Exhibit 12
`
`U.S. Patent No. 8,526,767 (“’767 Patent”)
`
`Invalidity Chart Based On Primary Reference U.S. Patent Application Publication No. 2007/0176906 (“WARREN”)
`
`WARREN qualifies as prior art to U.S. Patent No. 8,526,767 (“’767 Patent”) at least under 35 U.S.C. § 102(a) and anticipates and,
`alone or with other references, renders obvious one or more of claims 1-3, 6, and 11-14. To the extent WARREN does not disclose
`one or more limitations of the claims, it would have been obvious to combine the teachings of WARREN 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 ’767 Patent invalid.
`
`• U.S. Patent Application Publication No. 2009/0284478 (“BALTIERRA”)
`• U.S. Patent Application Publication No. 2007/0247435 (“BENKO”)
`• U.S. Patent No. 8,519,965 (“CADY”)
`• U.S. Patent Application Publication No. 2009/0325643 (“HAMADENE”)
`•
`Japanese Laid-Open Patent Application Gazette H09-231004 (“KATOU”)
`• U.S. Patent Application Publication No. 2009/0213084 (“KRAMER”)
`• U.S. Patent Application Publication No. 2010/0020025 (“LEMORT”)
`• U.S. Patent Application Publication No. 2008/0046425 (“PERSKI”)
`•
`International Patent Publication No. WO 00/63874 (“STRINGER”)
`• U.S. Patent Application Publication No. 2008/0036743 (“WESTERMAN”)
`• U.S. Patent Application Publication No. 2009/0225039 (“WILLIAMSON”)
`• U.S. Patent Application Publication No. 2007/0046643 (“HILLIS”) (prior art under at least 35 U.S.C. §102(b))
`• U.S. Patent Application Publication No. 2006/0066582 (“LYON”) (prior art under at least 35 U.S.C. §102(b))
`• U.S. Patent Application Publication No. 2007/0152984 (“ORDING”) (prior art under at least 35 U.S.C. §102(a))
`• U.S. Patent Application Publication No. 2007/0291009 (“WRIGHT”) (prior art under at least 35 U.S.C. §102(a))
`• Admitted Prior Art
`
`The excerpts cited herein are exemplary. For any claim limitation, Samsung 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. Similarly, where an excerpt cites to
`particular text referring to a figure, the citation should be understood to include the figure and related figures as well.
`
`1
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 1
`
`

`

`These invalidity contentions are not an admission by Samsung 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 Samsung concedes or acquiesces to any claim
`construction(s) implied or suggested by Plaintiff in its Complaint or the associated infringement claim charts. Nor is Samsung
`asserting any claim construction positions through these charts, including whether the preamble is a limitation. Samsung also does not
`concede or acquiesce that any asserted claim satisfies the requirements of 35 U.S.C. §§ 112 or 101 and submits these invalidity
`contentions only to the extent Plaintiff’s assertions may be understood.
`
`
`
`
`
`2
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 2
`
`

`

`
`
`Asserted Claims
`
`Claim 1
`
`Exemplary Disclosures
`
`
`
`[1.pre] A touch sensor device
`comprising:
`
`WARREN, alone or in combination with the knowledge of a person of ordinary skill in the art,
`discloses and/or renders obvious the touch sensor device recited in claim 1.
`
`WARREN at Abstract:
`“A proximity sensor device and method is provided that facilitates improved system usability.
`Specifically, the proximity sensor device and method provide a user with the ability to easily
`cause different results in an electronic system using a proximity sensor device as a user interface.
`For example, it can be used to facilitate user interface navigation, such as dragging and scrolling.
`As another example, it can be used to facilitate value adjustments, such as changing a device
`parameter. In general, the proximity sensor device is adapted to distinguish between different
`object combination motions, determine relative temporal relationships between those motions,
`and generate user interface results responsive to the motions. This allows a user to selectively
`generate different results using the motion of two different object combinations.”
`
`WARREN at [0002]:
`“This invention generally relates to electronic devices, and more specifically relates to proximity
`sensor devices and using a touch sensor device for producing user interface inputs.”
`
`WARREN at [0003]:
`“Proximity sensor devices (also commonly called touch pads or touch sensor devices) are widely
`used in a variety of electronic systems. A proximity sensor device typically includes a sensing
`region, often demarked by a surface, which uses capacitive, resistive, inductive, optical, acoustic
`and/or other technology to determine the presence, location and/or motion of one or more
`fingers, styli, and/or other objects. The proximity sensor device, together with finger(s) and/or
`other object(s), can be used to provide an input to the electronic system. For example, proximity
`sensor devices are used as input devices for larger computing systems, such as those found
`integral within notebook computers or peripheral to desktop computers. Proximity sensor devices
`are also used in smaller systems, including: handheld systems such as personal digital assistants
`
`3
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 3
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`(PDAs), remote controls, communication systems such as wireless telephones and text
`messaging systems. Increasingly, proximity sensor devices are used in media systems, such as
`CD, DVD, MP3, video or other media recorders or players.”
`
`WARREN at [0011]:
`“The present invention provides a proximity sensor device and method that facilitates improved
`system usability. Specifically, the proximity sensor device and method provide a user with the
`ability to easily cause different results in an electronic system using a proximity sensor device as
`a user interface. For example, it can be used to facilitate user interface navigation, such as
`dragging and scrolling. As another example, it can be used to facilitate value adjustments, such
`as changing a device parameter. In general, the proximity sensor device is adapted to distinguish
`between different object combination motions, determine relative temporal relationships between
`those motions, and generate user interface results responsive to the motions. Specifically, the
`proximity sensor device is adapted to indicate a first result responsive to detected motion of the
`first object combination, indicate a second result responsive to detected motion of the second
`object combination, the second result different from the first result, and indicate a third result
`responsive to detected motion of the first object combination following the detected motion of
`the second object combination, the third result different from first result and the second result.
`This allows a user to selectively generate different results using the motion of two different
`object combinations.”
`
`WARREN at [0012]:
`“In one specific embodiment, the proximity sensor device is implemented to facilitate continued
`cursor movement with selection, commonly referred to as “dragging” using motion of different
`object combinations. For example, the proximity sensor device is implemented to indicate
`selection with cursor movement responsive to detected motion of two adjacent objects across the
`sensing region, indicate selection without cursor movement responsive to detected motion of one
`object across the sensing region when the detected motion of one object across the sensing
`region followed the detected motion of two adjacent objects across the sensing region without an
`intervening termination event, and indicate further selection with cursor movement responsive to
`detected motion of two adjacent objects across the sensing region when the detected motion of
`
`4
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 4
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`two adjacent objects across the sensing region followed the detected motion of one object across
`the sensing region that followed the detected motion of the adjacent objects across the sensing
`region. This facilitates use of the proximity sensor device by a user to indicate results such as
`extended dragging, and is particularly useful for indicating continuing adjustments, for example,
`to facilitate dragging an object over a large distance or scrolling through a large document. This
`allows a user to continue to drag an object without requiring the user to perform more complex
`gestures on the proximity sensor device or activate extra control buttons.”
`
`WARREN at [0020]:
`“The present invention provides a proximity sensor device and method that facilitates improved
`system usability. Specifically, the proximity sensor device and method provide a user with the
`ability to easily cause different results in an electronic system using a proximity sensor device as
`a user interface. For example, it can be used to facilitate user interface navigation, such as
`dragging and scrolling.”
`
`WARREN at [0021]:
`“To cause selective results the proximity sensor device is adapted to distinguish between
`different object combination motions, determine relative temporal relationships between those
`motions, and generate user interface results responsive to the motions. Specifically, the
`proximity sensor device is adapted to indicate a first result responsive to detected motion of the
`first object combination, indicate a second result responsive to detected motion of the second
`object combination, the second result different from the first result, and indicate a third result
`responsive to detected motion of the first object combination following the detected motion of
`the second object combination, the third result different from first result and the second result.
`This allows a user to selectively generate different results using the motion of two different
`object combinations.”
`
`WARREN at [0024]:
`“In operation, proximity sensor device 116 suitably detects a position of stylus 114, finger or
`other input object within sensing region 118, and using processor 119, provides electrical or
`electronic indicia of the position to the electronic system 100. The system 100 appropriately
`
`5
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 5
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`processes the indicia to accept inputs from the user, to move a cursor or other object on a display,
`or for any other purpose.”
`
`WARREN at [0027]:
`“The processor 119, sometimes referred to as a proximity sensor processor or touch sensor
`controller, is coupled to the sensor and the electronic system 100. In general, the processor 119
`receives electrical signals from the sensor, processes the electrical signals, and communicates
`with the electronic system. The processor 119 can perform a variety of processes on the signals
`received from the sensor to implement the proximity sensor device 116. For example, the
`processor 119 can select or connect individual sensor electrodes, detect presence/proximity,
`calculate position or motion information, and report a position or motion when a threshold is
`reached, and/or interpret and wait for a valid tap/stroke/character/button/gesture sequence before
`reporting it to the electronic system 100, or indicating it to the user. The processor 119 can also
`determine when certain types or combinations of object motions occur proximate the sensor. For
`example, the processor 119 can distinguish between motion of a first object combination (e.g.,
`one finger, a relatively small object, etc.) and motion of a second object combination (e.g., two
`adjacent fingers, a relatively large object, etc.) proximate the sensing region, and can generate
`the appropriate indication in response to that motion. Additionally, the processor can distinguish
`the temporal relationship between motions of object combinations. For example, it can determine
`when motion of the first object combination has followed motion of the second object
`combination, and provide a different result responsive to the motions and their temporal
`relationship.”
`
`WARREN at [0032]:
`“It should be noted that although the various embodiments described herein are referred to as
`“proximity sensor devices”, “touch sensor devices”, “proximity sensors”, or “touch pads”, these
`terms as used herein are intended to encompass not only conventional proximity sensor devices,
`but also a broad range of equivalent devices that are capable of detecting the position of a one or
`more fingers, pointers, styli and/or other objects. Such devices may include, without limitation,
`touch screens, touch pads, touch tablets, biometric authentication devices, handwriting or
`character recognition devices, and the like. Similarly, the terms “position” or “object position” as
`
`6
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 6
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`used herein are intended to broadly encompass absolute and relative positional information, and
`also other types of spatial-domain information such as velocity, acceleration, and the like,
`including measurement of motion in one or more directions. Various forms of positional
`information may also include time history components, as in the case of gesture recognition and
`the like. Accordingly, proximity sensor devices can appropriately detect more than the mere
`presence or absence of an object and may encompass a broad range of equivalents.”
`
`WARREN at [0033]-[0034]:
`“In the embodiments of the present invention, the proximity sensor device 116 is adapted to
`provide the ability for a user to easily cause different results in an electronic system using a
`proximity sensor device 116 as part of a user interface. For example, it can be used to facilitate
`user interface navigation, such as cursor control, dragging and scrolling. As another example, it
`can be used to facilitate value adjustments, such as changing a device parameter. To cause
`selective results the proximity sensor device 116 is adapted to distinguish between different
`object combination motions, determine relative temporal relationships between those motions,
`and generate user interface results responsive to the motions. This allows a user to selectively
`generate different results using the motion of two different object combinations.
`In one specific embodiment, the proximity sensor device 116 is implemented to facilitate
`continued cursor movement with selection, a type of “dragging,” using motion of different object
`combinations. For example, the proximity sensor device 116 can be implemented to indicate
`selection with cursor movement (e.g., dragging) responsive to detected motion of two adjacent
`objects across the sensing region, indicate selection without cursor movement responsive to
`detected motion of one object across the sensing region when the detected motion of one object
`across the sensing region followed the detected motion of two adjacent objects across the sensing
`region without an intervening termination event, and indicate further selection with cursor
`movement responsive to detected motion of two adjacent objects across the sensing region when
`the detected motion of two adjacent objects across the sensing region followed the detected
`motion of one object across the sensing region that followed the detected motion of the adjacent
`objects across the sensing region. This facilitates use of the proximity sensor device 116 by a
`user to indicate results such as extended dragging over long distances. Thus, the proximity sensor
`
`7
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 7
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`device 116 allows a user to continue to drag an object without requiring the user to perform more
`complex gestures on the proximity sensor device or activate extra control buttons.”
`
`WARREN at [0036]-[0037]:
`“As described above, in the embodiments of the invention the proximity sensor device is adapted
`to distinguish between different object combination motions, determine relative temporal
`relationships between those motions, and generate user interface results responsive to the
`motions. The different object combinations can be distinguished based on a variety of different
`parameters, such as object type, object size, object proximity, pressure on the sensing region, and
`the number of objects proximate the sensing region, to list several non-limiting examples.
`As one specific example, the proximity sensor device is adapted to distinguish the number of
`objects proximate sensing region. Turning now to FIGS. 2-4, side views of exemplary object
`combinations are illustrated. Specifically, FIGS. 2-4 illustrate an embodiment where the
`proximity sensor device is adapted to distinguish between the number of fingers or other objects
`proximate the sensing region. In FIG. 2, the first object combination 202 comprises one finger
`204 proximate the sensing region 200. In FIG. 3, a second object combination 212 comprises two
`fingers 214 and 216 proximate the sensing region 200. Finally, in FIG. 4, the third object
`combination 222 comprises three fingers 224, 226 and 228. In this embodiment, the object
`position detector detects the position of the fingers proximate the sensing region, and determines
`the number of fingers present. Thus, the object position detector can determine if one, two or
`more fingers are proximate the touch sensor and generate a result responsive to the number of
`fingers and the motions of the fingers. Of course, the system could also be adapted to distinguish
`between any other quantities of objects, such as between three and four fingers, etc. It should be
`noted that such a system allows the user to easily change the object combination presented to the
`proximity sensor by selectively placing and lifting any combination of different fingers on the
`sensing area.”
`
`WARREN at [0041]:
`“As a further variation on these embodiments, the proximity sensor device can be adapted to
`determine the proximity of objects in distinguishing between object combinations. For example,
`the proximity sensor device can determine if two objects are within a specified proximity (e.g.,
`
`8
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 8
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`substantially adjacent) and distinguish the object combinations based on the number and/or
`proximity.”
`
`WARREN at [0042]-[0049]:
`“Turning now to FIG. 5, a state diagram 500 is illustrated schematically. The state diagram 500
`illustrates an implementation of a proximity sensor device adapted to distinguish between
`different object combination motions, determine relative temporal relationships between those
`motions, and generate user interface results responsive to the motions. As such, the state diagram
`500 can be implemented as part of a proximity sensor program, or as part of complete proximity
`sensor device. The state diagram 500 includes four states, an IDLE state 501, a FIRST RESULT
`state 502, a SECOND RESULT state 503, and a THIRD RESULT state 504. Each of these
`various states corresponds to a user interface action being performed in response to the various
`motions. Specifically, when in the FIRST RESULT state 502 a first user interface result is
`indicated responsive to object motion, when in the SECOND RESULT state 503 a second user
`interface result is indicated responsive to object motion, and when in the THIRD RESULT state
`504, a third user interface result is indicated responsive to object motion. The IDLE state 501
`provides an idle result.
`These indicated results can be any type of user interface action or adjustment. For example, the
`first result can comprise cursor movement without selection, the second result can comprise
`selection with cursor movement, and third result can comprise selection without cursor
`movement (e.g., with cursor movement inhibited). In such an implementation, the first result is
`providing “pointing”, the second result is providing “dragging”, the third result is providing
`continued selection without cursor motion, and the idle result occurring after a termination event.
`…
`Transitions between states are determined by detected object combination motion. For example,
`when in the IDLE state 501, detected first object combination motion (1) causes a transition to
`the FIRST RESULT state 502. Conversely, when in the IDLE state 501, detected second object
`combination motion (2) causes a transition to the SECOND RESULT state 503. When in the
`IDLE state 501, the detection of no object presence (0) causes the process to stay in the IDLE
`state 501.
`
`9
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 9
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`As a second example, when in the FIRST RESULT state 502, detected second object
`combination motion (2) causes a transition to the SECOND RESULT state 503. Conversely,
`when in the FIRST RESULT state 502, the detection of no object presence (0) causes a transition
`to the IDLE state 501. Finally, when in the FIRST RESULT state 502, the detection of first
`object combination motion (1) causes the process to stay in the FIRST RESULT state 502.
`It should be emphasized that the process illustrated in state diagram 500 can result in two
`different results responsive to the first object combination motion (1). Specifically, when in the
`FIRST RESULT state 502, first object combination motion (1) causes the first result.
`Conversely, when in the THIRD RESULT state 504, first object combination motion (1) causes
`the third result. This difference in result is determined in part by the relative temporal
`relationships between those motions. Specifically, if the first object combination motion (1) is
`following a termination event (i.e., removing the objects from the sensing region) the process
`transitions to the FIRST RESULT state 502 and the first result is indicated. If instead, the first
`object combination motion (1) is following a second result (i.e., SECOND RESULT state 503
`without an intervening termination event) the process transitions to the THIRD RESULT state
`504 and the third result is indicated.
`However, if in the SECOND RESULT state 503, and no object presence (0) for a period of time
`is detected, the no object presence (0) causes a transition to the IDLE state 501. Thus, no object
`presence of a period of time serves as a termination event, causing the next detection of a first
`object combination motion (1) to instigate a transition to FIRST RESULT state 502 instead of
`the THIRD RESULT state 504 that would have occurred without the termination event.”
`
`WARREN at [0052]-[0056]:
`“The system illustrated in FIGS. 5-13 operates as follows. After a period of inactivity, the
`proximity sensor device 600 would be in the IDLE state 501. When a user causes motion of a
`one object combination 604 (e.g., the first object combination), the process transitions to the
`FIRST RESULT state 502, and a cursor motion (a first result) is generated in response to the
`motion of the single object. This is illustrated in FIGS. 6 and 7, where the motion of the one
`object combination 604 across the sensing region 602 causes the cursor 702 to move across the
`program interface 700 and towards the icon 704.
`
`10
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 10
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`Upon moving the cursor 702 to the icon 704, the user can select the icon 704 and commence
`dragging the icon 704 by placing a second object (e.g., a second finger) on the sensing region
`602. The resulting detected motion of the two object combination 606 causes the process to
`transition to the SECOND RESULT state 503, and cursor motion with selection, referred to as
`“dragging” (a second result) is generated in response to the motion of the two object combination
`606. This is illustrated in FIGS. 8 and 9, where the motion of the two object combination 606
`across the sensing region 602 causes the cursor 702 and the selected icon 704 to be dragged
`across the program interface 700. This process continues until the object motion across the
`sensing region 602 is stopped (e.g., because the object motion has reached the edge of the
`sensing region 602 or simply by user choice).
`When continued dragging is desired, the user can reposition the objects on the sensing region
`602 without losing selection of the icon 704. Specifically, the user can remove one object from
`the sensing region 602, and move the remaining one object combination 604 back across the
`sensing region 602. This allows the user to reposition the objects without losing selection.
`Specifically, the detected motion of the one object combination 604 causes the process to
`transition to the THIRD RESULT state 504, and continued selection without cursor motion (a
`third result) is generated in response to the motion of the one object combination 604. This is
`illustrated in FIGS. 10 and 11, where the motion of the one object combination 604 across the
`sensing region 602 allows object repositioning while the icon 704 remains selected without
`causing cursor motion. This process continues until the user reaches the desired location on the
`sensing region.
`When the user reaches the desired object location and intends to continue dragging with cursor
`motion, the user can return the second object to the sensing region 602 and again moves the two
`object combination 606 across the sensing region. The detected motion of the two object
`combination 606 causes the process to again transition to the SECOND RESULT state 503, and
`dragging is continued in response to the motion of the two object combination 606. This is
`illustrated in FIGS. 12 and 13, where the motion of the two object combination 606 across the
`sensing region 602 again causes the cursor 702 and the selected icon 704 to be dragged across
`the program interface 700 until the icon 704 reaches the desired location.
`This process can be repeated as often as needed by the user. When dragging over a very large
`distance the process can be repeated many times, all without selection of the icon 704 being lost.
`
`11
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 11
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`[1.a] a sensor having a sensitive
`area extending in at least one-
`dimension and arranged to
`output sense signals responsive
`to proximity of an object to the
`sensitive area;
`
`However, if the user wishes returns to cursor motion without selection at any time, a termination
`event can be triggered, causing the process to return to the IDLE state 501. Again, in one
`embodiment the termination event can be triggered by lifting all objects from the sensing region
`for a period of time. The detection of no object presence for the period of time causes the process
`to return to the IDLE state 501, and the next detected motion of one object 604 will again trigger
`cursor motion, the first result. It should also be emphasized that an actual separate IDLE state
`501 is not required, and that process can be implemented by transitioning directly from the
`SECOND RESULT state 503 to the FIRST RESULT state 502 when a termination event occurs
`while in the SECOND RESULT state 503, and likewise transitioning directly from the THIRD
`RESULT state 504 to the FIRST RESULT state 502 when a termination event occurs while in
`the THIRD RESULT state 504.”
`
`WARREN at Claims 1-13.
`
`WARREN at FIGS. 2-13.
`
`WARREN, alone or in combination with the knowledge of a person of ordinary skill in the art,
`discloses and/or renders obvious “a sensor having a sensitive area extending in at least one-
`dimension and arranged to output sense signals responsive to proximity of an object to the
`sensitive area.”
`
`WARREN at Abstract:
`“A proximity sensor device and method is provided that facilitates improved system usability.
`Specifically, the proximity sensor device and method provide a user with the ability to easily
`cause different results in an electronic system using a proximity sensor device as a user interface.
`For example, it can be used to facilitate user interface navigation, such as dragging and scrolling.
`As another example, it can be used to facilitate value adjustments, such as changing a device
`parameter. In general, the proximity sensor device is adapted to distinguish between different
`object combination motions, determine relative temporal relationships between those motions,
`and generate user interface results responsive to the motions. This allows a user to selectively
`generate different results using the motion of two different object combinations.”
`
`
`12
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 12
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`WARREN at [0003]:
`“Proximity sensor devices (also commonly called touch pads or touch sensor devices) are widely
`used in a variety of electronic systems. A proximity sensor device typically includes a sensing
`region, often demarked by a surface, which uses capacitive, resistive, inductive, optical, acoustic
`and/or other technology to determine the presence, location and/or motion of one or more
`fingers, styli, and/or other objects. The proximity sensor device, together with finger(s) and/or
`other object(s), can be used to provide an input to the electronic system. For example, proximity
`sensor devices are used as input devices for larger computing systems, such as those found
`integral within notebook computers or peripheral to desktop computers. Proximity sensor devices
`are also used in smaller systems, including: handheld systems such as personal digital assistants
`(PDAs), remote controls, communication systems such as wireless telephones and text
`messaging systems. Increasingly, proximity sensor devices are used in media systems, such as
`CD, DVD, MP3, video or other media recorders or players.”
`
`WARREN at [0011]:
`“The present invention provides a proximity sensor device and method that facilitates improved
`system usability. Specifically, the proximity sensor device and method provide a user with the
`ability to easily cause different results in an electronic system using a proximity sensor device as
`a user interface. For example, it can be used to facilitate user interface navigation, such as
`dragging and scrolling. As another example, it can be used to facilitate value adjustments, such
`as changing a device parameter. In general, the proximity sensor device is adapted to distinguish
`between different object combination motions, determine relative temporal relationships between
`those motions, and generate user interface results responsive to the motions. Specifically, the
`proximity sensor device is adapted to indicate a first result responsive to detected motion of the
`first object combination, indicate a second result responsive to detected motion of the second
`object combination, the second result different from the first result, and indicate a third result
`responsive to detected motion of the first object combination following the detected motion of
`the second object combination, the third result different from first result and the second result.
`This allows a user to selectively generate different results using the motion of two different
`object combinations.”
`
`
`13
`
`SAMSUNG V. SOLAS
`IPR2021-01254
`Exhibit 2013
`Page 13
`
`

`

`Asserted Claims
`
`Exemplary Disclosures
`
`WARREN at [0012]:
`“In one specific embodiment, the proximity sensor device is implemented to facilitate continued
`cursor movement with selection, commonly referred to as “dragging” using motion of different
`object combinations. For example, the proximity sensor device is implemented to indicate
`selection with cursor movement responsive to detected motion of two adjacent objects across the
`sensing region, indicate selection without cursor movement responsive to detected motion of one
`object across the sensing region when the detected motion of one object across the sensing
`region followed the detected motion of two adjacent objects acro