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17 PO Response to Pet: Patent Owner Response

Document IPR2024-00294, No. 17 PO Response to Pet - Patent Owner Response (P.T.A.B. Oct. 10, 2024)
... injured persons in dangerous scenarios wear a Sensor Module and a Receiver Module, and each Receiver Module transmits measurements to the PDA carried by a medic. The medic uses their PDA to remotely monitor multiple injured ...
Further, even if D’Angelo were prior art, there are many reasons why a POSITA would not have been motivated to use the medic’s PDA to power and “read out” measured data from one injured person’s Receiver Module after its battery ...
... three wirelessly connected components: (1) a “Sensor Module” worn by on each injured person’s forehead; (2) a “Receiver Module” worn on each injured person’s body; and (3) one PDA used by a medic to remotely monitor the injured ...
Further, Apple’s proposed modification assumes that the medic would use the PDA to power the Receiver Module attached to an injured person, upon reaching that person in the field.
A POSITA would have understood that if the medic went to the injured person, he or she would not have used Mendelson’s PDA to power the Receiver Module because there would no longer be a need to remotely monitor that person.
... person right in front of them using typical medical equipment such as a finger-clip pulse oximeter or stethoscope, and applied the emergency medical care deemed necessary. Id. And if the person’s injuries warranted monitoring after ...
A POSITA would have understood that the medic was not using the PDA as intended (i.e., monitoring “multiple” injured people at the same time) whenever the medic had to use the PDA to read out one injured person’s Receiver Module, ...
... Relatedly, if the medic was using the PDA-turned-wristwatch to power and read out data from one injured person’s Receiver Module as Apple proposes, the medic would not be using the PDA-turned-wristwatch to monitor “multiple” injured ...
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39 Other Hearing transcript: Other Hearing transcript

Document IPR2023-01237, No. 39 Other Hearing transcript - Other Hearing transcript (P.T.A.B. Jan. 29, 2025)
... the left the petition notes that a person of skill in the art would take that instruction that we just saw to go look at other layouts in similar systems. And in the portion on the right the Petitioner and Petitioner’s expert talk about how a person ...
Federal Circuit in the ICON Health & Fitness case has talked about how when you have equipment of different sizes in two different references, that doesn’t mean that a person of skill in the art 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 IPR2023-01236 Patent 10,815,188 B2 IPR2023-01237 Patent 9,586,805 B1 IPR2023-01238 Patent 10,974,955 B2 wouldn’t be able to figure ...
They just point them out and say that a person of skill in the art seeing this blocked storage area wouldn’t look at it anymore. But we know from the case law that’s not what a person of skill in the art would do.
... on Slide 35, sorry, getting a little further with that, just showing Petitioner’s expert actually did do weighing, and noted that these elements in Cable are simple aisle walkways, known elements to persons of skill in the art. And that a person ...
You can see the photo on the right, which is from Exhibit 2012 where there are safety concerns that can result in some pretty serious incidents, fires, personal injuries, and that type of thing.
And that’s I think what we’re advocating for here is that there’s so much at stake with fires that can occur and personnel that can become injured that it’s certainly something that would be taken into consideration.
A person of ordinary skill in the art would conclude that the use of brass in refueling is really just a serious risk. And again, with fires and personal injury at stake there’s really no reason to take that kind of risk.
There are some pretty serious consequences that can happen in the face of refueling problems, fires, personal injury and there's no reason why one of ordinary skill in the art would take the risk of using a brass fitting or an AFLA seal that ...
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41 Other Hearing transcript: Other Hearing transcript

Document IPR2023-01236, No. 41 Other Hearing transcript - Other Hearing transcript (P.T.A.B. Jan. 29, 2025)
... the left the petition notes that a person of skill in the art would take that instruction that we just saw to go look at other layouts in similar systems. And in the portion on the right the Petitioner and Petitioner’s expert talk about how a person ...
Federal Circuit in the ICON Health & Fitness case has talked about how when you have equipment of different sizes in two different references, that doesn’t mean that a person of skill in the art 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 IPR2023-01236 Patent 10,815,188 B2 IPR2023-01237 Patent 9,586,805 B1 IPR2023-01238 Patent 10,974,955 B2 wouldn’t be able to figure ...
They just point them out and say that a person of skill in the art seeing this blocked storage area wouldn’t look at it anymore. But we know from the case law that’s not what a person of skill in the art would do.
... on Slide 35, sorry, getting a little further with that, just showing Petitioner’s expert actually did do weighing, and noted that these elements in Cable are simple aisle walkways, known elements to persons of skill in the art. And that a person ...
You can see the photo on the right, which is from Exhibit 2012 where there are safety concerns that can result in some pretty serious incidents, fires, personal injuries, and that type of thing.
And that’s I think what we’re advocating for here is that there’s so much at stake with fires that can occur and personnel that can become injured that it’s certainly something that would be taken into consideration.
A person of ordinary skill in the art would conclude that the use of brass in refueling is really just a serious risk. And again, with fires and personal injury at stake there’s really no reason to take that kind of risk.
There are some pretty serious consequences that can happen in the face of refueling problems, fires, personal injury and there's no reason why one of ordinary skill in the art would take the risk of using a brass fitting or an AFLA seal that ...
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1002 Exhibit: Ex 1002 2 No Title Spreadsheet of Prior Expert Cases

Document IPR2024-01380, No. 1002-3 Exhibit - Ex 1002 2 No Title Spreadsheet of Prior Expert Cases (P.T.A.B. Sep. 6, 2024)
... CENTRAL DISTRICT OF CALIFORNIA Western Division - Los Angeles / International Trade Commission, Washington, D.C. Plaintiff Number 13-36-BLG- RFC 150900684 Date 2014 2016 4:16-cv-01153 2017 Type Patent Personal Injury ...
... Florida In The Superior Court of Troup County State of Georgia 2019-CA- 000579-AX 2021 18-CV-0079 2022 Personal Injury Personal Injury Zapata v Republic Services, Inc.
Christy Sahlstrom v The Greenery Nursery Kiera Hynes v Buck Institute Apparatus and Systems for Air Borne Cleaning of Surfaces Macy v Ray Lovato Recycling Center Trevor Horlacher v Heavy Equipment Solutions LLC Plaintiff Benchmark Case No. 222671 BMA Case No. 222671 2022 Personal Injury Defendant United States International Trade Commission, Washington, D.C. Inv. No. 337- TA-1304 2022 Patent Plaintiff In the Circuit Court of La Crosse County State of Wisconsin 21-CV-206 2022 Defendant United ...
... County, Illinois County Department Law Division Case No. CJ- 2021-153 2024 Personal Injury Case No. 9:22- cv-81726 Civil Action No. 2:18-cv- 00551-RJS- PMW No. 21 L 007107 2024 Patent 2024 Trade Secret 2024 Personal Injury
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1002 Exhibit: Ex 1002 2 Expert Report Cases No Title Just Table

Document IPR2024-01381, No. 1002-3 Exhibit - Ex 1002 2 Expert Report Cases No Title Just Table (P.T.A.B. Sep. 6, 2024)
... CENTRAL DISTRICT OF CALIFORNIA Western Division - Los Angeles / International Trade Commission, Washington, D.C. Plaintiff Number 13-36-BLG- RFC 150900684 Date 2014 2016 4:16-cv-01153 2017 Type Patent Personal Injury ...
... Florida In The Superior Court of Troup County State of Georgia 2019-CA- 000579-AX 2021 18-CV-0079 2022 Personal Injury Personal Injury Zapata v Republic Services, Inc.
Christy Sahlstrom v The Greenery Nursery Kiera Hynes v Buck Institute Apparatus and Systems for Air Borne Cleaning of Surfaces Macy v Ray Lovato Recycling Center Trevor Horlacher v Heavy Equipment Solutions LLC Plaintiff Benchmark Case No. 222671 BMA Case No. 222671 2022 Personal Injury Defendant United States International Trade Commission, Washington, D.C. Inv. No. 337- TA-1304 2022 Patent Plaintiff In the Circuit Court of La Crosse County State of Wisconsin 21-CV-206 2022 Defendant United ...
... County, Illinois County Department Law Division Case No. CJ- 2021-153 2024 Personal Injury Case No. 9:22- cv-81726 Civil Action No. 2:18-cv- 00551-RJS- PMW No. 21 L 007107 2024 Patent 2024 Trade Secret 2024 Personal Injury
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30 Pet Reply to PO Resp: Petitioners Reply to Patent Owners Response

Document IPR2024-00294, No. 30 Pet Reply to PO Resp - Petitioners Reply to Patent Owners Response (P.T.A.B. Jan. 13, 2025)

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2037 Exhibit: October 10, 2024 Expert Declaration of R James Duckworth, PhD

Document IPR2024-00294, No. 2037 Exhibit - October 10, 2024 Expert Declaration of R James Duckworth, PhD (P.T.A.B. Oct. 10, 2024)

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1004 Exhibit: Ex No 1004

Document IPR2025-00110, No. 1004 Exhibit - Ex No 1004 (P.T.A.B. Jan. 15, 2025)

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