`
`U.S. Patent No. 5,525,980 (“Jahier”)
`
`Exhibit C-14
`
`U.S. Patent No. 5,525,980 (“Jahier”) qualifies as prior art to U.S. Patent No. 9,024,790 (“’790 Patent”) at least under pre-AIA 35
`U.S.C. § 102(b) and anticipates, and alone or with other references, renders obvious one or more of claims 1, 4-8, 10-14, 16-24. To
`the extent Jahier does not disclose one or more limitations of the claims, it would have been obvious to combine the teachings of
`Jahier with the knowledge of one of ordinary skill in the art and with one or more of the references below to render the claims at issue
`in the ’790 patent invalid. The cited references listed in the following charts disclose or render obvious the respective limitations under
`those constructions agreed to by the parties and, where constructions are in dispute, under either party’s construction as set forth in the
`updated Joint Proposed Claim Construction Chart dated October 31, 2019 unless noted otherwise.
`• U.S. Patent No. 7,545,366 (“Sugimoto”)
`• U.S. Patent No. 5,618,232 (“Martin”)
`• U.S. Patent No. 7,844,914 (“Andre”)
`•
`Japanese Patent Publication JP2000-214989 (“Amano”)
`• Quantum 16 Key QMatrixTM Keypanel Sensor IC (“QT60161”)
`• Quantum QProx QT160 / QT161 Manual (“QT160”)
`• U.S. Patent No. 6,696,985 (“Houston”)
`• U.S. Patent No. 5,760,715 (“Senk”)
`• Prior art references as set forth in Exhibit C-13
`• Prior art references as described in the cover pleading to these contentions
`
`Asserted Claims
`
`Claim 1
`
`1[pre] An apparatus comprising:
`
`Prior Art Disclosures
`
`Jahier, alone or in combination with other references identified in this chart or
`elsewhere in Respondents’ invalidity contentions, and further in light of the
`knowledge of a person of ordinary skill in the art, discloses the apparatus recited
`in claim 1.
`
`Jahier discloses: “A method and apparatus for determining a valid selection of a
`capacitance tactile keyboard as a function of a selection state and validation state
`
`1
`
`Neodron Ltd.
`Exhibit 2002
`IPR2020-00778
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`Page 1 of 102
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