HTC Corporation and HTC America, Inc.
`Petitioner Demonstratives
`
`HTC Corporation and HTC America, Inc.
`v.
`Advanced Audio Devices, LLC
`
`Case IPR2014-01157
`Patent No. 7,933,171 B2
`
`Oral Hearing
`September 17, 2015
`
`HTC, Ex. 1027
`HTC v. Advanced Audio Devices
`IPR2014-001157
`
`
`Petitioner Demonstratives
`
`HTC Corporation and HTC America, Inc.
`v.
`Advanced Audio Devices, LLC
`
`Case IPR2014-01157
`Patent No. 7,933,171 B2
`
`Oral Hearing
`September 17, 2015
`
`HTC, Ex. 1027
`HTC v. Advanced Audio Devices
`IPR2014-001157
`
`
`
`PTAB Instituted Grounds
`(Institution Decision, Paper 6, at 26)
`
`Claims Challenged
`1, 2, 5, 6, 7, 14, 17, 20,
`26, 28, 37, 40, 42, 43,
`45–48
`
`1, 2, 5, 6, 7, 14, 17, 20,
`26, 28, 37, 40, 42, 43,
`45–48
`
`23
`
`Basis
`§ 103
`
`§ 103
`
`§ 103
`
`References
`Nathan ’259 and Nathan
`’255
`
`Sound Blaster, Lucente,
`Ozawa, and Hawkins
`
`Sound Blaster, Lucente,
`Ozawa, Hawkins, and
`Martin
`
`IPR2014-01157
`
`HTC Demonstrative 171-2
`
`
`
`Nathan ‘259
`
`
`
`Nathan ‘255
`
`IPR2014-01157
`
`HTC Demonstrative 171-3
`
`
`
`Nathan ‘255
`
`•
`
`•
`
`New Selection Acquisition Mode:
`•
`“… the manager can access the mode of new
`selection acquisition by touching a button located
`on the touch screen.” (¶91)
`“The NSAM module is the new selections
`acquisition mode module. When this mode is
`activated, a new control screen appears. This mode
`is designed to assist the manager regarding the
`location or fast and efficient acquisition of titles of
`musical selections.” (¶92)
`“…a third panel for scanning the title database, for
`private use, to allow the system manager or owner
`to examine the database containing the available
`titles via the audiovisual data distribution network
`to control and retrieve said titles” (¶41)
`Customer Browsing and Selection Mode
`•
`“The CBSM module is the customer browsing and
`selection mode module. Access to this module is
`triggered from the "in service" mode by touching
`the screen. When the customer touches the screen,
`the screen display disappears to make room for a
`menu provided for powerful browsing assisted by
`digitized voice messages to guide the user in his
`choice of musical selections.” (¶99)
`“The first title selection panel proceeding to help
`customers find and select a desired title” (¶41)
`
`•
`
`IPR2014-01157
`
`HTC Demonstrative 171-4
`
`
`
`Nathan ‘259
`
`“A first object of the invention is to propose an apparatus which allows selection and downloading of digital
`data, and reproduction of these digital data for domestic apparatus or use of the device for karaoke.” (¶2)
`“Another object of the invention is to devise a modular device which allows the user to develop a design
`allowing storage of a plurality of audio or video or audiovisual information selections. This object is achieved by
`a second mass storage module (108) allowing the recording of a plurality of digitized audiovisual data.” (¶¶8-9)
`
`IPR2014-01157
`
`HTC Demonstrative 171-5
`
`
`
`
`
`Nathan ‘259
`
`The selection graphics
`screen shown in Fig. 10
`is displayed by button
`(1025) from any zone of
`the playback graphics
`screen. (¶74)
`
`Front (10) includes a red
`button (1019) which allows
`the “purchase" function
`described below. (¶46)
`This remote control device
`can trigger display of the
`graphics screen located in
`FIG. 9 when the "purchase"
`key equivalent to (1019) of
`the remote control is
`pressed. (¶46)
`
`Available songs (¶74)
`
`Purchase, check
`PIN/credit card,
`download (¶¶68-73)
`
`Select, add to
`queue (¶74))
`
`IPR2014-01157
`
`HTC Demonstrative 171-6
`
`
`
`Grounds 1-3 under 35 USC 103(a)
`Motivations to Combine
`
`Ground
`
`References
`
`1
`
`2
`
`3
`
`Nathan ‘259 (Ex. 1002)+
`Nathan ‘255 (Ex. 1003)
`Sound Blaster (Ex. 1004) +
`Lucente (Ex. 1005) +
`Ozawa (Ex. 1006)
`Sound Blaster (Ex. 1004) +
`Lucente (Ex. 1005) +
`Ozawa (Ex. 1006)+
`Hawkins (Ex. 1008) +
`Martin (Ex. 1007)
`
`Petition
`(Paper 1)
`
`2014 Schmandt
`Declaration
`(Ex. 1009)
`
`Reply
`(Paper 21)
`
`17:4-18
`
`¶82
`
`11-12, 15
`
`2015 Schmandt
`Rebuttal
`Declaration
`(Ex. 1014)
`¶¶13, 15
`
`36:20-42:15 ¶¶139-161
`
`16-23
`
`¶¶50-65
`
`56:9-60:5
`
`¶¶214-216
`
`
`*
`
`*
`
`* Not separately addressed by AAD
`
`IPR2014-01157
`
`HTC Demonstrative 171-7
`
`
`
`Ground 1: Nathan ‘259 (Ex. 1002) in view of
`Nathan ‘255 (Ex. 1003)
`
`Element
`
`Challenged Claim
`
`1.Preamble
`
`1.A
`
`1.B
`
`1.C
`
`1.D
`
`1.E
`
`1.F
`
`1.G
`
`A personal digital stereo audio player configured to store sound
`tracks and play the stored sound tracks for personal enjoyment, said
`personal digital stereo audio player comprising:
`a unitary, integral housing containing;
`
`at least non-volatile memory;
`
`and a processor connected to the non-volatile memory and configured
`for maintaining and selectively accessing and playing sound tracks
`stored in the non-volatile memory,
`the housing further comprising a display controlled by the processor,
`
`the processor being configured to cause the display to display a
`plurality of menus relating to a library of sound tracks,
`wherein all of the sound tracks in the library and their names are
`stored in the non-volatile memory of the personal digital stereo audio
`player,
`
`wherein the menus include at least one of a list of names of sound
`tracks and a list of groups of sound tracks;
`
`Petition (Paper
`1)
`
`18:3-15
`
`
`18:16-19:4
`
`19:5-11
`
`19:12-20:4
`
`
`20:5-13
`
`20:14-21:16
`
`21:17-22:7
`See also 1.B 19:5
`See also 1.E
`20:14
`
`22:8-23:1
`
`
`2014
`Schmandt
`Declaration
`(Ex. 1009)
`¶84
`
`¶85
`
`¶86
`
`¶87
`
`¶88
`
`¶89-91
`
`¶92
`See also 1.B
`¶80
`
`
`¶92-93
`
`Reply
`(Paper
`21)
`
`*
`
`*
`
`*
`
`12-14
`
`*
`
`*
`
`*
`
`*
`
`IPR2014-01157
`
`* Claim element undisputed by AAD
`HTC Demonstrative 171-8
`
`
`
`Ground 1: Nathan ‘259 (Ex. 1002) in view of
`Nathan ‘255 (Ex. 1003)
`
`Element
`
`Challenged Claim
`
`1.H
`
`1.I
`
`1.J
`
`1.K
`
`1.L
`
`1.M
`
`a headphone jack in the housing;
`
`an input in the housing for receiving audio data;
`
`an amplifier operatively connected to the processor and the
`headphone jack and configured to amplify audio output signals
`produced during playing, which are transmitted to the headphone
`jack;
`and at least one touch-operable control in the housing and in
`communication with the processor,
`
`wherein the processor is configured such that: at least one of the at
`least one touch-operable control is touchable to allow selection
`from the menus which the processor causes to be displayed on the
`display,
`at least one of the at least one touch-operable control is touchable
`to control the volume at which audio is played,
`
`2014
`Schmandt
`Declaration
`(Ex. 1009)
`¶95
`
`¶96
`
`¶97-98
`
`¶99-101
`
`¶102
`
`¶103
`
`Petition
`(Paper 1)
`
`23:2-3
`
`23:4-12
`
`
`23:13-24:3
`
`
`
`24:4-25:4
`
`
`25:6-15
`
`
`
`25:16-26:3
`
`
`
`Reply
`(Paper
`21)
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`IPR2014-01157
`
`* Claim element undisputed by AAD
`HTC Demonstrative 171-9
`
`
`
`Ground 1: Nathan ‘259 (Ex. 1002) in view of
`Nathan ‘255 (Ex. 1003)
`
`Element
`
`Challenged Claim
`
`1.N
`
`1.O
`
`1.P
`
`1.Q
`
`1.R
`
`1.S
`
`at least one of the at least one touch-operable control is touchable to
`pause a sound track which is being played,
`at least one of the at least one touch-operable control is touchable to stop
`a sound track as it is being played and play the next sound track in a group
`of sound tracks,
`at least one of the at least one touch-operable control is touchable to
`selectively power the personal digital stereo audio player on and off,
`and, at least one of the at least one touch-operable control is touchable to
`select and play at least one of an individual sound track and a group of
`sound tracks through the headphone jack,
`wherein the personal digital stereo audio player is configured to display on
`the display at least one of time elapsed (ascending) and time remaining
`(descending) for the sound track being played,
`wherein the personal digital stereo audio player is configured such that
`the non-volatile memory stores a library of sound tracks that is received by
`the input and which has been pre-selected by a user,
`
`Reply
`(Paper
`21)
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`Petition
`(Paper 1)
`
`26:4-8
`
`26:9-14
`
`
`26:15-20
`
`27:1-12
`See also
`1.H 23:2
`27:13-18
`
`
`27:19
`See also
`1.B 19:5
`See also 1.I
`23:4
`
`2014
`Schmandt
`Declaration
`(Ex. 1009)
` ¶104
`
`¶105
`
`¶106
`
`¶107
`See also 1.H
`¶95
`¶108
`
`
`¶109
`See also 1.B
`¶80
` See also 1.I
`¶96
`
`IPR2014-01157
`
`* Claim element undisputed by AAD
`HTC Demonstrative 171-10
`
`
`
`Ground 1: Nathan ‘259 (Ex. 1002) in view of
`Nathan ‘255 (Ex. 1003)
`
`Element
`
`Challenged Claim
`
`1.T
`
`1.U
`
`1.V
`
`1.W
`
`wherein the non-volatile memory comprises at least one of a Hard Disk Drive,
`solid state memory, and random address memory,
`
`wherein the personal digital stereo audio player is configured to receive audio
`data through the input of the personal digital stereo audio player,
`
`whereby sound tracks become stored in the non-volatile memory as digital
`data;
`
`and wherein the personal digital stereo audio player is configured such that at
`least one of the at least one touch-operable control is touchable to cause the
`personal digital stereo audio player to display on the display at least one of a
`list of names of sound tracks, and a list of groups of sound tracks,
`
`Petition
`(Paper 1)
`
`28:11-14
`See also 1.B
`19:5
`28:15-17
`See also 1.I
`23:4
`
`28:18-20
`See also 1.B
`19:5
`See also 1.I
`23:4
`29:1-5
`See also 1.G
`22:8
`
`2014 Schmandt
`Declaration
`(Ex. 1009)
`¶110
`See also 1.B ¶80
`
`¶111
`See also 1.I ¶96
`
`
`¶112
`See also 1.B ¶80
`See also 1.I ¶96
`
`¶113
`
`
`Reply
`(Paper
`21)
`*
`
`*
`
`*
`
`*
`
`IPR2014-01157
`
`* Claim element undisputed by AAD
`HTC Demonstrative 171-11
`
`
`
`Ground 1: Nathan ‘259 (Ex. 1002) in view of
`Nathan ‘255 (Ex. 1003)
`
`Element
`
`Challenged Claim
`
`1.X
`
`1.Y
`
`wherein the personal digital stereo audio player is configured such that at least
`one of the at least one touch-operable control is touchable to cause the
`personal digital stereo audio player to play at least one of a specific sound
`track and a group of sound tracks through the headphone jack,
`and wherein the personal digital stereo audio player is configured such that at
`least one of the at least one touch-operable control is touchable to control the
`volume at which sound tracks are played through the headphone jack.
`
`Petition
`(Paper 1)
`
`29:6-10
`See also 1.Q
`26:15
`
`29:11-14
`See also 1.H
`23:2
`See also
`1.M 25:16
`
`2014 Schmandt
`Declaration
`(Ex. 1009)
`¶114
`See also 1.Q
`¶107
`
`¶115
`See also 1.H ¶95
`See also 1.M
`¶103
`
`Reply
`(Paper
`21)
`12-14
`
`
`*
`
`IPR2014-01157
`
`* Claim element undisputed by AAD
`HTC Demonstrative 171-12
`
`
`
`Ground 2: Sound Blaster (Ex. 1004) in view of
`Lucente (Ex. 1005) and Ozawa (Ex. 1006)
`
`Element
`
`Challenged Claim
`
`1.Preamble A personal digital stereo audio player configured to store sound
`tracks and play the stored sound tracks for personal enjoyment, said
`personal digital stereo audio player comprising:
`a unitary, integral housing containing;
`
`1.A
`
`1.B
`
`1.C
`
`1.D
`
`1.E
`
`1.F
`
`1.G
`
`at least non-volatile memory;
`
`and a processor connected to the non-volatile memory and configured for
`maintaining and selectively accessing and playing sound tracks stored in the
`non-volatile memory,
`the housing further comprising a display controlled by the processor,
`
`the processor being configured to cause the display to display a plurality of
`menus relating to a library of sound tracks,
`wherein all of the sound tracks in the library and their names are stored in
`the non-volatile memory of the personal digital stereo audio player,
`
`wherein the menus include at least one of a list of names of sound
`tracks and a list of groups of sound tracks;
`
`Petition
`(Paper 1)
`
`43:1-15
`
`2014
`Schmandt
`Declaration
`(Ex. 1009)
`¶163
`
`43:16-44:1
`
`¶164-165
`
`44:2-14
`
`44:15-45:3
`
`
`45:4-9
`
`45:10-14
`
`45:15
`See also 1.B
`43:16
`
`
`45:17-46:12
`
`
`¶166
`
`¶167
`
`
`¶168
`
`¶169
`
`¶170
`See also 1.B
`¶166
`
`
`¶170
`
`Disputed
`by AAD
`
`No
`
`No
`
`No
`
`No
`
`No
`
`No
`
`No
`
`No
`
`IPR2014-01157
`
`HTC Demonstrative 171-13
`
`
`
`Ground 2: Sound Blaster (Ex. 1004) in view of
`Lucente (Ex. 1005) and Ozawa (Ex. 1006)
`
`Element
`
`Challenged Claim
`
`1.H
`
`1.I
`
`1.J
`
`1.K
`
`1.L
`
`1.M
`
`a headphone jack in the housing;
`
`an input in the housing for receiving audio data;
`
`an amplifier operatively connected to the processor and the
`headphone jack and configured to amplify audio output signals
`produced during playing, which are transmitted to the headphone
`jack;
`and at least one touch-operable control in the housing and in
`communication with the processor,
`
`wherein the processor is configured such that: at least one of the at
`least one touch-operable control is touchable to allow selection
`from the menus which the processor causes to be displayed on the
`display,
`
`at least one of the at least one touch-operable control is touchable
`to control the volume at which audio is played,
`
`Petition
`(Paper 1)
`
`46:13-19
`
`46:20-47:17
`
`47:18-48:8
`
`
`48:9-49:17
`
`
`49:18-50:2
`See also
`1.E, 45:10
`See also
`1.K, 48:9
`
`50:3-9
`
`
`2014
`Schmandt
`Declaration
`(Ex. 1009)
`¶172
`
`¶174
`
`¶175
`
`
`¶177
`See also 1.E
`¶169
`
`¶179
`See also 1.E
`¶169
`See also 1.L
`¶177
`
`¶180
`See also 1.L
`¶177
`
`
`Disputed
`by AAD
`
`No
`
`No
`
`No
`
`No
`
`No
`
`No
`
`IPR2014-01157
`
`HTC Demonstrative 171-14
`
`
`
`Ground 2: Sound Blaster (Ex. 1004) in view of
`Lucente (Ex. 1005) and Ozawa (Ex. 1006)
`
`Element
`
`Challenged Claim
`
`Petition
`(Paper 1)
`
`at least one of the at least one touch-operable control is touchable to
`pause a sound track which is being played,
`
`50:10-14
`
`
`1.N
`
`1.O
`
`1.P
`
`1.Q
`
`1.R
`
`1.S
`
`2014
`Schmandt
`Declaration
`(Ex. 1009)
`¶181
`See also 1.L
`¶177
`
`¶182
`See also 1.L
`¶177
`
`¶183
`
`¶184-185
`
`Disputed
`by AAD
`
`No
`
`No
`
`No
`
`No
`
`No
`
`No
`
`at least one of the at least one touch-operable control is touchable to
`stop a sound track as it is being played and play the next sound track in a
`group of sound tracks,
`at least one of the at least one touch-operable control is touchable to
`selectively power the personal digital stereo audio player on and off,
`and, at least one of the at least one touch-operable control is touchable
`to select and play at least one of an individual sound track and a group
`of sound tracks through the headphone jack,
`wherein the personal digital stereo audio player is configured to display
`on the display at least one of time elapsed (ascending) and time
`remaining (descending) for the sound track being played,
`wherein the personal digital stereo audio player is configured such that
`the non-volatile memory stores a library of sound tracks that is received
`by the input and which has been pre-selected by a user,
`
`50:15-19
`See also
`1.K, 48:9
`
`50:20-51:6
`
`51:7-52:15
`
`
`52:16-17
`
`¶186
`
`52:18-53:6
`
`¶187
`
`IPR2014-01157
`
`HTC Demonstrative 171-15
`
`
`
`Ground 2: Sound Blaster (Ex. 1004) in view of
`Lucente (Ex. 1005) and Ozawa (Ex. 1006)
`
`Element
`
`Challenged Claim
`
`1.T
`
`1.U
`
`1.V
`
`1.W
`
`wherein the non-volatile memory comprises at least one of a Hard
`Disk Drive, solid state memory, and random address memory,
`
`wherein the personal digital stereo audio player is configured to
`receive audio data through the input of the personal digital stereo
`audio player,
`whereby sound tracks become stored in the non-volatile memory as
`digital data;
`
`and wherein the personal digital stereo audio player is configured
`such that at least one of the at least one touch-operable control is
`touchable to cause the personal digital stereo audio player to
`display on the display at least one of a list of names of sound tracks,
`and a list of groups of sound tracks,
`
`2014
`Schmandt
`Declaration
`(Ex. 1009)
`¶188
`See also 1.B
`¶166
`
`¶189
`See also 1.I
`¶174
`
`¶190
`See also 1.B
`¶166
`See also 1.I
`¶174
`¶191
`
`
`Petition
`(Paper 1)
`
`53:7
`See also
`1.B 43:16
`
`53:8
`See also 1.I
`46:20
`
`53:9
`See also
`1.B 43:16,
`46:20
`
`53:10
`See also
`1.G 45:17
`
`
`Disputed
`by AAD
`
`No
`
`No
`
`No
`
`No
`
`IPR2014-01157
`
`HTC Demonstrative 171-16
`
`
`
`Ground 2: Sound Blaster (Ex. 1004) in view of
`Lucente (Ex. 1005) and Ozawa (Ex. 1006)
`
`Element
`
`Challenged Claim
`
`1.X
`
`1.Y
`
`wherein the personal digital stereo audio player is configured such
`that at least one of the at least one touch-operable control is
`touchable to cause the personal digital stereo audio player to play at
`least one of a specific sound track and a group of sound tracks
`through the headphone jack,
`and wherein the personal digital stereo audio player is configured
`such that at least one of the at least one touch-operable control is
`touchable to control the volume at which sound tracks are played
`through the headphone jack.
`
`Disputed
`by AAD
`
`No
`
`No
`
`Petition
`(Paper 1)
`
`53:11
`See also
`1.Q 50:20
`
`
`53:12
`See also
`1.H 46:13
`See also
`1.M 50:3
`
`
`2014
`Schmandt
`Declaration
`(Ex. 1009)
`¶192
`See also 1.Q
`¶184
`
`
`¶193
`See also 1.H
`¶172
`See also 1.M
`¶180
`
`
`
`IPR2014-01157
`
`HTC Demonstrative 171-17
`
`
`
`Motivation to Combine
`Sound Blaster, Lucente, and Ozawa
`
`“In my opinion, a person of ordinary skill in the art would consider the teachings of each of Sound Blaster,
`Lucente, and Ozawa to be pertinent in designing a digital audio player, such as a computer with digital audio
`playback capability… A person of ordinary skill in the art would therefore consider Sound Blaster, Lucente, and
`Ozawa to be within the same field and would naturally consider the teachings of one to be relevant to the
`other…
`“In my opinion, a person of ordinary skill in the art would recognize that the functionality provided by the
`software taught by Sound Blaster, including recording and storing audio files, would provide similar benefits in
`a portable personal computer using a touch screen interface, such as the pen computer discussed in Lucente,
`for the same reason they would be beneficial in a personal computer (whether a desktop or laptop) using an
`interface such as a mouse… Lucente teaches that the touch screen computer it describes is intended to
`maintain the capability to be used for a wide range of software programs… In light of this overlap, and the
`similarity between the audio subsystems and audio input and output hardware of Sound Blaster and Lucente, a
`person of ordinary skill in the art would be motivated to combine a system with the flexibility, portability, and
`ease of use of Lucente with the audio management capabilities of Sound Blaster. Similarly, a person of ordinary
`skill in the art would recognize that the downloaded library of Ozawa could be improved using the
`organizational methods (e.g. sorting into playlists) of Sound Blaster…
`“In my opinion, combining the elements claimed by Challenged Claims of the 403 Patent into a single unit
`would not produce any benefits that would not be readily apparent to a person of ordinary skill in the art
`familiar with the teachings of Sound Blaster, Lucente, and Ozawa.”
`Ex. 1009 (Schmandt Decl., ¶¶ 157-159)
`Petition (Paper 1) at 36:20-42:19
`
`IPR2014-01157
`
`HTC Demonstrative 171-18
`
`
`
`Compatible Hardware
`
`
`
`M-Wave Audio
`subsystem
`Headphone port
`Microphone port
`Line in/out ports
`
`Schmandt Rebuttal Declaration:
`•
`[S]ound functionality for a variety of computing devices,
`including laptops and tablets with touch screens, was well-
`known at the time of the alleged invention, and a person of
`ordinary skill in the art would understand that the basic
`software concepts illustrated in Sound Blaster, including the
`use and management of playlists, could be adapted to work
`in a variety of computer systems having the appropriate
`hardware to play back sound files stored in memory, and
`would have a reasonable expectation of success… Ex. 1010,
`¶55.
`[A] person of ordinary skill in the art would understand the
`teachings of the Sound Blaster reference to be applicable to
`other types of busses or connections beyond the specific ISA
`example used on that particular card. Id., ¶56.
`The purpose of using a standard bus such as ISA, PCI, or MCA
`is to provide a common interface for hardware designers to
`allow their components to connect. Adapting hardware such
`as a sound card to utilize a known bus standard would have
`been a routine task well within the ability of a person of
`ordinary skill in the art, and would not have required undue
`experimentation. Id.
`Lucente discloses the use of Mwave Audio. Mwave audio was
`SoundBlaster compatible. Id., ¶57.
`
`•
`
`•
`
`•
`
`IPR2014-01157
`
`HTC Demonstrative 171-19
`
`
`
`Compatible Hardware
`
`Petition at 39:20-40:12:
`•
`Ozawa describes a portable audio device that
`uses personal computer technology (e.g. ISA,
`AT and PCT buses - Ozawa at 7: 27- 38; 9: 15-
`23) for the input and storage of audio, along
`with dedicated push-button controls such as
`direction, input and mode keys (e.g. fast-
`forward, play, rewind, stop and pause keys)
`are on the front panel of the housing for
`controlling playback of stored audio. The
`Ozawa device allows a user to selectively
`download music from a network service
`center, save that music to a hard disc within
`the player, and listen to music through
`headphones. The Ozawa device fits in a
`single rectangular housing and includes a
`CPU, RAM, hard disc for storing audio data,
`LCD display, 20 modem, headphone terminal
`and microphone terminal on its upper
`surface.
`
`IPR2014-01157
`
`HTC Demonstrative 171-20
`
`
`
`Compatible Software
`Touch-screen tablets/laptops
`Including IBM Tablets
`running Windows by 1997
`[I]n 1997 Fujitsu sold tablet
`computers running the
`Windows 95 operating system,
`such as the Fujitsu Stylistic
`1200. The Fujitsu Stylistic
`featured a touch-screen display
`along with a row of dedicated
`touch-sensitive controls
`immediately under the touch
`screen, including controls for
`sound playback, and a pen that
`could be pressed against the
`touch screen to achieve the
`same functions as left or right
`mouse clicks on a Windows 95
`machine without a touch
`screen:
`Ex.1009, ¶ 49
`
`Ex. 1009, App. J
`
`U.S. Patent No. 5,983,073… describes a laptop computer with
`a touch screen that could operate with a GUI based operating
`system such as Microsoft Windows 3.1
`Ex.1009, ¶ 50
`
`Ex. 1009, App. W
`
`IPR2014-01157
`
`HTC Demonstrative 171-21
`
`
`
`Contingent Motion to Amend
`
`References of record or known to AAD teaching additional elements of AAD
`proposed changes
`Teachings of reference
`
`Yavelow (Ex. 1009, App. G)
`
`Ex. 1007, App. G, Fig. 15-5.
`
`15:15-19
`
`WinPlay 3 (See Ex. 1009, ¶ 36)
`
`(See Ex. 1007, ¶ 36)
`
`15:19-16:3
`
`IPR2014-01157
`
`HTC Demonstrative 171-22
`
`Reference
`
`Sound Blaster (Ex. 1004) in view of
`Lucente and Ozawa
`Sound Blaster in view of Nathan ‘259
`and Nathan ‘255
`Logan (Ex. 1020)
`
`Looney (Ex. 1021)
`
`Yankowski (Ex. 1022)
`
`Sound Blaster: 2-25
`
`Sound Blaster: 2-25
`
`Abstract, Fig. 2, (item 211), 9:4–6,
`11:22–28, 30:4–58
`Figs. 14–16, 7:45–62, 9:52–
`59, 10:35–58
`10:48–63, Fig. 5
`
`Windows 95 CD player (Ex. 1009, App. I) App. I at 239–40
`
`Opposition to
`Motion to Amend
`(Paper 22)
`6:4-8:16
`
`8:17-9:20
`
`11:16-12:3
`
`14:8-14
`
`12:16-20
`
`14:20-15:4
`
`Schmandt Opposition
`Declaration (Ex. 1023)
`
`¶¶11-22
`
`¶¶25-28
`
`¶33
`
`¶23
`
`¶31
`
`¶¶ 31-32
`
`¶ 30
`
`¶ 30
`
`
`
`Contingent Motion to Amend
`
`Additional references teaching additional elements of AAD proposed changes
`
`Reference
`
`Winamp (Ex. 1021) in view of Fujitsu
`(Ex. 1024)
`
`Winamp (Ex. 1021) in view of Lucente,
`Ditzik (Ex. 1022), and Ozawa
`
`Opposition to Motion to Amend (Paper
`22)
`19:2-20:4 (Motivation to combine)
`20:10-22:16 (original)
`22:16-22:12 (proposed changes)
`23:13-24:13
`
`Schmandt Opposition
`Declaration (Ex. 1023)
`¶¶35-39
`
`¶¶40-44
`
`IPR2014-01157
`
`HTC Demonstrative 171-23
`
`
`
`Conclusion
`PTAB should invalidate and cancel
`challenged claims based on instituted grounds
`
`Claims Challenged
`1, 2, 5, 6, 7, 14, 17, 20,
`26, 28, 37, 40, 42, 43,
`45–48
`
`1, 2, 5, 6, 7, 14, 17, 20,
`26, 28, 37, 40, 42, 43,
`45–48
`
`23
`
`Basis
`§ 103
`
`§ 103
`
`§ 103
`
`References
`Nathan ’259 and Nathan
`’255
`
`Sound Blaster, Lucente,
`Ozawa, and Hawkins
`
`Sound Blaster, Lucente,
`Ozawa, Hawkins, and
`Martin
`
`IPR2014-01157
`
`HTC Demonstrative 171-24
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