throbber
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re Patent of: Singh et al.
`U.S. Pat. No.: 6,400,376 B1
`Issue Date:
`June 4, 2002
`Appl. Serial No.: 09/217,400
`Filing Date: Dec. 21, 1998
`Title: DISPLAY CONTROL FOR HAND-HELD DATA PROCESSING DEVICE
`
`
`
`
`
`Attorney Docket No.: 30146-0017IP1
`
`
`
`DECLARATION OF DR. GREGORY F. WELCH
`
`I, Dr. Gregory F. Welch, of Longwood, Florida, declare that:
`
`1.
`
`I am currently a Professor and the Florida Hospital Endowed Chair in
`
`Healthcare Simulation at the University of Central Florida (UCF) with
`
`appointments in the College of Nursing, the Computer Science Division of the
`
`Department of Electrical Engineering and Computer Science, and the Institute for
`
`Simulation & Training. I am also an Adjunct Professor of Computer Science at the
`
`University of North Carolina at Chapel Hill (UNC). My qualifications for
`
`formulating my analysis on this matter are summarized here and are addressed
`
`more fully in my curriculum vitae, which is attached hereto as Appendix A.
`
`2.
`
`In 1986, I received a B.S. degree in Electrical Engineering
`
`Technology from Purdue University (with Highest Distinction). In 1995, I
`
`received a M.S. in Computer Science from UNC. In 1997, I received a Ph.D. in
`
`Computer Science from UNC.
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`Page 1 of 78
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`3.
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`Previously I have been a Research Professor at the University of
`
`North Carolina at Chapel Hill, a Senior Engineer at Northrop-Grumman’s Defense
`
`Systems Division where I worked on the AN/ALQ-135 electronic countermeasures
`
`system for the U.S. Air Force F-15 Eagle, and a member of the technical staff of
`
`NASA’s Jet Propulsion Laboratory where I worked on the Voyager Spacecraft
`
`project. The vast majority of my professional and academic work has been directed
`
`toward the use of computers to measure (sense) various physical phenomena and
`
`then act on those measurements.
`
`4. My current research interests include human-computer interaction,
`
`virtual and augmented reality, human motion tracking systems, three-dimensional
`
`(3D) telepresence, projector-based graphics, computer vision and view synthesis,
`
`and medical applications of computers for training, assessment, and practice. I
`
`have co-authored over 100 publications in these areas, and I am a co-inventor on
`
`multiple patents. I currently supervise over $2M in research funding, and am
`
`jointly responsible for over $23M in grants overall since 1996, from (for example)
`
`the Office of Naval Research (ONR), the National Science Foundation (NSF), The
`
`National Institutes of Health National Library of Medicine (NIH-NLM), the
`
`Defense Advanced Research Projects Agency (DARPA), the Department of
`
`Energy (DOE), and private companies—all involving multi-disciplinary and multi-
`
`institutional projects. I am the Co-Director of the Synthetic Reality Laboratory and
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`the Interactive Systems & User Experience Research Cluster of Excellence at
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`UCF.
`
`5.
`
`I have co-chaired major academic conferences and meetings
`
`(including IEEE ISMAR 2012 and Virtual Reality 2013), served on numerous
`
`program committees, co-chaired workshops, and serve as a peer reviewer for many
`
`conferences and journals. I am an Associate Editor for the journal Presence:
`
`Teleoperators and Virtual Environments, and an Associate Editor for the journal
`
`Frontiers in Virtual Environments.
`
`6.
`
`I am a member of multiple professional societies including the
`
`Institute of Electrical and Electronics Engineers (IEEE, Senior Member) and the
`
`Association for Computing Machinery (ACM).
`
`7. My work in human interface systems and the associated the computer-
`
`based sensing (e.g., hardware, software, sources/sensors, signal processing, and
`
`algorithms) goes back at least to the early 1980s when I was an undergraduate at
`
`Purdue University, e.g., with the co-development of an environmentally aware
`
`“smart wheelchair” for children with Cerebral Palsy. Fellow student and co-
`
`developer James Williams and I received an “Outstanding Senior Design Project
`
`award for “The Easy Chair” in 1986. One of my core contributions to the
`
`wheelchair project was the development of a novel customizable touch pad to be
`
`used by the children to control the wheelchair. The touch pad was customizable to
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`allow caregivers to design an interface that was tailored to each child and their
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`unique (limited) affordances. My work on touch pad technology in the mid 1980’s
`
`built on technology that had been developed decades earlier. I co-wrote and
`
`delivered various documents describing our pressure sensitive and infrared touch
`
`pad technology, and “The Easy Chair” system as a whole.
`
`8. My work in computer-based sensing continued into the late 1980s and
`
`early 1990s when I worked at NASA’s Jet Propulsion Laboratory (the Voyager
`
`Project) and Northrop-Grumman’s Defense Systems Division (a radar jammer). In
`
`particular in 1992 I attended graduate school at the University of North Carolina at
`
`Chapel Hill (UNC) where I studied/worked under the direction of Prof. Gary
`
`Bishop and others as a graduate student. My Ph.D. work, which I completed in
`
`1996, introduced a new Kalman filter-based Single Constraint at a Time (SCAAT)
`
`approach to sensing for applications such as human motion tracking in Virtual
`
`Environments. It was one of the critical aspects of the HiBall system for tracking
`
`heads, hands, and user interface devices. This system was commercialized by
`
`3rdTech and sold until approximately 2012. As a part of this work, I created what
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`is now a popular web site dedicated to the Kalman filter, and I co-authored a paper
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`titled “An Introduction to the Kalman filter” that has been cited over 6,000 times
`
`according to an estimate from Google search results.
`
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`9. While a research faculty member at UNC from 1996-2011, I co-
`
`led/led the Tracker Research Group, the 3D Computer Vision Group, and the
`
`Office of the Future Group. This includes conception and acquisition of contracts
`
`and grants; leading the subsequent research efforts; advising students; serving on
`
`Ph.D. committees; etc. In the mid-to-late 1990s I co-developed methods for
`
`tracking human motion by combining measurements from cameras that recognize
`
`and track natural features in the environment, with inertial and other sensing
`
`devices (accelerometers and gyros). Along the way I have developed human
`
`interface devices for research (e.g., physician interfaces for medical visualization
`
`and telepresence), and supervised the development of human interface devices by
`
`students in a Virtual Worlds course at UNC.
`
`10. Over the course of my academic and career experiences, I have
`
`invested a considerable amount of time researching technologies and techniques
`
`regarding the ways people input touch commands to devices, including through the
`
`use of touch screen displays. My efforts here include researching various resistive,
`
`capacitive, and optical touch devices, and their interaction with human motion of
`
`pen and finger inputs.
`
`11. Presently I am leading the development of several human interface
`
`projects related to military and healthcare simulation and training at UCF. For
`
`example, my team recently developed a system that comprises a plastic model of a
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`human head with rear-projected dynamic (live) animated facial imagery, and
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`whole-head touch sensing for medical training, e.g., to train healthcare
`
`professionals in the diagnosis of strokes. I published these results along with my
`
`co-authors in the March 2015 Proceedings of IEEE Virtual Reality 2015. We are
`
`currently working on realizing this over a full-body surface (an entire “Physical-
`
`Virtual Patient Bed”). Given the large number of cameras and projectors, and the
`
`unusual surfaces involved (large and complex), the development efforts are
`
`challenging but have the potential to provide a great benefit. The methods we are
`
`developing are generally applicable to touch sensing on non-parametric rear-
`
`projection surfaces. My team is also working on detecting physical contact (and
`
`proximal conditions) for the purpose of “sterile field” training of healthcare
`
`professionals. While in this case the goal of the healthcare professional is to not
`
`touch certain surfaces, the means for training this is to detect the location and
`
`timing of touch events. This detection is also aimed at unusual surfaces, and even
`
`dynamic surfaces.
`
`12. My analyses set forth in this declaration are informed by my
`
`experience in the fields of computer science and electrical engineering. Based on
`
`my above-described experience in computer science and electrical engineering, I
`
`believe that I am considered to be an expert in the field. Also, based on my
`
`experiences, I understand and know of the capabilities of persons of ordinary skill
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`in this field during the mid-1990s and during the time before the priority date for
`
`the ’376 patent (described in detail below in ¶¶ 18-20), and I taught, participated in
`
`organizations, and worked closely with many such persons during that time frame.
`
`13. As part of my independent analysis for this Declaration, I have
`
`considered the following: my own knowledge and experience, including my work
`
`experience in the fields of computer science and electrical engineering; my
`
`experience in teaching and advising students in those subjects; and my experience
`
`in working with others involved in those fields. In addition, I have analyzed the
`
`following publications and materials:
`
` The disclosure and claims of U.S. Patent No. 6,400,376 to Singh et al.
`
`(“the ’376 patent”; Ex. 1001);
`
` The prosecution history of the of the ’376 patent (Serial No. 09/217,400;
`
`Ex. 1002);
`
` U.S. Pat. No. 6,321,158 to DeLorme et al. filed August 31, 1998 (and
`
`published November 20, 2001) (“DeLorme”; Ex. 1004);
`
` U.S. Pat. No. 5,731,979 to Yano et al. published March 24, 1998
`
`(“Yano”; Ex. 1005);
`
` U.S. Pat. No. 5,615,384 to Allard et al. published March 25, 1997
`(“Allard”; Ex. 1006);
`
`Page 7 of 78
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` U.S. Pat. No. 5,623,589 to Needham et al. published April 22, 1997
`
`(“Needham”; Ex. 1007);
`
` Patent Owner’s Infringement Contentions for Ericsson Inc. et al v. Apple,
`
`Inc., Case No. 2:15-cv-289-JRG (E.D. Tex.) (“Infringement
`
`Contentions”; Ex. 1008); and
`
` Other background references, of which I had previously been aware, not
`
`cited herein, that a POSITA would have recognized as being related to
`
`the subject matter of the ’376 patent.
`
`14. Although this Declaration refers to selected portions of the cited
`
`references for the sake of brevity, it should be understood that these are examples,
`
`and that one of ordinary skill in the art would have viewed the references cited
`
`herein in their entirety and in combination with other references cited herein or
`
`cited within the references themselves. The references used in this Declaration,
`
`therefore, should be viewed as being incorporated herein in their entirety.
`
`15.
`
`I am not, and never was, an employee of Apple Inc. I have been
`
`engaged in the present matter to provide my independent analysis of the issues
`
`raised in the petition for inter partes review of the ’376 patent. I received no
`
`compensation for this declaration beyond my normal hourly compensation based
`
`on my time actually spent studying the matter, and I will not receive any added
`
`compensation based on the outcome of this inter partes review of the ’376 patent.
`
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`
`
`OVERVIEW OF CONCLUSIONS FORMED
`16. This Declaration explains the conclusions that I have formed based on
`
`my independent analysis. To summarize those conclusions:
`
` Based upon my knowledge and experience and my review of the prior art
`
`publications listed above, I believe that claims 16 and 28 of the ’376
`
`patent are obvious in light of U.S. Pat. No. 6,321,158 to DeLorme et al.
`
`(“DeLorme”) in view of U.S. Pat. No. 5,731,979 to Yano et al. (“Yano”).
`
` Based upon my knowledge and experience and my review of the prior art
`
`publications listed above, I believe that claims 17 and 29-31 of the ’376
`
`patent are obvious in light of DeLorme in view Yano and further in view
`
`of U.S. Pat. No. 5,615,384 to Allard et al. (“Allard”).
`
` Based upon my knowledge and experience and my review of the prior art
`
`publications listed above, I believe that claims 16 and 28 of the ’376
`
`patent are anticipated by U.S. Pat. No. 5,623,589 to Needham et al.
`
`("Needham").
`
` Based upon my knowledge and experience and my review of the prior art
`
`publications listed above, I believe that claims 17 and 29-31 of the ’376
`
`patent are obvious in light of Needham in view of Allard.
`
`
`
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`BACKGROUND KNOWLEDGE ONE OF SKILL IN THE ART WOULD
`HAVE HAD PRIOR TO THE FILING OF THE ’376 PATENT
`17. The technology in the ’376 patent at issue generally relates to
`
`receiving user input and changing a display in response to user selection of a
`
`touch-sensitive display. See Ex. 1001 at 7:1-55. The ’376 patent describes
`
`receiving input through a touch-sensitive display to allow a user to view sections of
`
`a virtual page. Id. at 5:26-43; 7:1-55. For example, a user can select an area of a
`
`“virtual page” that is divided into sub-pages, to cause a portion of the selected sub-
`
`page to be displayed. Id. at 7:1-55. The ’376 indicates that this functionality was
`
`implemented in response to the “limitation on the size of the screen” of prior art
`
`devices which made it “difficult if not often impossible to show an entire virtual
`
`page on the screen” or to “provide adequate and reliable user control of the many
`
`desired functions of the device.” Id. at 1:61-2:7.
`
`18. Prior to the filing date of the ’376 patent (December 21, 1998) there
`
`existed numerous products, publications, and patents that implemented or
`
`described the functionality claimed in claims 16-17 and 28-31 of the ’376 patent.
`
`Based upon my knowledge and experience and my review of the prior art
`
`publications listed above, I believe that a person of ordinary skill in the art at the
`
`time would have recognized that the subject matter described in claims 16-17 and
`
`28-31 of the ’376 patent was well known in the prior art. Further, to the extent
`
`there was any problem to be solved in subject matter recited in claims 16-17 and
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`28-31 of the ’376 patent, a person of ordinary skill in the art at the time would have
`
`known that such a problem had already been solved in the prior art systems before
`
`the filing date of the ’376 patent.
`
`19. Based upon my experience in this area, a person of ordinary skill in
`
`the art in this field at the relevant time frame (“POSITA”) would have had a
`
`combination of experience and education in computer science or electrical
`
`engineering and their subfield of user interfaces. This typically would consist of a
`
`minimum of a bachelor degree in computer science or electrical engineering or a
`
`related engineering field plus 2-5 years of work and/or research experience in the
`
`field of computer science or electrical engineering and their subfield of user
`
`interfaces.
`
`20. Based on my experiences and as described in ¶¶ 1-13, I have a good
`
`understanding of the capabilities of a POSITA. Indeed, I have taught, participated
`
`in organizations, and worked closely with many such persons over the course of
`
`my career, including during the mid-1990s and continuing through the present
`
`time.
`
`INTERPRETATIONS OF THE ’376 PATENT CLAIMS AT ISSUE
`
`21.
`
`I understand that, for purposes of my analysis in this inter partes
`
`review proceeding, the terms appearing in the patent claims should be interpreted
`
`according to their “broadest reasonable construction in light of the specification of
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`the patent in which it appears.” 37 C.F.R. § 42.100(b). In that regard, I understand
`
`that the best indicator of claim meaning is its usage in the context of the patent
`
`specification as understood by a POSITA. I further understand that the words of
`
`the claims should be given their plain meaning under the broadest reasonable
`
`interpretation standard, unless that meaning is inconsistent with the patent
`
`specification or the patent’s history of examination before the Patent Office (for
`
`example, where the applicant explicitly acted as a lexicographer to provide a clear
`
`and unambiguous definition of a term in the patent specification, or where the
`
`applicant provided an explicit disclaimer/disavowal of a particular claim scope). I
`
`also understand that the words of the claims should be interpreted as they would
`
`have been interpreted by a POSITA at the time the invention was made (not today).
`
`Because I do not know at what date the invention as claimed was made, I have
`
`used the filing date of the ’376 patent, which is December 21, 1998. Without
`
`exception, however, the interpretations that I provide below would have also been
`
`correct if the date of invention was anywhere within the mid to late 1990s. I have
`
`been asked to provide my interpretation of the following terms and phrases of the
`
`’376 patent set forth below.
`
`22. Claims 16, 17, 28, and 29 recite “a virtual page.” Based on my
`
`knowledge and experience in this field and my review of the ’376 patent, I believe
`
`a POSITA would have recognized that the ’376 patent provides a lexicographic
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`definition for this term. See Ex. 1001 at 1:12-23. Under the broadest reasonable
`
`interpretation standard, the term “virtual page” should be understood to mean “a
`
`two dimensional representation of data and/or program commands,” as explicitly
`
`recited in the ’376 patent. Id. This text in the ’376 patent clarifies a preferred or
`
`optional arrangement for the “virtual page” where “the two dimensions may be
`
`greater than the size of the portion of the screen available to display it so that only
`
`a portion of such data/command representation is visible in a display screen at a
`
`given time.” Id. The ’376 patent gives an “example” in which “personal computers
`
`can be used to display different data or program commands in different ‘windows’,
`
`where the virtual pages of the data and/or program commands in one or more of
`
`the ‘windows’ are larger than the windows.” Id. Accordingly, based upon my
`
`knowledge and experience in this field and my review of the ’376 patent, I believe
`
`that a POSITA would have recognized that the applicant was plainly attempting to
`
`provide its own specific definition for the phrase “virtual page” for all instances of
`
`this phrase as used in the ’376 patent. I note that this interpretation of the term “a
`
`virtual page” is also consistent with the Patent Owner’s interpretation of this term
`
`as broadly expressed in the Patent Owner’s Infringement Contentions in a
`
`concurrent district court proceeding, which indicate that a digital book having
`
`multiple pages, a PDF or other text file having multiple pages, or a collection of
`
`multiple images each satisfy this claim term. Ex. 1008 at pp. 15-19.
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`23. Claims 16 and 28 recite “a composite of two or more subpages.”
`
`Based on my knowledge and experience in this field and my review of the ’376
`
`patent, I believe a POSITA would have understood this term to mean “two or more
`
`identifiable sections of the virtual page.” This interpretation is consistent with the
`
`’376 patent specification, which discloses:
`
`“In another preferred form of this aspect of the invention, the virtual
`page includes a plurality of sub-pages with each sub-page oriented
`side-by-side with at least one of the other the sub-pages. In still
`another preferred form of this aspect of the invention, the screen
`portion is substantially as large as each sub-page. In yet another
`preferred form of this aspect of the invention, each sub-page is a
`logical unit of the virtual page.”
`Ex. 1001 at 3:7-13; see also 7:1-21. Also, based on my knowledge and experience
`
`in this field, I believe a POSITA would have recognized this interpretation as being
`
`consistent with the plain meaning of “a composite of two or more subpages” as it
`
`was normally understood and used in this field and as being consistent with the
`
`’376 patent specification (for example, as described above). Also, I believe that a
`
`POSITA would have recognized there were no clear and unambiguous attempts by
`
`the inventors to act as a “lexicographer” (in the ’376 patent specification or file
`
`history) in order to provide a meaning that departs from the plain meaning
`
`identified above. This interpretation of the term “a composite of two or more
`
`subpages” is also consistent with the Patent Owner’s interpretation of this term as
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`expressed in the Patent Owner’s Infringement Contentions, which indicate that two
`
`or more pages of a digital book, two or more pages of a PDF or other text file,
`
`portions of two or more webpages displayed on a screen, portions of two or more
`
`windows displayed on a screen, or a collection of two or more images would
`
`satisfy this claim term. Ex. 1008 at pp. 19-39.
`
`
`
`ANALYSIS OF DELORME IN VIEW OF YANO (CLAIMS 16 and 28)
`24. Based upon my knowledge and experience and my review of the prior
`
`art publications listed above, I believe that claims 16 and 28 of the ’376 patent are
`
`obvious in light of DeLorme in view of Yano. DeLorme is one of many prior art
`
`examples of a touchscreen device that, much like the embodiments claimed by the
`
`’376 patent, is configured to display virtual pages made up of subpages and receive
`
`user input to allow a user to view portions of the subpages. Ex. 1004 at 4:21-22;
`
`12:20-30; 60:59-61:5 FIGs. 1A1, 1A5, 5-5C. The disclosure of DeLorme is
`
`directed to an “integrated routing/mapping information system (IRMS)” having a
`
`touch screen for accepting user input. Ex. 1004 at 1:20-31; 4:21-22; 12:26-30. As
`
`shown below, FIG. 1A1 of DeLorme depicts a user operating a “portable PDA”
`
`which can be “implemented on a variety of state-of-art handheld palmtop portable
`
`‘personal organizer’ devices” and is configured to accept touch inputs on the touch
`
`screen “by touching, tapping, or sliding on the screen.” Ex. 1004 at 11:64-12:3;
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`12:20-30. FIG. 1A1 shows a user utilizing the touchscreen functionality of
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`DeLorme’s PDA:
`
`
`
`Ex. 1004 at FIG. 1A1.
`
`25. DeLorme further discloses providing “[a] set of electronic maps” that
`
`are divided into “discrete, identifiable, adjacent and related map tiles, quads, grids,
`
`[or] frames.” Id. at 5:65-66; 10:31-45; 60:59-65. This division of the map into
`
`“tiles” or “quadrangles” allows the user to easily view “small quadrangular units”
`
`of the map and navigate between the tiles using touch inputs rather than viewing a
`
`zoomed out map image covering a large area. Id. at 60:66-61:5; see also 26:16-19;
`
`21:33-34; 61:21-23. As I’ve indicated in the figure below (in red with a callout
`
`box and arrow), FIG. 5B shows adjacent tiles of a larger map image, including
`
`partially displayed map tiles adjacent to fully displayed map tiles:
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`Partial map tile adjacent to other
`map tiles
`
`Ex. 1004 at FIG. 5B (annotation added); 61:21-32.
`
`
`
`26. DeLorme discloses allowing a user to navigate among map tiles “by
`
`touching the screen” to select a particular map tile, which causes the map display
`
`to “pan” and “re-center on the geographic point touched by the PDA user.” Ex.
`
`1004 at 26:16-19. DeLorme also discloses receiving user input in the form of a
`
`“[t]ap [on] the map” display which causes the display to “pan/recenter” to the
`
`selected area. Id. at 21:33-34. Furthermore, a POSITA would have recognized
`
`from the teachings of DeLorme that when a user selects a portion of the map
`
`display by touching the touchscreen, the map display is panned such that selected
`
`map tile (i.e., the map tile touched by the user) is recentered and displayed in full at
`
`the center of the touchscreen display. Id. at 21:33-34; 26:16-19. For example,
`
`referring to the above annotated reproduction of FIG. 5B, if a user were to touch
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`the touchscreen at the location indicated by the red arrow that I’ve added, the map
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`display would “pan/recenter” such that the map tile indicated by the red arrow
`
`(which is only partially displayed on the screen in FIG. 5B) would be fully
`
`displayed and centered on the touchscreen display. Id. at 21:33-34; 26:16-19;
`
`12:20-30; 16:51-61. Additionally, a POSITA would understand that each of the
`
`displayed map tiles (as shown in FIG. 5B above as well as FIGs. 5, 5A, and 5C) is
`
`associated with a particular selectable portion of the touchscreen.
`
`27. Yano describes a similar system for displaying a map having different
`
`sections identified by a grid system, as shown in annotated FIG. 11:
`
`Yano’s map image
`grid coordinates
`
`
`
`Ex. 1005 at FIG. 11 (annotation added); 2:32-34; 9:21-23. Yano discloses a
`
`navigation device for use in a vehicle navigation system that includes a
`
`touchscreen configured to “display[] a map image in fixed mode in which the
`
`center of the map image shows a touched position of a touch screen.” Ex. 1005 at
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`2:32-34 (emphasis added); 9:21-23. Yano discloses two main operating modes: a
`
`“scroll mode” in which the vehicle’s current location is displayed at the center of
`
`the screen and the map scrolls as the vehicle moves and; a “fixed mode” in which
`
`the map centers on a location on the map grid selected by a user touching the touch
`
`screen at that grid location. Id. at 3:55-67.
`
`28. As set forth in more detail below, all of which is based upon my
`
`knowledge and experience in this art and my review of DeLorme and Yano, I
`
`believe that the teachings of DeLorme in view of Yano provide every element
`
`recited in claims 16 and 28 of the ’376 patent, and that there were a number of
`
`reasons (articulated in detail in ¶¶ 36-39 below) that would have prompted a
`
`POSITA to provide this resulting combination of DeLorme and Yano.
`
`[16.P] A method of controlling a touch sensitive display screen to display a
`virtual page that is larger than said display screen, said method comprising:
`29. The DeLorme reference discloses a method of controlling a touch
`
`sensitive display screen to display a virtual page that is larger than said display
`
`screen. For example, DeLorme discloses an “integrated routing/mapping
`
`information system (IRMS)” that includes a “portable PDA” which accepts touch
`
`inputs on the touch screen in the form of “touching, tapping, or sliding on the
`
`screen.” Ex. 1004 at 1:20-31; 4:21-22; 11:64-12:3; 12:20-30. DeLorme further
`
`discloses providing “[a] set of electronic maps” that are divided into “discrete,
`
`identifiable, adjacent and related map tiles, quads, grids, [or] frames” so that
`
`Page 19 of 78
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`portions of the map can be displayed on the display screen. Id. at 5:65-66; 10:31-
`
`45; 60:59-65. This division of the map into “tiles” or “quadrangles” allows the user
`
`to easily view “small quadrangular units” of the map and navigate between the tiles
`
`using touch inputs rather than viewing a zoomed out map image covering a large
`
`area. Id. at 60:66-61:5; see also 26:16-19; 21:33-34; 61:21-23.
`
`30. As shown in FIG. 5B (see below, annotation added), the map display
`
`is larger than the display screen with some of the map tiles being only partially
`
`displayed on the screen:
`
`Partial map tile adjacent to other
`map tiles
`
`
`
`Ex. 1004 at FIG. 5B (annotation added); 61:21-32. DeLorme also allows a user to
`
`pan the map display to cause portions of the map not previously displayed to be
`
`presented on the touchscreen. Ex. 1004 at 60:67-61:2; 21:30-34 (“[t]ap the map . . .
`
`to pan /recenter to different areas.”); 26:16-19. For example, if a user were to
`
`Page 20 of 78
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`touch the partially displayed map tile of FIG. 5B indicated by the red arrow
`
`(above) the map display would re-center on the selected map tile and map tiles that
`
`are off-screen in FIG. 5B (e.g. to the right of the selected, partially displayed map
`
`tile) would be displayed on the touchscreen as the map display pans to re-center on
`
`the selected tile. Accordingly, based upon my knowledge and experience in this
`
`field and my review of DeLorme and the ’376 patent, DeLorme discloses the
`
`claimed display of a “virtual page” as recited in this claim.
`
`[16.1] defining said virtual page as a composite of two or more subpages;
`
`31. The DeLorme reference discloses defining said virtual page as a
`
`composite of two or more subpages. For example, as discussed in ¶¶ 29-30 above,
`
`DeLorme discloses dividing the electronic maps into “discrete, identifiable,
`
`adjacent and related map tiles, quads, grids, [or] frames” so that portions of the
`
`map can be displayed on the display screen. Id. at 5:65-66; 10:31-45; 60:59-65.
`
`This division of the map into “tiles” or “quadrangles” allows the user to easily
`
`view “small quadrangular units” of the map and navigate between the tiles using
`
`touch inputs. Id. at 60:66-61:5; see also 26:16-19; 21:33-34; 61:21-23. DeLorme
`
`further describes “preferred embodiments” in which the system “organize[s]
`
`geographic data into tiles, grids, quads or frames” and displays the adjacent tiles to
`
`form a map display as shown in FIGs. 5, 5A, 5B, and 5C.
`
`
`
`Page 21 of 78
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`
`
`Ex. 1004 at FIGs. 5-5C; 61:12-32. As FIGs. 5-5C show, the display screen of
`
`DeLorme’s system can display several adjacent map tiles at once, including both
`
`full and partial map tiles.
`
`[16.2] displaying adjacent portions of at least two of said subpages on said
`display screen;
`32. The DeLorme reference discloses displaying adjacent portions of at
`
`least two of said subpages on said display screen. For example, as discussed in ¶ 29
`
`Page 22 of 78
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`22
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`above, DeLorme discloses dividing the electronic maps into “discrete, identifiable,
`
`adjacent and related map tiles, quads, grids, [or] frames” with multiple map tiles
`
`displayed simultaneously. Id. at 5:65-66; 10:31-45; 60:59-61:32. This division of
`
`the map into “tiles” or “quadrangles” allows the user to easily view “small
`
`quadrangular units” of the map and navigate between the tiles using touch inputs.
`
`Id. at 60:66-61:5; see also 26:16-19; 21:33-34; 61:21-23. DeLorme further
`
`describes “preferred embodiments” in which the system “organize[s] geographic
`
`data into tiles, grids, quads or frames” and displays the adjacent tiles to form a map
`
`display as shown in FIGs. 5, 5A, 5B, and 5C (reproduced above). Id. at 61:12-32.
`
`FIGs. 5, 5A, 5B, and 5C show “typical map/route display output[s]” of DeLorme’s
`
`“Integrated Routing/Mapping Information System (IRMIS)” that can be displayed
`
`as “annotate[d] maps” displaying “location information and route guidance”
`
`including “route, point and/or map information” displayed on DeLorme’s
`
`touchscreen PDA. Ex. 1004 at 57:16-43 (“FIG. 5 illustrates cartographic data
`
`structures as seen on typical map/route display output”); 12:50-53 (“touch-screen
`
`map display”).
`
`[16.3] identifying a selected subpage by sensing a touch input in an area of
`said display screen where one of said subpages is displayed; and
`33. The teachings of DeLorme in view of Yano disclose identifying a
`
`selected subpage by sensing a touch input in an area of said display screen where
`
`one of said subpages is displayed. For example, DeLorme discloses allowing a
`
`Page 23 of 78
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`user to navigate among map tiles “by touching the screen” to select a particular
`
`map tile, which causes the map display to “pan” and “re-center on the geographic
`
`point touched by the PDA user.” Ex. 1004 at 26:16-19; 12:50-53 (“touch-screen
`
`map display”). DeLorme also discloses receiving user input in the form of a “[t]ap
`
`[on] the map” display which causes the display to “pan/recenter” to the selected
`
`area. Id. at 21:33-34. Furthermore, a POSITA would have recognized from the
`
`teachings of DeLorme that when a user selects a portion of the map display by
`
`touching the touchscreen, the map display is panned such that selected map tile
`
`(i.e., the map tile touched by the user) is recentered and displayed in full at the
`
`center of the touchscreen display. Id. at 21:33-34; 26:16-19. I will next walk
`
`through an example with reference to this annotated version of FIG. 5B (displaying
`
`both partially and fully displayed map tiles):
`
`Partial map tile adjacent to other
`map tiles
`
`
`
`Page 2

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