mounted object or a point on a hand” but do not otherwise define,
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`and do not ever provide any objective bounds for, when a feature is “localized” or when it is
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`“associated with a limb” (an arm or a leg). The ’068 and ’648 Patents also describe mounting a
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`display device on the user’s head to display a tracked virtual object or virtual environment. See
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`id., 2:9–23, cl. 14; ’648 Patent, cls. 2, 17, 20.
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`19.
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`The ’068 and ’648 Patents relate to a “tracking technique that is “essentially
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`‘sourceless’ in that it can be used anywhere with no set-up of a source, yet it enables a wider
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`range of virtual environment-style navigation and interaction techniques than does a simple
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`head-orientation tracker, including manual interaction with virtual objects.” See ’068 Patent,
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`1:36–42. For instance, the ’068 and ’648 Patents disclose FIG. 1 (below), described as a “simple
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`and easy to don” hardware system including “a wearable computer 10, a headset 15 with
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`integrated tracking system, and a hand-mounted beacon 14.” Id., 5:13-17, Fig. 1. An “ultrasonic
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`receiver system 12 for tracking the beacon [14]” includes “a few small signal-conditioning
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`circuits and [is] integrated with the sourceless orientation tracker 30 in the head-worn display
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`15.” Id., 5:17–25. In general, the patent relates to visualization of and interaction with a virtual
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`environment using a wearable system in arbitrary unprepared environments.
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`’068 Patent, Fig. 1.
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`20.
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`Because the Family One Patents contain substantially the same disclosures, I
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`will cite to the ’068 Patent when referencing portions of the Family One specifications that are
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`
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`the same in both the ’068 and ’648 Patents.
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`2.
`
`The Family Two Patents
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`21.
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`The ’632 and ’253 Patents relate to estimating an object’s position and/or
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`orientation based on measurement information from sensors. See ’632 Patent, 1:17–20, 1:64–
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`67. These sensors may include “inside-out” sensors, which are “fixed to the object and makes
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`measurements with respect to a target fixed to an environment,” or “outside-in” sensors, which
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`are “fixed to the environment and makes measurements with respect to a target fixed to the
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`object.” Id., 7:35–39. The targets can be specially mounted (e.g., LEDs) or features of the
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`natural environment. Id., 1:54–59 (“If a complete map of the terrain is not available in advance,
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`the robot may observe landmarks, build a map based on the landmark observations, and
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`determine its location on the map that it has constructed so far. The landmarks may be man-
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`made markers or natural features of the terrain.”). To perform the calculation, the ’632 and ’253
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`Patents describe using an “estimation subsystem” that configures an estimation algorithm called
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`a “Kalman filter” to “estimate the sensor calibration parameters using a common infrastructure,”
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`which can be used to determine, for example, the location of a vehicle as it navigates an
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`environment outfitted with sensors. Id., 2:11–13, 10:21–22, cls. 52–58.
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`22.
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`Because the Family Two Patents contain substantially the same disclosures, I
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`will cite to the ’632 Patent when referencing portions of the Family One specifications that are
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`the same in both the ’632 and ’253 Patents.
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`VI. CLAIM TERMS IN DISPUTE
`
`A.
`
`1.
`
`Family One Patents (’068 and ’684 Patents)
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`“track a position of a first localized feature”
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`Defendants’
`Construction
`Indefinite
`
`Patents and Claims
`
`Term
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`’068 Patent, claims 1, 54,
`55
`
`’648 Patent, claim 1
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`Defendants:
`“track a position
`of a first
`localized feature”
`
`Plaintiffs: “track a
`position of a first
`localized feature
`associated with a
`limb of the user”
`
`
`Plaintiffs’
`Construction
`“Plain and ordinary
`meaning, in light of
`the claim and
`specification—i.e.,
`track a position of a
`first part of a limb
`of a user, or an
`object or part of an
`object associated
`with a limb of the
`user”
`
`23.
`
`I understand that the parties dispute the construction of the term “track a position
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`8
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`Case 6:21-cv-00755-ADA Document 45-7 Filed 02/28/22 Page 12 of 79
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`of a first localized feature.” Defendants propose that the term is indefinite. Plaintiffs propose
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`that the longer term “track a position of a first localized feature associated with a limb of the
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`user” should be given its plain and ordinary meaning, which they contend is “track a position
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`of a first part of a limb of a user, or an object or part of an object associated with a limb of the
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`user.”
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`24.
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`I understand that a term is indefinite if it fails to inform a POSITA of the scope
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`of the invention with reasonable certainty, even when the term is read in light of the
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`specification and the prosecution history.
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`25.
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`In my opinion, based on the claims and the specification of the ’068 and ’648
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`Patents, a POSITA would not have understood the scope of the term “track a position of a first
`
`localized feature,” or the longer phrase “track a position of a first localized feature associated with
`
`a limb of the user” for at least the following reasons.
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`26.
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`First, “localized” is not a well-defined term in the field of computer vision. There
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`is no commonly used or understood numerical range, i.e., within a certain distance of a known
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`position, that qualifies something as “localized.” Additionally, in the field of computer vision,
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`“localized” can, depending on the usage and context, refer to a position in a two-dimensional
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`image or a three dimensional world. A POSITA would have had to rely on the ’068 and ’684
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`Patents themselves to understand the meaning of “localized.”
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`27.
`
`A POSITA reading the ’068 and ’684 Patents would have expected a description
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`of what it means for a feature to be “localized.” But the ’068 and ’684 Patents do not provide
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`even the most basic information about the term “localized,” including some acceptable range
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`or degree of allowed uncertainty. For example, no actual algorithm or rules are disclosed in the
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`claims or the specification. A POSITA would, therefore, not be informed of the scope of
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`“localized” with reasonable certainty.
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`28.
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`Second, a POSITA would not have understood what it means to “track[] the
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`position of a first localized feature.” It is unclear whether the claim term refers to the two-
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`dimensional position of the “localized feature” on some image sensor or the three-dimensional
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`position of the “localized feature” in the world. Moreover, the claim confusingly refers to
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`tracking the “position” of a “localized” feature even though the use of the past tense in the term
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`“localized” implies that some undefined aspect of the feature’s position or locality has already
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`been tracked or determined in some undefined manner.
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`29.
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`And third, the addition of the rest of the phrase that Plaintiffs allege needs
`
`construction, i.e., “track a position of a first localized feature associated with a limb of the user”
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`does not clarify the claim’s scope. To the contrary, the phrase merely exacerbates the problem
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`by indicating that the term “localized” means something different than the feature merely being
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`“associated with” a limb. And, as with the term “localized,” the phrase “associated with” in the
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`context of the claim is vague and does not provide a POSITA with a reasonable certainty about
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`the claim’s scope. The Family One specifications state that in one aspect “[t]he localized feature
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`associated with the limb may include a hand-held object or a hand-mounted object or a point
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`on a hand” and provides an example of a user “holding a hand-held object 516, in this case a
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`tennis racquet.” ’068 Patent, 1:47-52, 14:9–10; see also Fig. 5 (below).
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`
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`But the specifications do not explain or define, and do not ever provide any objective bounds
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`for determining, when or how a feature (such as a tennis racket) “associated with the limb” has
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`become “localized” or by what objective criteria one might know whether and when such a
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`feature has become “localized.” The specification’s examples do not provide clarity as to what
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`might be encompassed within the scope of the terms “localized” or “associated with the limb of
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`the user.” For example, it is not clear whether for a “feature associated with the limb of user”
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`to be deemed “localized,” it must have been determined to be physically a part of the user’s arm
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`(or leg), held in the user’s hand, affixed to the user’s arm or hand or leg or foot, near to the
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`user’s arm or hand or leg or foot—and if so, how near—such that the feature has both become
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`“localized” and is also “associated with the limb of the user.” One example is an object that is
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`connected to the user’s limb in some non-rigid way, like a dog that the user is walking at the
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`end of a leash. One end of the leash (in the user’s hand) could be “associated with the limb of a
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`user” but it is not possible to assess whether the other end of the leash, or the dog’s collar, or
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`the dog, or any part of the dog are “localized” without some guidelines as to, among other
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`things, whether “localized” is a measure of proximity and, if so, the acceptable range of
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`proximity. For example, one feature on such a handheld object, such as a dog on a leash, might
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`be considered “localized” under some numerical range but not “localized” under a different
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`range, which exemplifies the lack of clarity as to the scope of “a first localized feature associated
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`with a limb of the user.”
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`30.
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`For example, an AR designer might want to design a system where some object
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`is rendered such that it appears to be affixed to the head of a dog the user is walking. Assume
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`the system tracks the head of the dog. The dog is attached to a leash held by one of the user’s
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`hands. In this scenario, it would be unclear whether or not tracking the point (or points) on the
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`dog practices a “first localized feature associated with a limb of a user.” The designer of this
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`system would not know whether or not the system would infringe the claim element that recites
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`“track a position of a first localized feature” or even the longer phrase “track a position of a first
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`localized feature associated with a limb of the user.” Moreover, what if the designer wished to
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`perform tracking without any of the supposedly infringing localization? How would a designer
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`that tracks a “feature associated with the limb of the user” know whether or not that feature was
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`also “localized”? For example, a POSITA would not understand how close an item must be to
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`a user’s limb to be “associated with a limb of a user” when it is in fact not physically attached
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`to the user (or whether it even is “localized” if it is not physically attached to the user). Consider
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`dribbling a basketball where the ball intermittently is in contact with the user’s hand. Or even
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`more extreme, a user kicking a soccer ball or throwing a football each which are momentarily
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`physically in contact with the user’s hand. A POSITA would not understand how close that
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`object must be to the user such that it is still a “localized feature,” and the patent provides no
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`definition or explanation by which a designer could make that determination.
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`31.
`
`Plaintiffs’ proposed extrinsic evidence does not shed light on the scope of the
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`term “localized” or “localized feature associated with a limb of the user.” For example,
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`Plaintiffs cite “Vision for Mobile Robots” by M. Brady (“Brady”), which describes computing
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`“localized feature points” in an image. Ex. 8 (GNTX0001630). As a preliminary matter, Brady
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`confines “localized” to points which have a position in the 3D world and which are located in
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`an image—a meaningful distinction that the ’068 and ’684 Patents do not make. The ’068 and
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`’684 Patents do not provide such limiting definition, nor do they describe or even suggest
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`feature localization based on known forms of image or pattern recognition. Interpreting
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`“localized feature” as Brady’s “localized feature points” in the context of image or pattern
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`recognition would not be consistent with the specifications of the ’068 and ’684 Patents for at
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`least two reasons. First, the “localized feature” in the ’068 and ’684 Patents is “associated with
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`a limb of the user,” not an image. Second, the Brady reference specifically discusses computing
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`localized feature points in images. The ’068 and ’684 Patents, in contrast, do not provide any
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`explanation of what “localized” even means, let alone any indication of how any points
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`“associated with a limb of the user” would (or could) become “localized.” At best, the patents
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`provide examples of where a point “associated with a limb of a user” could be (e.g., somewhere
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`on a hand or hand-held object) but they provide no objective bounds or definition for
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`determining whether and when any such point has become “localized.”
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`32.
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`The additional reference cited by Plaintiffs (“Duell”) suffers from similar
`
`problems because it also describes selecting specific “localized features” to be “design[ing] a
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`correlation filter based on the local feature of [a given] window size and shape that maximizes
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`average relative discrimination” such that the specific objects can be detected in an image. Ex.
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`9 (GNTX0001617) at -1619. But the ’068 and ’684 Patents provide no such detail, which
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`according to Duell, must be carried out and tested with various training sets for each type of
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`recognizable image or feature. See generally GNTX0001617. Duell also calls his own proposed
`
`
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`13
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`Case 6:21-cv-00755-ADA Document 45-7 Filed 02/28/22 Page 17 of 79
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`“general localized feature selection” “suboptimal” (id. at GNTX0001625) and admits that a
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`“selection process that remains to be solved is how to design local feature correlation filters that
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`are invariant to such things as rotation and scale changes” (id. at GNT0001628)—a problem the
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`’068 and ’684 Patent specifications also fail to address.
`
`33.
`
`Thus, in my opinion, both proposed terms “track a position of a first localized
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`feature” and “track a position of a first localized feature associated with a limb of the user” are
`
`indefinite in the context of the ’068 and ’648 Patent claims.
`
`2.
`
` “redisplaying the first object at a second position on the display
`device determined based on the change in the position of the first
`localized feature”
`
`Term
`“redisplaying the first object
`at a second position on the
`display device determined
`based on the change in the
`position of the first localized
`feature”
`
`’068 Patent, claim 26
`
`Defendants’ Construction Plaintiffs’ Construction
`Indefinite
`Plain and ordinary meaning,
`in light of the claim and
`specification.
`
`
`
`34.
`
`I understand that the parties dispute the construction of the term “redisplaying
`
`the first object at a second position on the display device determined based on the change in the
`
`position of the first localized feature” as it appears in claim 26 of the ’068 Patent. Defendants
`
`propose that this term is indefinite. Plaintiffs propose that the term should be given its plain and
`
`ordinary meaning. But Plaintiffs provide no explanation or definition for what any such plain
`
`and ordinary meaning is or how it could be discerned from the patent specification.
`
`35.
`
`I understand that a term is indefinite if it fails to inform a POSITA of the scope
`
`of the invention with reasonable certainty, even when the term is read in light of the
`
`specification and the prosecution history.
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`
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`Case 6:21-cv-00755-ADA Document 45-7 Filed 02/28/22 Page 18 of 79
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`36.
`
`I also understand that a dependent claim includes all of the elements in the
`
`independent claim, or claims, from which the claim depends.
`
`37.
`
`In my opinion, based on the claims and the specification of the ’068 Patent, a
`
`POSITA would not have understood the scope of claim 26 because the term “redisplaying the
`
`first object at a second position on the display device determined based on the change in the
`
`position of the first localized feature” is in conflict with a similar limitation in claim 15, from
`
`which claim 26 depends.
`
`38.
`
`Claim 26 depends from claims 16, 15, 14, and 1. Each of these claims are
`
`reproduced below, with emphasis added to the relevant claim limitations.
`
`Claim 1. A method comprising:
`
`mounting a sourceless orientation tracker on a user’s head, and
`
`using a position tracker to track a position of a first localized feature associated
`
`with a limb of the user relative to the user's head.
`Claim 14. The method of claim 1, further comprising:
`
`mounting a display device on the user’s head; and
`
`displaying a first object at a first position on the display device.
`
`Claim 15. The method of claim 14, further comprising:
`
`changing the orientation of the display device; and
`
`after changing the orientation of the display device, redisplaying the first
`
`object at a second position on the display device based on the change
`in orientation.
`
`
`Claim 16. The method of claim 15,
`
`wherein the second position is determined so as to make the position of the
`first object appear to be fixed relative to a first coordinate reference frame,
`which frame does not rotate with the display device during said changing of the
`orientation of the display device.
`
`Claim 26. The method of claim 16, further comprising:
`
`changing the position of the first localized feature relative to the position
`tracker; and
`
`after changing the position of the first localized feature, redisplaying the first
`
`object at a second position on the display device determined
`based on the change in the position of the first localized feature.
`
`
`39.
`
`Claim 15 requires