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
`
`
`
`

`
`IPR2016-01053
`Patent 8,879,987
`
`
`TABLE OF CONTENTS
`
`Page
`
`I. MANDATORY NOTICES ......................................................................................... 1
`
`A.
`
`Real Party-In-Interest ........................................................................................ 1
`
`B.
`
`C.
`
`Related Matters ................................................................................................... 1
`
`Lead Counsel, Back-Up Counsel And Service Information ................... 2
`
`II.
`
`SECTION 42.104(A) CERTIFICATION ................................................................ 2
`
`III. PRELIMINARY STATEMENT ................................................................................ 2
`
`IV. SUMMARY OF PRECISE RELIEF REQUESTED ............................................ 4
`
`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 1-5, 12-17, 19 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.
`
`F.
`
`Dependent Claims 2-5 Are Obvious Over Soin And Wang .................. 19
`
`Independent Claim 12 And Dependent
`Claims 13-17, 19 Are Obvious Over Soin And Wang ........................... 23
`
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`Patent 8,879,987
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`VIII. GROUND 2: CLAIMS 1-3, 5, 12-17, 19 ARE
`OBVIOUS UNDER 35 U.S.C. § 103 OVER TEE AND ACHARYA .......... 30
`
`A.
`
`Tee........................................................................................................................ 30
`
`B. Acharya ............................................................................................................... 31
`
`C. Motivation To Combine Tee And Acharya ............................................... 31
`
`E.
`
`F.
`
`Dependent Claims 2-3 and 5 Are Obvious Over Tee And Acharya ... 40
`
`Independent Claim 12 And Dependent
`Claims 13-17, 19 Are Obvious Over Tee And Acharya ........................ 43
`
`IX. GROUND 3: CLAIM 4 IS OBVIOUS
`UNDER 35 U.S.C. § 103 OVER TEE, ACHARYA, AND BENCO ............. 50
`
`A.
`
`Benco ................................................................................................................... 50
`
`B. Motivation To Combine Tee, Acharya, And Benco ............................... 50
`
`X.
`
`CONCLUSION ............................................................................................................ 53
`
`
`
`
`
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`ii
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`IPR2016-01053
`Patent 8,879,987
`
`
`Cases
`
`TABLE OF AUTHORITIES
`
`Page(s)
`
`Ex Parte Nehls,
`88 USPQ2d 1883 (BPAI 2008) ......................................................... 15, 16, 19, 37
`
`In re Fox,
`471 F.2d 1405 (CCPA 1973) ..................................................................... 5, 17, 38
`
`Statutes
`
`35 U.S.C. § 102 ................................................................................................ passim
`
`35 U.S.C. § 103 ......................................................................................... 4, 8, 30, 50
`
`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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`iii
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`IPR2016-01053
`Patent 8,879,987
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`LIST OF EXHIBITS
`
`Ex. No. Description / Date
`
`1101
`
`1102
`
`1103
`
`1104
`
`1105
`
`1106
`
`1107
`
`1108
`
`1109
`
`1110
`
`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”)
`
`Applicant’s Response to Office Action During Prosecution of ’342
`Patent, filed May 31, 2011
`
`Declaration of Peter Rysavy (“Rysavy Decl.”), signed and dated April
`30, 2016
`
`Random House Webster’s Computer & Internet Dictionary (2000)
`(excerpts)
`
`Second Declaration of Peter Rysavy (“Second Rysavy Decl.”), signed
`and dated May 17, 2016
`
`1111 U.S. Provisional Application Ser. No. 60/844,645, filed Sep. 15, 2006.
`
`1112 U.S. Patent Application Ser. No. 11/889,941, filed Aug. 17, 2007.
`
`
`
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`IPR2016-01053
`Patent 8,879,987
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`Petitioner RPX Corporation (“RPX”) respectfully requests inter partes
`
`review of claims 1-5, 12-17, and 19 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
`
`On April 30, 2016, RPX filed petitions for inter partes review of a different
`
`claim set of the ’987 patent (IPR2016-00985) and claims in related U.S. Patent No.
`
`8,135,342 (IPR2016-00989). This Petition is filed concurrently with a second
`
`petition for inter partes review of U.S. Patent No. 8,135,342 (IPR2016-01052) and
`
`a petition for inter partes review of claims 6-9 of the ’987 patent (IPR2016-
`
`01054). The ’987 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-
`
`1
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`

`
`IPR2016-01053
`Patent 8,879,987
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`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.
`
`C. Lead Counsel, Back-Up Counsel And Service Information
`
`Andrew M. Mason (Lead) andrew.mason@klarquist.com, Reg. No. 64,034,
`
`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. One goal of the patent
`
`is to allow users to “access any browser-based web site or software application”
`
`2
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`through the cell phone’s network connection, with user interactions made through
`
`“the desktop monitor, keyboard, mouse, speakers and printer.” ’987 patent 3:8-31.
`
`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
`
`phone to a larger display and keyboard. Id. at 2:20-26. This is incorrect. As shown
`
`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.
`
`3
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`Patent 8,879,987
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`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. 1104) and Wang (Ex. 1105)
`
`35 U.S.C.
`§ 103
`
`1-5, 12-17,
`19
`
`Ground 2 Tee (Ex. 1102) and Acharya (Ex. 1103) 35 U.S.C.
`§ 103
`
`1-3, 5, 12-17,
`19
`
`Ground 3 Tee, Acharya, and Benco (Ex. 1106)
`
`35 U.S.C.
`§ 103
`
`4
`
`Sections VII-IX below provide the required statements of precise relief
`
`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 1, and its dependents 2-5, are
`
`representative. Independent claim 12, and its corresponding dependent claims (13-
`
`17, 19, respectively) recite elements nearly identical to those in claims 1-5.
`
`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
`
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`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
`
`skilled artisan); Rysavy Decl. ¶¶ 41, 54, 90.
`
`VI. CLAIM CONSTRUCTION
`
`A.
`
`Person Of Ordinary Skill In The Art
`
`The person of ordinary skill in the art in September 2006 (“skilled artisan”)
`
`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
`
`5
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`the elements of the constructions proposed below.
`
`“user information” (claims 1, 2, 5, 12-13, 19): “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. A
`
`skilled artisan would have understood “user information” to generally refer to any
`
`data, documents, or information accessible to one or more users over a network,
`
`e.g., through a web browser via the Internet. Second Rysavy Decl. ¶¶ 29-31.
`
`Outside the claims, the ’987 patent first suggests that “user information”
`
`differs from “media,” ’987 13:54-56, but later provides “a movie or steaming [sic]
`
`video on a selected peripheral device” as an example of “displaying user
`
`information,” ’987 13:58-62. The term’s sole other appearance could be read
`
`either as equating “user information” with “media” or distinguishing the two from
`
`one another. ’987 13:44-46 (“[T]he user controls the user information or media.”).
`
`The ’987 patent also discusses how its techniques can be used over the
`
`Internet to access information uploaded by “another.” ’987 patent 14:17-27. A
`
`skilled artisan would have understood this to refer to a wireless device user
`
`accessing content (user information) uploaded to a website by that or another user.
`
`Second Rysavy Decl. ¶¶ 29-30.
`
`This term may not require construction, as “user information” does not add a
`
`patentable distinction over the prior art. Second Rysavy Decl. ¶ 31. To the extent
`
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`it is construed, however, it should be construed broadly.
`
`“two users interconnect to said peripheral device, said two users
`
`controlling said user information” (claims 1, 12): 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 have understood
`
`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” (claim 16): Outside the claims, the ’987
`
`patent uses the term “server” only four times, none in the context of a wireless
`
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`device “operat[ing] as a computer server.” ’987 patent 1:43; 13:2; 13:37; 14:25.
`
`Accordingly, this term should be construed consistent with its plain meaning,
`
`which includes providing data to other devices. Rysavy Decl. ¶ 42; Ex. 1109.
`
`“said user information is employed in a manner that uniquely associates
`
`the user information with one or more peripheral devices” (claim 19): Outside
`
`the claims, the ’987 patent does not discuss uniquely associating user information
`
`with peripheral devices, or even use the terms “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 1-5, 12-17, 19 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.
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`Soin, Abstract & ¶¶ 44, 91. Soin also describes how the wireless devices connect
`
`to the Internet, “which provides an infrastructure for widely distributed
`
`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 allow
`
`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
`
`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 have been 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
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`peripheral device hub that could, in turn, connect to other peripheral devices, such
`
`as a display, as taught 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 as
`
`such peripheral hub devices were common by 2006. Rysavy Decl. ¶ 120.
`
`D.
`
`Independent Claim 1 Is Obvious Over Soin And Wang
`
`Claim 1
`1.1 A
`communication
`system for
`facilitating user
`connectivity,
`said system
`comprising:
`
`1.2 a
`communications
`network, said
`network
`comprising at
`least one server
`with user
`information
`thereon, said
`user information
`being remote to a
`user;
`
`1.3 a peripheral
`device, said
`
`Soin and Wang
`“[T]he invention applies to any device wherein it may be
`desirable to wirelessly project content from one computing
`device to the display of another computing device. … It
`should be understood, therefore, that handheld, portable and
`other computing devices and computing objects of all kinds
`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.
`Soin: “…enable an alternate display device to wirelessly
`receive content from a computing device.” Soin ¶ 8. “The
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`peripheral device
`being associated
`with said user;
`
`1.4 a wireless
`device, said
`wireless device
`wirelessly
`interconnected
`within said
`communications
`network to said
`server and said
`peripheral
`device; and
`
`control point of FIG. 4A discovers, controls, and projects to
`the Conference Room Projector Device of FIG. 4B, which
`may include laptops, projectors, monitors, etc.” Soin ¶ 112.
`“Alternate Display Device, or Projector Device: … This
`could be an actual projector or another device, such as a
`laptop, hooked to a projector.” Soin ¶ 24.
`
`“Once a user connects to the alternate display device at 600,
`the alternate display device returns a ‘SessionToken’ that
`identifies the connection of the individual at 610. At a given
`point in time, one individual ‘owns’ the alternate display
`device.” Soin ¶ 115; see also Soin Fig. 6; Soin ¶¶ 113-14,
`Fig. 5.
`“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. “…enable an alternate
`display device to wirelessly receive content from a computing
`device.” Soin ¶ 8; see also Soin Fig. 2A; Rysavy Decl.
`¶¶ 95-105; Rysavy Fig. 1. “[T]he invention applies to any
`device wherein it may be desirable to wirelessly project
`content from one computing device to the display of another
`computing device.” Soin ¶ 58; see also ¶ 40 (“[C] omputer
`110 a may be a laptop, and computing devices 10 a, 10 b, etc.
`may be remote media devices, or alternate display devices.
`…”). “[A] variety of devices may have applications, objects
`or resources that may implicate the ability to wirelessly
`project content via the invention.” Soin ¶ 34. “Any of these
`computing devices may be processing data or requesting
`services or tasks that may implicate the wireless
`transmission/reception of content in accordance with the
`invention.” Soin ¶ 40.
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`“[T]he multimedia information is provided to a wireless
`mobile terminal using so-called next generation cellular
`technology (i.e., 3G and 4G) ….” Wang ¶ 26; see also Wang
`¶¶ 27, Figs. 1, 3, 5-7
`
`Soin describes “computing devices,” including “a gaming console, handheld
`
`computer, portable computer, etc.” 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.”). A computing device 110a, 110b, etc. (wireless device) uses a
`
`communications network, such as the Internet, to connect to a “server computer 10
`
`. . . with access to various types of storage elements” (server with user information
`
`thereon). Soin Figs. 2A-2B; ¶¶ 33, 44-45; see also Rysavy Decl. ¶¶ 95-100, 177.
`
`This could include both wired and wireless connections and it also would have
`
`been obvious to use a cell phone as the computing device, as taught by Wang, thus
`
`wirelessly connecting to the server. Wang ¶¶ 26-27; Rysavy Decl. ¶¶ 100, 122,
`
`127. Soin’s computing device wirelessly connects to alternate display devices
`
`(peripheral devices) over the network. Soin ¶¶ 40, 55, Fig. 2A; Rysavy Decl. ¶¶
`
`95, 99, 105-109. These alternate display devices are associated with the user. E.g.,
`
`Soin ¶ 115.
`
`1.5 said
`user
`controlling
`said
`peripheral
`device
`
`“…enable an alternate display device to wirelessly receive content
`from a computing device.” Soin ¶ 8. “The control point of FIG.
`4A discovers, controls, and projects to the Conference Room
`Projector Device of FIG. 4B, which may include laptops,
`projectors, monitors, etc.” Soin ¶ 112. “… allow a user to
`discover and remotely control a projector, project an application
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`from said
`wireless
`device,
`
`said user
`information
`being
`transmitted
`to said
`peripheral
`device
`from said
`wireless
`device, and
`
`employed
`at the
`control of
`said user,
`
`(Desktop, PowerPoint, etc.) and extend a desktop to a
`disaggregated display device.” Soin ¶ 109; see also id. ¶¶ 100,
`110-112, 118 (“A configuration UI … 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.”), 120, 169, claim 24, claim 74, Figs. 4A-4B; Rysavy Decl.
`¶¶ 95-100, 131, 182-83.
`
`“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 Soin ¶¶ 21,
`102-104, 106, Fig. 3.
`
`“[T]here 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.”).
`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). ….” Wang ¶ 32.
`
`Soin describes remotely controlling the alternate display device (peripheral
`
`device) from the wireless computing device (wireless device) by using a
`
`“configuration UI” to, e.g., choose screen resolution or add audio. Soin ¶¶ 118,
`
`120, 160 and Figs. 4A-4B; see also Rysavy Decl. ¶¶ 131, 190-191.
`
`Soin describes how a user would control transmission of the user
`
`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.
`
`For example, a user who downloaded information to her laptop could then elect to
`
`transmit that information to a separate projector. Soin ¶ 106; Rysavy Decl. ¶¶ 182-
`
`183. Soin describes that the “projector” may be “an actual projector or another
`
`device, such as a laptop, hooked to a projector.” Soin ¶ 26; see also Fig. 2A
`
`(showing a number of devices (110) to which content can be transmitted).
`
`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 employs and controls the user information on the alternate display
`
`device (peripheral device) by, e.g., changing the slide shown on the alternate
`
`display device. Id.; see also id. ¶ 171; Rysavy Decl. ¶¶ 190-191, 197.
`
`1.6 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 ¶ 104; see also
`Soin ¶ 162; Rysavy Decl. ¶¶ 150-151.
`
`Element 1.6 recites that the peripheral device comprises “personal
`
`equipment of said user.” Ownership of the equipment does not make any technical
`
`difference, and the ’987 does not assert otherwise. Thus, this element carries no
`
`patentable weight. Ex Parte Nehls, 88 USPQ2d 1883 (BPAI 2008) (“Precedential
`
`Opinion”). See also, Rysavy Decl. ¶¶ 150-151. Regardless, Soin teaches that the
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`equipment can be the user’s or that of a third party, disclosing that a user can send
`
`content to a “large display monitor,” ¶ 21, which a skilled artisan would have
`
`understood could be either the user’s personal monitor or a third party monitor.
`
`Rysavy Decl. ¶¶ 150-151.
`
`1.7 wherein
`two users
`interconnect
`to said
`peripheral
`device, said
`two users
`controlling
`said user
`information,
`
`“[B]y including wireless technology, ... capable of projecting to a
`projector, the mobile device is able to project wirelessly … .”
`Soin ¶ 99. “With the invention, it is also easier to switch between
`multiple PC sources, for instance, if there are multiple people
`presenting from their own laptops.” Soin ¶ 99; see also Soin ¶
`21. “The invention also includes the ability to transfer control of
`a presentation to another connected user, whereby any user can
`transfer control of the presentation to another person.” Soin
`¶ 167 (emphasis added). “[T]he methods, as described in the
`present application may apply to any computing device or
`environment, such as a gaming console, handheld computer,
`portable computer, etc., whether wired or wireless, and may be
`applied to any number of such computing devices connected via
`a communications network, and interacting across the network.”
`Soin ¶ 181; see also supra Section VII.D (element 20.4); Rysavy
`Decl. ¶¶ 156-160, 174.
`Wang: “Examples of applications 714 where a larger screen and
`potentially superior audio may be enjoyed include video
`conference, HDTV, games, GPS, and video on demand.” Wang
`¶ 58.
`
`To the extent this element recites more than an unpatentable intended use of
`
`the peripheral device, Nehls, 88 USPQ2d 1883, Soin describes multiple computing
`
`devices, operated by respective users,