Case 6:21-cv-00755-ADA Document 70-15 Filed 06/10/22 Page 1 of 2
`Case 6:21-cv-00755-ADA Document 70-15 Filed 06/10/22 Page 1 of 2
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`EXHIBIT AAA
`EXHIBIT AAA
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`Case 6:21-cv-00755-ADA Document 70-15 Filed 06/10/22 Page 2 of 2
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`Exhibit A-14
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`Invalidity of U.S. Patent No. 6,757,068 (“’068 Patent”)1 under Pre-AIA Section 102 or Section 103 in view of
`Virtual Vision’s Head Mounted Displays (“Virtual Vision’s HMD”)2
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`Virtual Vision’s HMD was publicly available at least as of 1999. Plaintiffs assert a priority date of January 28, 2000 for the ’068 Patent.
`Even assuming that the ’068 Patent is entitled to this priority date, Virtual Vision’s HMD qualifies as prior art under at least pre-AIA Section
`102(a) to the ’068 Patent.
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`As described herein, the asserted claims of the ’068 Patent are invalid (a) under one or more sections of 35 U.S.C. § 102 as anticipated
`expressly or inherently by Virtual Vision’s HMD and (b) under 35 U.S.C. § 103 as obvious in view of Virtual Vision’s HMD standing alone
`and, additionally, in combination with the knowledge of one of ordinary skill in the art, and/or other prior art, including but not limited to the
`prior art identified in Defendants’ Invalidity Contentions and the prior art described in the claim charts attached in Exhibits A-1 – A-27. With
`respect to the proposed modifications to Virtual Vision’s HMD, as of the priority date of the ’068 Patent, such modification would have been
`obvious to try, an obvious combination of prior art elements according to known methods to yield predictable results, a simple substitution of
`one known element for another to obtain predictable results, a use of known techniques to improve a similar devices or method in the same
`way, an application of a known technique to a known device or method ready for improvement to yield predictable results, a variation of a
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`1 Discovery in this case is ongoing and, accordingly, this invalidity chart is not to be considered final. Defendants have conducted the invalidity analysis herein without
`having fully undergone claim construction and a Markman hearing. By charting the prior art against the claim(s) herein, Defendants are not admitting nor agreeing to
`Plaintiffs’ interpretation of the claims at issue in this case. Additionally, these charts provide representative examples of portions of the charted references that disclose
`the indicated limitations under Plaintiffs’ application of the claims; additional portions of these references other than the representative examples provided herein may
`also disclose the indicated limitation(s) and Defendants contend that the asserted claim(s) are invalid in light of the charted reference(s) as a whole. Defendants reserve
`the right to rely on additional citations or sources of evidence that also may be applicable, or that may become applicable in light of claim construction, changes in
`Plaintiffs’ infringement contentions, and/or information obtained during discovery as the case progresses. Further, by submitting these invalidity contentions,
`Defendants do not waive and hereby expressly reserve their right to raise other invalidity defenses, including but not limited to defenses under Sections 101 and 112.
`Defendants reserve the right to amend or supplement this claim chart at a later date, including after the Court’s order construing disputed claim terms.
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`2 The claim limitations described herein were disclosed by Virtual Vision’s HMD as of the earliest priority date of the ’068 Patent. For instance: Virtual Vision, Fed
`Corporation/Virtual Vision, Inc. Demo SVGA Headset Monitor at DisplaySearch / EBN Industry Conference (Mar. 8, 1999),
`https://web.archive.org/web/20000309122559/http://www.virtualvision.com/ (“VV Ex. 1.”); Virtual Vision, Fed Corp. Reveals Use of Virtual VIsion, Inc. Display in
`Godzilla Movie (May 18, 1998), https://web.archive.org/web/20000309122559/http://www.virtualvision.com/ (“VV Ex. 2.”); Virtual Vision, Virtual Vision
`Incorporated Corporate Overview (1999), https://web.archive.org/web/20000309122559/http://www.virtualvision.com/ (“VV Ex. 3.”); Virtual Vision, Virtual Vision
`Inc., Demonstrates Prototype Personal Information Display (PID TM) Headset Systems (May 19, 1998),
`https://web.archive.org/web/20000309122559/http://www.virtualvision.com/ (“VV Ex. 4.”); Virtual Vision, Eglass Frequently Asked Questions (1999)
`https://web.archive.org/web/20000309122559/http://www.virtualvision.com/ (“VV Ex. 5.”); Virtual Vision, Virtual Vision’s Eglass TM Preliminary Specifications
`(2000), https://web.archive.org/web/20000309122559/http://www.virtualvision.com/ (“VV Ex. 6.”); Virtual Vision, Fed Corporation Announces Acquistion of
`Virtual Vision, Inc. from Telxon Corporation (Apr. 27, 1998), https://web.archive.org/web/20000309122559/http://www.virtualvision.com/ (“VV Ex. 7.”); David
`Lieberman, Wearable Monitor’s 1-inch LCOS Display Turns Heads, EE TIMES ONLINE (Mar. 12, 1999),
`https://web.archive.org/web/20000309122559/http://www.virtualvision.com/ (“VV Ex. 8.”); W. R. Sherman & A. B. Craig, Boeing Wire Bundles, An Augmented
`Reality Application, in UNDERSTANDING VIRTUAL REALITY 513–520 (2003) (“VV Ex. 9.”).
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