Exhibit C.14
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`U.S. Patent No. 8,102,286 (“’286 patent”)
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`U.S. Patent No. 5,525,980 (“Jahier”)
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`U.S. Patent No. 5,525,980 (“Jahier”) was filed on April 21, 1993, and issued on June 11, 1996. Jahier qualifies as prior art to U.S.
`Patent No. 8,102,286 (“’286 patent”) at least under pre-AIA 35 U.S.C. § 102(b), and alone or with other references, renders obvious
`one or more of claims 1-5, 7-17, and 19-24. 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 ’286 patent invalid.
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` U.S. Patent No. 7,545,366 (“Sugimoto”) was filed on May 20, 2005, and issued June 9, 2009. Sugimoto qualifies as prior art
`with regard to the ’286 patent at least under 35 U.S.C. § 102(e) (pre-AIA).
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` U.S. Patent No. 5,618,232 (“Martin”) was filed on March 23, 1995, and issued April 8, 1997. Martin qualifies as prior art with
`regard to the ’286 patent at least under 35 U.S.C. § 102(b) (pre-AIA).
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` U.S. Patent No. 7,844,914 (“Andre”) was filed on September 16, 2005, and issued November 30, 2010. Andre qualifies as
`prior art with regard to the ’286 patent at least under 35 U.S.C. § 102(e) (pre-AIA).
`
`
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`Japanese Patent Publication JP2000-214989 (“Amano”) was published on August 4, 2000. Amano qualifies as prior art with
`regard to the ’286 patent at least under 35 U.S.C. § 102(b) (pre-AIA).
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` Quantum 16 Key QMatrixTM Keypanel Sensor IC (“QT60161”) was published in 2001. QT60161 qualifies as prior art with
`regard to the ’286 patent at least under 35 U.S.C. § 102(b) (pre-AIA).
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` Quantum QProx QT160 / QT161 Manual (“QT160”) was published in 2002. QT160 qualifies as prior art with regard to
`the ’286 patent at least under 35 U.S.C. § 102(b) (pre-AIA).
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` U.S. Patent No. 6,696,985 (“Houston”) was filed on April 24, 2001, and issued February 24, 2004. Houston qualifies as prior
`art with regard to the ’286 patent at least under 35 U.S.C. § 102(b) and (e) (pre-AIA).
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`WEST\289623690.1
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`Page 1 of 82
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`Neodron Ltd.
`Exhibit 2003
`IPR2020-00778
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`Page 1 of 2
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` U.S. Patent No. 5,760,715 (“Senk”) was filed on April 15, 1997 and issued on June 2, 1998. Senk qualifies as prior art with
`regard to the ’286 patent at least under 35 U.S.C. § 102(b) (pre-AIA).
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` U.S. Patent No. 5,012,124 (“Hollaway”) was filed on Jul. 24, 1989, and issued Apr. 30, 1991. Hollaway qualifies as prior art
`with regard to the ’286 patent at least under 35 U.S.C. § 102(b) (pre-AIA).
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`The excerpts cited herein are exemplary. For any claim limitation, Defendants may rely on excerpts cited for /any other limitation
`and/or additional excerpts not set forth fully herein to the extent necessary to provide a more comprehensive explanation for a
`reference’s disclosure of a limitation. Where an excerpt refers to or discusses a figure or figure items, that figure and any additional
`descriptions of that figure should be understood to be incorporated by reference as if set forth fully herein.
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`To the extent this limitation is not disclosed by this reference, this limitation is rendered obvious in light of this reference by itself, this
`reference combined with the knowledge of a person or ordinary skill in the art, and this reference combined with the other references
`charted for this patent or cited in these charts. These references all are in comparable fields and have similar disclosures such that they
`are readily combinable. For example, the prior art references charted for this patent all disclose user interfaces for and methods of
`controlling electronic devices, including determining whether there has been a touch and distinguishing between intended and
`unintended touches, as established in these charts. All of these disclosures also would have been within the knowledge of a person
`having ordinary skill in the art (“a POSITA”). A POSITA seeking to apply the teachings of, for example, any of these references
`would have been motivated to practice this limitation for the reasons set forth in these references and as a matter of common sense.
`Additional motivation arises from a desire to overcome known problems and determining intended touches using known techniques.
`Additional motivation to do so arises from combining prior art elements according to known methods to yield predictable results to
`improve a similar device. Doing so would have been within the abilities of one of skill in the art, would not have required undue
`effort, and would have led to expected results. Practicing this limitation amounts to merely choosing from a finite number of
`identified, predictable solutions, with a reasonable expectation of success.
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`These invalidity contentions are not an admission by Defendants that the accused products or components, including any current or
`past version of these products or components, are covered by, or infringe the asserted claims, particularly when these claims are
`properly construed and applied. These invalidity assertions are also not an admission that Defendants concede or acquiesce to any
`claim construction(s) implied or suggested by Plaintiff in its Complaint or the associated infringement claim charts. Nor are
`Defendants asserting any claim construction positions through these charts, including whether the preamble is a limitation. Defendants
`also do not concede or acquiesce that any asserted claim satisfies the requirements of 35 U.S.C. §§ 112 or 101 and submit these
`invalidity contentions only to the extent Plaintiff’s assertions may be understood.
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`Page 2 of 82
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`Neodron Ltd.
`Exhibit 2003
`IPR2020-00778
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`Page 2 of 2
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