UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`RPX CORPORATION
`Petitioner
`
`v.
`
`SOCKEYE LICENSING TX LLC
`Patent Owner
`____________
`
`U.S. Patent No. 8,879,987 B1
`Issued: November 4, 2014
`Application No.: 13/418,829
`Filed: March 13, 2012
`Title: System, Method And Apparatus For
`Using A Wireless Device To Control Other Devices
`____________
`
`
`
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT 8,879,987 B1
`
`
`
`

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`Case IPR2016-00985
`Patent 8,879,987
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`
`
`TABLE OF CONTENTS
`
`Petition
`
`Page
`
`I. MANDATORY NOTICES ............................................................................. 1
`A.
`Real Party-In-Interest ............................................................................ 1
`B.
`Related Matters ...................................................................................... 1
`C.
`Lead Counsel, Back-Up Counsel, And Service Information ................ 2
`SECTION 42.104(a) CERTIFICATION ......................................................... 2
`II.
`III. PRELIMINARY STATEMENT ..................................................................... 2
`IV. SUMMARY OF PRECISE RELIEF REQUESTED ...................................... 3
`V.
`THE ’987 PATENT ......................................................................................... 4
`A.
`Claims .................................................................................................... 4
`B.
`The Patent’s Admissions About The Prior Art ..................................... 4
`VI. CLAIM CONSTRUCTION ............................................................................ 5
`A.
`Person Of Ordinary Skill In The Art ..................................................... 5
`B.
`Broadest Reasonable Interpretation ...................................................... 5
`VII. GROUND 1: CLAIMS 20-29, 31-37, 40-45 ARE
`OBVIOUS UNDER 35 U.S.C. § 103 OVER SOIN AND WANG ................ 8
`A.
`Soin ........................................................................................................ 8
`B. Wang ...................................................................................................... 9
`C. Motivation To Combine Soin And Wang ........................................... 10
`E.
`Dependent Claims 21-29, 31 Are Obvious Over Soin And Wang ..... 20
`F.
`Independent Claims 32, 40 And Dependent Claims
`33-37, 39 And 41-45, 47 Are Obvious Over Soin And Wang ............ 31
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`Case IPR2016-00985
`Patent 8,879,987
`VIII. GROUND 2: CLAIMS 20-23, 25-29, 37, 40-44 ARE
`OBVIOUS UNDER 35 U.S.C. § 103 OVER TEE AND ACHARYA ......... 34
`A.
`Tee ....................................................................................................... 34
`B. Acharya................................................................................................ 35
`C. Motivation To Combine Tee And Acharya ........................................ 35
`E.
`Dependent Claims 21-23, 25-29, 31
`Are Obvious Over Tee And Acharya .................................................. 45
`Claim 25 Is Obvious Over Tee And Acharya ..................................... 47
`Independent Claim 40 And Dependent
`Claims 41-45, 47 Are Obvious Over Tee And Acharya ..................... 53
`IX. GROUND 3: CLAIMS 24 AND 32-37, 39 ARE OBVIOUS
`UNDER 35 U.S.C. § 103 OVER TEE, ACHARYA, AND BENCO ........... 55
`A.
`Benco ................................................................................................... 55
`B. Motivation To Combine Tee, Acharya, And Benco ........................... 55
`C. Dependent Claim 24 Is Obvious Over Tee, Acharya, And Benco ..... 57
`D.
`Independent Claim 32 And Dependent
`Claims 33-37, 39 Are Obvious Over Tee, Acharya, And Benco ........ 57
`CONCLUSION .............................................................................................. 59
`
`F.
`G.
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`X.
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`Case IPR2016-00985
`Patent 8,879,987
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`
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`TABLE OF AUTHORITIES
`
`Petition
`
`Page(s)
`
`Cases
`Ex Parte Nehls,
`88 USPQ2d 1883 (BPAI 2008) ............................................................... 16, 18, 20
`In re Fox,
`471 F.2d 1405 (CCPA 1973) ..................................................................... 4, 19, 44
`Statutes
`35 U.S.C. § 102 ................................................................................................ passim
`35 U.S.C. § 103 ................................................................................................ passim
`37 C.F.R. § 42.100 ..................................................................................................... 5
`37 C.F.R. § 42.104 ..................................................................................................... 4
`37 C.F.R. § 42.15 ....................................................................................................... 1
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`Case IPR2016-00985
`Patent 8,879,987
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`Petition
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`LIST OF EXHIBITS
`
`1001
`
`1002
`
`1003
`
`1004
`
`Ex. No. Description / Date
`Michael D. Harold, U.S. Patent No. 8,879,987, System, Method And
`Apparatus For Using A Wireless Device To Control Other Devices,
`issued November 4, 2014 (“’987 Patent”)
`Lai King Tee et al., U.S. Patent Application Publication No.
`2006/0203758 A1, filed September 27, 2005, published September 14,
`2006 (“Tee”)
`Shrikant Acharya et al., U.S. Patent Application Publication No.
`2005/0036509 A1, filed June 2, 2004, published February 17, 2005
`(“Acharya”)
`Ravipal Soin et al., U.S. Patent Application Publication No.
`2005/0091359 A1, filed February 25, 2004, published April 28, 2005
`(“Soin”)
`Tiejun Ronald Wang et al., U.S. Patent Application Publication No.
`2006/0077310 A1, filed June 24, 2005, published April 13, 2006
`(“Wang”)
`David S. Benco et al., U.S. Patent Application Publication No.
`2005/0135393 A1, filed December 19, 2003, published June 23, 2005
`(“Benco”)
`1007 Applicant’s Response to Office Action During Prosecution of ’342
`Patent, filed May 31, 2011
`1008 Declaration of Peter Rysavy (“Rysavy Decl.”), signed and dated April
`30, 2016
`Random House Webster’s Computer & Internet Dictionary (2000)
`(excerpts)
`
`1005
`
`1006
`
`1009
`
`iv
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`Petitioner RPX Corporation (“RPX”) respectfully requests inter partes
`
`
`
`Petition
`
`review of claims 20-29, 31-37, 39-45, and 47 of U.S. Patent No. 8,879,987 (“’987
`
`patent”). The Director is hereby authorized to charge deposit account no. 02-4550
`
`for the fee specified by 37 C.F.R. § 42.15, along with any additional fees required.
`
`I. MANDATORY NOTICES
`A. Real Party-In-Interest
`RPX is the sole real party-in-interest in this proceeding. RPX has not
`
`communicated with any client about its intent to contest the validity of the ’987
`
`patent, the preparation of this petition, or the filing of this petition. RPX has
`
`complete control over all aspects of this proceeding and is responsible for all costs
`
`and expenses associated with this proceeding.
`
`B. Related Matters
`The ’342 patent is at issue in five pending lawsuits filed against Wildcat
`
`Licensing LLC et al in the Northern District of Illinois by TCT Mobile, Inc. (1-15-
`
`cv-10058); Lenovo (United States) Inc. (1-15-cv-09729); Best Buy Stores, LP (1-
`
`15-cv-09625); Sony Electronics Inc. et al (1-15-cv-09628); Hewlett-Packard
`
`Company (1-15-cv-09341). Currently-pending U.S. Patent Appl. No. 14/531,641
`
`claims priority to the ’987 patent. This Petition is being filed concurrently with a
`
`petition for inter partes review of related U.S. Patent No. 8,135,342.
`
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`C. Lead Counsel, Back-Up Counsel, And Service Information
`Andrew M. Mason (Lead) andrew.mason@klarquist.com, Reg. No. 64,034,
`
`Petition
`
`
`
`John D. Vandenberg (Back-up), john.vandenberg@klarquist.com, Reg. No.
`
`31,312. Petitioner intends to request pro hac vice admission for Jeffrey S. Love
`
`(Back-up), jeffrey.love@klarquist.com. Klarquist Sparkman, LLP, 121 SW
`
`Salmon St., Ste. 1600, Portland, Oregon 97204, telephone (503) 595-5300, fax
`
`(503) 595-5301. Petitioner consents to electronic service.
`
`II.
`
`SECTION 42.104(a) CERTIFICATION
`RPX certifies that the ’987 patent is available for inter partes review and
`
`RPX is not barred or estopped from requesting an inter partes review challenging
`
`the patent claims on the grounds identified in this petition.
`
`III. PRELIMINARY STATEMENT
`The ’987 patent relates to use of a wireless communications device (e.g., a
`
`cell phone) to control and provide network connectivity to standard desktop
`
`peripherals (e.g., a monitor and keyboard). E.g., Abstract. The primary goal?
`
`Allow users to “access any browser-based web site or software application using
`
`the desktop monitor, keyboard, mouse, speakers and printer,” with the wireless
`
`device providing an Internet connection. ’987 patent 3:8-31, Abstract.
`
`The ’987 Patent admits that the prior art included “using a wireless cell
`
`phone device as a computer,” but asserts that the prior art fails to connect a cell
`
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`phone to a larger display and keyboard. Id. at 2:20-26. This is incorrect. As shown
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`Petition
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`
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`below, cell phones were connected to desktop monitors, keyboards, and other
`
`devices, e.g., through docking stations and other hub systems by 2005, before the
`
`’987 patent’s claimed priority date of September 15, 2006. Rysavy Decl. ¶¶ 20-22.
`
`This Petition relies on two distinct base grounds of obviousness:
`
`(i) Soin and Wang and (ii) Tee and Acharya. The primary references, Soin and
`
`Tee, are not cumulative at least because: Soin discloses broadly applicable
`
`technologies whereas Tee focuses more narrowly on mobile terminals (as reflected
`
`in Soin’s classification by the USPTO in a “Computer Network Managing”
`
`subclass and Tee’s classification under a “Repeater” subclass); Soin is prior art
`
`under 35 U.S.C. § 102(b), whereas Tee is prior art under §§ 102(a), (e); and they
`
`combine with different secondary references to render the challenged claims
`
`obvious.
`
`IV. SUMMARY OF PRECISE RELIEF REQUESTED
`RPX requests review of the following claims on the listed grounds:
`
`
`
`Reference(s)
`
`Basis
`
`Claims
`
`Ground 1 Soin (Ex. 1004) and Wang (Ex. 1005)
`
`35 U.S.C.
`§ 103
`Ground 2 Tee (Ex. 1002) and Acharya (Ex. 1003) 35 U.S.C.
`§ 103
`35 U.S.C.
`§ 103
`
`Ground 3 Tee, Acharya, and Benco (Ex. 1006)
`
`20-29, 31-37,
`39-45, 47
`20-23, 25-29,
`31, 40-45, 47
`24, 32-37, 39
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`Sections VII-IX below provide the required statements of precise relief
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`Petition
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`requested for each claim challenged, per 37 C.F.R. § 42.104(b).
`
`For the reasons set forth herein, there is at least a reasonable likelihood that
`
`petitioner will prevail with respect to at least one of the challenged claims.
`
`V. THE ’987 PATENT
`A. Claims
`Of the challenged claims, independent claim 20, and its dependents 21-29
`
`and 31, are representative. Independent claims 32 and 40, and their corresponding
`
`dependent claims (33-37, 39 and 41-45, 47, respectively) recite elements nearly
`
`identical to those in claims 20-29 and 31. Rysavy Decl. ¶ 48 (side-by-side chart).
`
`B.
`The Patent’s Admissions About The Prior Art
`The ’987 patent contains admissions relevant to the patentability analysis.
`
`Although all challenged claims include a multi-user aspect (e.g., “two users
`
`interconnect to said peripheral device”), the ’987 patent provides few details on the
`
`technical implementation of such multi-user embodiments, devoting just two
`
`sentences and one figure to the topic. The patent’s lack of detail on these claim
`
`elements indicates that a skilled artisan would have readily known how to
`
`implement such features. In re Fox, 471 F.2d 1405, 1407 (CCPA 1973) (claim
`
`elements not described in detail in the specification are presumed known to a
`
`POSITA); Rysavy Decl. ¶¶ 41, 54, 90.
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`VI. CLAIM CONSTRUCTION
`A.
`Person Of Ordinary Skill In The Art
`The person of ordinary skill in the art in September 2006 (“skilled artisan”)
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`Petition
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`would have had a bachelor’s degree in computer science, computer engineering,
`
`and/or electrical engineering and at least 1-2 years of communications and/or
`
`network engineering experience, including experience with wired and wireless
`
`networks, local- and wide-area networks, and interconnection of various user
`
`devices through these types of networks. Rysavy Decl. ¶¶ 30-33.
`
`B.
`Broadest Reasonable Interpretation
`The challenged claims are given their broadest reasonable interpretation
`
`(“BRI”) in light of the specification. 37 C.F.R. § 42.100(b). RPX proposes the
`
`following claim constructions, which would be the same under the Phillips
`
`standard. Each of these constructions is pertinent because the prior art discloses
`
`the elements of the constructions proposed below.
`
`“user information” (claims 20, 25, 31-33, 39-41, 47): “user information”
`
`can be documents, applications, songs, and/or movies, as the patent describes these
`
`as examples of “user information.” ’987 patent 12:65-13:2; Rysavy Decl. ¶ 37.
`
`“operates said peripheral device from said wireless device” (claims 20,
`
`32, 40): This term includes both (i) using a wireless device to navigate through
`
`user information, a website or other media, play a game, or access media, which is
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`displayed on a peripheral device; and (ii) using the wireless device to directly
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`control peripheral devices, in the context of a traditional desktop computing
`
`environment. Rysavy Decl. ¶ 30.
`
`Outside the claims, the ’987 patent does not discuss “operating” a peripheral
`
`device, but the specification describes two analogous concepts: One, a user
`
`“control[ling] various peripheral devices,” e.g., to “navigate through the user
`
`information, a website or other media, play a game or access media,” ’987 patent
`
`13:52-60; and two, a “wireless cell phone device … made to operate as a
`
`traditional desktop computing environment, i.e., one having a full-sized computer
`
`screen, keyboard, mouse, printer and speakers.” Id. at 6:22-26; see also Rysavy
`
`Decl. ¶ 38.
`
`The parent patent ’342 file history emphasizes the “desktop computing
`
`environment,” created by “a cell phone or like PDA, through connectivity to the
`
`peripheral components of a desktop computer or electronic system, to create a
`
`media center controlled by the user through the cell phone.” Ex. 1007 at 9 (May
`
`31, 2011 OA Response); id. at 10 (discussing how “peripheral components of the
`
`claimed invention … constitute ‘dumb’ devices, such as speakers, monitors,
`
`displays, keyboards, a computer mouse, and other separate and peripheral devices,
`
`all of which are directly controlled by the cell phone or PDA, which acts as the
`
`‘CPU.’”).
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`“two users interconnect to said peripheral device, said two users
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`Petition
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`controlling said user information” (claims 20, 32, 40): The patent gives only
`
`passing mention to multi-user scenarios, with gaming as a non-limiting example.
`
`’987 patent 14:50-56 (“[T]wo or more individuals may desire to attach to the same
`
`device or devices 502, e.g., in a gaming environment.”). The ’987 patent depicts
`
`an exemplary multi-user environment in Fig. 4, but does not describe whether both
`
`wireless devices (401 and 402) are connected to the peripheral device (502)
`
`simultaneously or one at a time. A skilled artisan reading this language, either
`
`alone or in the context of the ’987 description and figures, would understand it to
`
`encompass both simultaneous and one-at-a-time connection and control. Rysavy
`
`Decl. ¶ 41. Moreover, “simultaneous” does not appear in this claim, although
`
`Patent Owner used a similar term to limit other claims. E.g., ’987 claim 5
`
`(“simultaneously”). Given the specification’s lack of a limiting definition, and the
`
`claims’ lack of any language indicating simultaneity, this term encompasses both
`
`scenarios (i) when the two users connect and control simultaneously and (ii) when
`
`they do so one at a time, such as when passing control of a presentation among
`
`different users, each at their own device.
`
`“operates as a computer server” (claims 28, 36, 44): Outside the claims,
`
`the ’987 patent uses the term “server” only four times, none in the context of a
`
`wireless device “operat[ing] as a computer server.” ’987 patent 1:43; 13:2; 13:37;
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`14:25. Accordingly, this term should be construed consistent with its plain
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`Petition
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`meaning, which includes providing data to other devices. Rysavy Decl. ¶ 42; Ex.
`
`1009.
`
`“said user information is employed in a manner that uniquely associates
`
`the user information with one or more peripheral devices” (claims 31, 39, 47):
`
`Outside the claims, the ’987 patent does not discuss uniquely associating user
`
`information with peripheral devices, or even use the term “unique” or “uniquely.”
`
`The ‘987 patent does disclose user information being transmitted to specific
`
`peripheral device(s) selected by the user. See, e.g., ‘987 patent, 3:54-60 (“…
`
`specify the devices to which the wireless cell phone will connect …”).
`
`Accordingly, this term should be construed as encompassing any action that
`
`associates the user information with one or more specific peripheral devices,
`
`including selecting specific peripheral devices to which the user information
`
`should be transmitted by the wireless device. Rysavy Decl ¶ 43-45.
`
`VII. GROUND 1: CLAIMS 20-29, 31-37, 40-45 ARE
`OBVIOUS UNDER 35 U.S.C. § 103 OVER SOIN AND WANG
`A.
`Soin
`Soin published April 28, 2005, and is prior art under § 102(b). Soin
`
`describes systems and methods for providing content to an alternate display device
`
`from different wireless computing devices, such as handheld or laptop devices.
`
`Soin, Abstract & ¶¶ 44, 91. Soin also describes how the wireless devices connect
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`to the Internet, “which provides an infrastructure for widely distributed
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`Petition
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`computing.” Soin ¶ 37; see also id. ¶ 69 (“Individuals and business users alike are
`
`provided with a seamlessly interoperable and Web-enabled interface for
`
`applications and computing devices, making computing activities increasingly
`
`Web browser or network-oriented.”). Thus, the systems and methods in Soin
`
`allowed multiple users on multiple devices to download content from Web servers
`
`through Web-enabled applications, and then control display of that content on
`
`alternate display devices, such as projectors or laptops. Rysavy Decl. ¶¶ 95-120.
`
`B. Wang
`Wang published April 13, 2006, from an application filed June 24, 2005, and
`
`is prior art under at least §§ 102(a) and 102(e).
`
`Wang describes how a “video
`
`signal” or other “multimedia data
`
`stream” from a “wireless communication
`
`network” is received at a mobile
`
`terminal, converted, and then provided
`
`to an alternate display terminal, either
`
`wirelessly or over a wired connection.
`
`Wang, Abstract; Fig. 1.
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`C. Motivation To Combine Soin And Wang
`One of ordinary skill in the art would have been motivated to combine the
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`
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`Petition
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`teachings of Soin with the relevant teachings of Wang discussed below. Rysavy
`
`Decl. ¶¶ 121-122. Both Soin and Wang address communicating multimedia data
`
`from a network server through a portable device to peripheral devices, such as
`
`displays. Soin does not teach use of a docking station or hub within its system;
`
`however, docking stations were well-known. Rysavy Decl. ¶ 122. For example,
`
`Wang teaches such a device in the form of a mobile terminal signal conversion
`
`module (MTSCM). Wang ¶ 29. Wang also explains the benefits of using such
`
`devices in systems like that disclosed in Soin. Wang ¶¶ 44-51. For example,
`
`Wang explains how an MTSCM “provides the flexibility of allowing any standard
`
`mobile terminal and/or display to be potentially interface [sic] with the MTSCM
`
`without imposing constraints on the mobile terminal or external display terminal
`
`manufacturers.” Wang ¶ 51 (noting that this requires additional hardware). A
`
`skilled artisan would be motivated to improve Soin by incorporating features of
`
`Wang, such as the MTSCM device. A skilled artisan would have recognized that
`
`the MTSCM could be incorporated into the Soin system as a peripheral device hub
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`that could, in turn, connect to other peripheral devices, such as a display, as taught
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`Petition
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`
`
`in Wang. Wang ¶¶ 32-34, Rysavy Decl. ¶ 122.
`
`In addition to the increased device flexibility offered by Wang’s MTSCM
`
`device, this improvement would be wholly compatible with the Soin system, and
`
`there would be no technological hurdles to implementing this device as such
`
`peripheral hub devices were common by 2006. Rysavy Decl. ¶ 120
`
`D.
`Independent Claim 20 Is Obvious Over Soin And Wang
`Claim 20
`Soin and Wang
`20.1 A wireless
`“[T]he invention applies to any device wherein it may be
`desirable to wirelessly project content from one computing
`device for
`device to the display of another computing device. … It
`facilitating user
`should be understood, therefore, that handheld, portable and
`connectivity
`other computing devices and computing objects of all kinds
`comprising:
`are contemplated for use in connection with the present
`invention, i.e., anywhere that a device may wish to wirelessly
`deliver content to an alternate display.” Soin ¶ 58.
`“The present invention may apply to an environment with
`server computers and client computers deployed in a network
`environment or distributed computing environment, having
`remote or local storage.” Soin ¶ 33. “In a network
`environment in which the communications network/bus 14 is
`the Internet, for example, the servers 10 a, 10 b, etc. can be
`Web servers with which the clients 110 a, 110 b, 110 c, 110 d,
`110 e, etc. communicate via any of a number of known
`protocols such as HTTP.” Soin ¶ 44. “When used in a LAN
`networking environment, the computer 110 is connected to the
`LAN 171 through a network interface or adapter 170. When
`used in a WAN networking environment, the computer 110
`typically includes a modem 172 or other means for
`establishing communications over the WAN 173, such as the
`Internet. The modem 172, which may be internal or external
`… ” Soin ¶ 56. Rysavy Decl. ¶ 177.
`
`20.2 a
`connector, said
`connector
`connecting a
`user of said
`wireless device
`to a remote
`server
`containing user
`information
`therein;
`
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`Soin describes “computing devices,” including “a gaming console, handheld
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`Petition
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`computer, portable computer, etc., whether wired or wireless.” Soin ¶ 181; see
`
`also id. ¶¶ 3-4, Fig. 2A, ¶ 162 (“[T]he invention applies to any computing device,
`
`PC or otherwise, not just mobile devices.”). These computing devices 110a, 110b,
`
`etc. (wireless devices) have a “network interface” or “modem” (connector) that, via
`
`a communications network/bus 14, such as the Internet, connects to a “server
`
`computer 10 . . . with access to various types of storage elements” (remote server
`
`containing user information). Soin Figs. 2A-2B; ¶¶ 33, 44-45; see also Rysavy
`
`Decl. ¶¶ 95-100, 177.
`
`20.3 a memory,
`said memory
`containing
`therein said user
`information
`downloaded
`from said
`server;
`
`“Components of computer 110 may include, but are not
`limited to, … a system memory 130.” Soin ¶ 50; see also Soin
`¶ 51. “The system memory 130 includes computer storage
`media in the form of volatile and/or nonvolatile memory …
`By way of example, and not limitation, FIG. 2B illustrates
`operating system 134, application programs 135, other
`program modules 136, and program data 137.” Soin ¶ 52; see
`also Soin ¶¶ 53-56, Fig. 2B, ¶¶ 61-64, Fig. 2C. “Each client
`computer 110a, 110b, 110c, 110d, 110e, etc. and server
`computer 10 a, 10 b, etc. may be equipped … with
`connections or access to various types of storage elements or
`objects, across which files or data streams may be stored or to
`which portion(s) of files or data streams may be downloaded,
`transmitted or migrated.” Soin ¶ 45; see also id. ¶ 56 (“remote
`application programs”), ¶¶ 69-71, ¶ 47, ¶ 177. See also Fig.
`2A; Rysavy Decl. ¶¶ 178-181.
`Wang: “Still referring to the system 100 illustrated in FIG. 1,
`multimedia information may be provided by any number of
`service providers 102 a-b and delivered through a network 104
`to a base station 106 to ultimately accommodate transmission
`
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`of the multimedia information, among other things, to a
`cellular phone 108. …” Wang ¶ 27; Rysavy Decl. ¶¶ 124-128.
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`Users running Web-based applications in the Soin system would download
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`user information, such as “files or data streams,” to the computing device. Soin
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`¶ 45; Rysavy Decl. ¶¶ 124-128. A skilled artisan would understand that, inherent
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`to this downloading, the computing device would store the downloaded user
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`information in some memory on the computing device. Rysavy Decl. ¶¶ 178-181.
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`While Soin does not explicitly discuss the types of information that could be
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`downloaded, a skilled artisan would have understood that Soin’s “data streams”
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`(¶ 45) could have included the video or multimedia information specifically taught
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`by Wang: “multimedia information may be provided by any number of service
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`providers 102 a-b and delivered through a network 104 to a base station 106 to
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`ultimately accommodate transmission of the multimedia information … to a
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`cellular phone 108.” Wang ¶ 27. Thus, Soin and Wang teach element 1.2.
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`20.4 a
`transmitter, said
`transmitter, at
`the control of
`said user,
`sending said
`user
`information to a
`peripheral
`device; and
`
`“Alternate display devices in accordance with the invention
`include, but are not limited, to Wi-Fi 802.11b technology,
`currently the most common form of wireless communication
`in the projector and computer industry.” Soin ¶ 24. “When
`used in a LAN networking environment, the computer 110 is
`connected to the LAN 171 through a network interface or
`adapter 170. When used in a WAN networking environment,
`the computer 110 typically includes a modem 172 or other
`means for establishing communications over the WAN 173,
`such as the Internet.” Soin ¶ 56; see also Soin ¶ 67.
`“Alternate Display Device, or Projector Device: The projector
`device … could be an actual projector or another device, such
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`as a laptop, hooked to a projector.” Soin ¶ 26. “In one aspect,
`the invention enables a display device, such as a projector or
`large display monitor, to … to receive content/data from a
`mobile computing device.” Soin ¶ 98; see also ¶ 21. “In an
`exemplary Mirror scenario, Melissa walks into a conference
`room …. She wirelessly projects the slide show on her laptop
`as-is on the projector.” ¶ 102. “In a typical 1:N scenario, Fred
`meets his colleagues at the airport lobby who all have laptops
`… Fred can easily project his slides on all his colleagues’
`laptops, and/or a projector, if one is available.” Soin ¶ 104.
`“[T]he user is asked via the UI if he wants to project content.
`… the user picks a display, e.g., projector to which to display
`content.” Soin ¶ 106; see also id. Fig. 3. “Conference room
`projector technology in accordance with the invention
`combines two key technologies: UPnP and Terminal Services.
`The use of these two technologies in accordance with the
`invention allow a user to discover and remotely control a
`projector, project an application (Desktop, PowerPoint, etc.)
`and extend a desktop to a disaggregated display device.” Soin
`¶ 109; see also Rysavy Decl. ¶¶ 182-183.
`Wang: “The cellular phone 108 is connected to the MTSCM
`110. This may be accommodated by a cable connection that
`interfaces the cellular phone 108 to the MTSCM 112 housing
`110. Through this connection, the MTSCM 112 receives the
`video signal from the cellular phone 108 (step 404). … A
`wireless connection may also be provided, although it may
`currently be less practical to provide than the wired connection
`because of the potential for high throughput rate
`requirements.” Wang ¶ 32.
`
`Soin describes how a user would control transmission of the user
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`information from the computing device (e.g., a laptop) to a peripheral device
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`(referred to as an “alternate display device” or “projector device”). Soin ¶¶ 26, 98.
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`For example, a user who downloaded information to her laptop could then elect to
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`transmit that information to a separate projector. Soin ¶ 106; Rysavy Decl. ¶¶ 182-
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`183. Soin describes that the “projector” may be “an actual projector or another
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`device, such as a laptop, hooked to a projector.” Soin ¶ 26; see also Fig. 2A
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`(showing a number of devices (110) to which content can be transmitted). Soin
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`teaches that its method “may apply to any computing device or environment,” and
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`a skilled artisan would have found it obvious to extend the Soin method to include
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`peripheral device hubs, such as the MTSCM taught by Wang. Wang ¶ 32; Rysavy
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`Decl. ¶ 182-183. Thus, Wang’s MTSCM is another type of peripheral device.
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`To carry out the transmission, the computing devices contain transmitters
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`within a network interface or modem. Soin ¶¶ 56, 67; see also Rysavy Decl.
`
`¶¶ 182-183. Soin specifically states that its devices would be capable of Wi-Fi
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`802.11b communications, Soin ¶ 24, which would require transmitters configured
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`to communicate using this Wi-Fi protocol, Rysavy Decl. ¶¶ 182-183.
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`20.5 an
`interface, on
`said wireless
`device,
`where said
`user through
`said
`interface
`operates said
`peripheral
`device from
`said wireless
`device,
`
`“In the extended case, there is a UI to enable one to navigate the
`presentation on the alternate display. For instance, one may have
`a PowerPoint presentation being presented on a projector and one
`wants to go to the next slide while having speaker notes on the
`laptop screen. In this case, one can use a UI on the laptop screen
`to highlight something on the slide or go to the next slide.” Soin
`¶ 163; see also id. ¶ 171 (“[A] change of slide at the server device
`correspondingly changes the slide at the client devices.”). “The
`use of these two technologies in accordance with the invention
`allow a user to discover and remotely control a projector, project
`an application (Desktop, PowerPoint, etc.) and extend a desktop
`to a disaggregated display device.” Soin ¶ 109; see also id.
`¶¶ 100, 102-104, 110-112, Figs. 4A-4B; Rysavy Decl. ¶¶ 95-100,
`131. “A configuration UI can be launched from the ‘Options’
`button on a dialog box in accordance with the invention that
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`allows the user to any of: set a password for the projection, select
`cloning mode vs. extended mode, select the screen resolution and
`select video, or audio and video.” Soin ¶ 118; see also Soin
`¶¶ 120, 169, claim 24, claim 74.
`
`Soin describes a UI (user interface) on the computing device for “enabl[ing]
`
`one to navigate the presentation on the alternate display.” Soin ¶ 163. Through
`
`this UI, a user operates the alternate display device (peripheral device) from the
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`computing device (wireless device) by, e.g., changing the slide shown on the
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`alternate display device. Id.; see also id. ¶ 171; Rysavy Decl. ¶¶ 190-191, 197.
`
`Soin also describes operating, or remotely controlling, the alternate display
`
`device from the wireless computing device by using a “configuration UI” (user
`
`interface) to, e.g., choose screen resolution or add audio. Soin ¶¶ 118, 120, 160
`
`and Figs. 4A-4B; see also Rysavy Decl. ¶¶ 131, 190-191.
`
`20.6 wherein
`said peripheral
`device
`comprises one
`or more
`components of
`personal
`equipment of
`said user,
`
`“Patrick sets his laptop in the meeting mode as he enters the
`client’s conference room. His machine discovers the wireless
`projector in the room.” Soin ¶ 103. “Fred meets his
`colleagues at the airport lobby who all have laptops … Fred
`can easily project his slides on all his colleagues’ laptops,
`and/or a projector, if one is available.” Soin