`Apple Inc.
`v.
`Zentian Limited
`Patent 10,839,789
`
`Patent Owner’s Demonstratives
`
`Presented March 12, 2024
`
`1
`
`
`
`Argument Roadmap
`
`v Smyth alone cannot teach the recited “single IC”
`v The combination of Smyth and Mozer lacks a
`motivation
`v Petitioner has failed to prove a reasonable expectation
`of success
`
`2
`
`
`
`Argument Roadmap
`
`v Smyth alone cannot teach the recited “single IC”
`v The combination of Smyth and Mozer lacks a
`motivation
`v Petitioner has failed to prove a reasonable expectation
`of success
`
`3
`
`
`
`Smyth alone cannot teach the recited “single IC”
`
`Smyth’s state memory 342 was not on same IC as classifier processor 341
`
`Smyth
`
`Schmandt
`
`Dr. Anderson
`Sur-reply at 1-4, Ex. 2020 ¶¶ 40-41, Ex. 1009 at 4, Ex. 1005 Fig. 3
`
`4
`
`
`
`Smyth alone cannot teach the recited “single IC”
`
`Motorola DSP56000 could not fit the 4.8 kb to 5.5 kb that Mr. Schmandt said would be required
`
`Kloker
`
`Dr. Anderson
`Sur-reply at 1-4, Ex. 2020 ¶¶ 40-41, Ex. 2021 at 21:23-22:10; Ex. 1009 at 4
`
`5
`
`
`
`Argument Roadmap
`
`v Smyth alone cannot teach the recited “single IC”
`v The combination of Smyth and Mozer lacks a
`motivation
`v Petitioner has failed to prove a reasonable expectation
`of success
`
`6
`
`
`
`Smyth + Mozer lacks a motivation
`
`Petition’s “offloading” motivation fails
`
`Petition
`
`Dr. Anderson
`
`Mozer
`
`Sur-reply at 5-7, Ex. 2020 ¶¶ 48-49, Ex. 1046, Abstract, 9:22-26, 10:46-53
`
`7
`
`
`
`Smyth + Mozer lacks a motivation
`
`Petition’s “no CPU Hold” motivation fails
`
`Mr. Schmandt
`
`Dr. Anderson
`
`Sur-reply at 7-10, Ex. 2020 ¶ 53, Ex. 2021 at 36:2-12, 35:2-6
`
`8
`
`
`
`Smyth + Mozer lacks a motivation
`
`Petitioner’s reliance on Dr. Anderson’s testimony fails
`
`Dr. Anderson was discussing the
`invention of the ’789 Patent
`
`Dr. Anderson said Nguyen does
`not teach the IC of the claims
`
`Sur-reply at 10-11; Ex. 1069 at 88:17-89:2, 92:12-21
`
`9
`
`
`
`Argument Roadmap
`
`v Smyth alone cannot teach the recited “single IC”
`v The combination of Smyth and Mozer lacks a
`motivation
`v Petitioner has failed to prove a reasonable expectation
`of success
`
`10
`
`
`
`Petitioner has failed to prove
`a reasonable expectation of success
`
`Mr. Schmandt admitted that Mozer’s on-chip “vector memory” is not the
`“acoustic model memory”
`
`Sur-reply at 12-15; Ex. 2021 at 31:15-21
`
`11
`
`
`
`Petitioner has failed to prove
`a reasonable expectation of success
`
`Petitioner’s combination requires fabricating a new IC
`
`Sur-reply at 12-15; Ex. 2020 ¶¶ 54-62; Pet. 41-43
`
`12
`
`
`
`Petitioner has failed to prove
`a reasonable expectation of success
`
`Petitioner concedes that POSA could not fabricate
`Smyth’s processor 341 and state memory 342 on one IC
`
`Petitioner’s combination requires fabricating a new IC; the
`claims do not recite fabrication. Pet. at 41-42.
`
`Petitioner has identified no prior art “commercially
`available IC” that meets the challenged claims
`
`Sur-reply at 12-15; Ex. 2020 ¶¶ 54-62; Pet. 41-43
`
`13
`
`
`
`Petitioner has failed to prove
`a reasonable expectation of success
`
`Boike and Ozcelink not directed to speech recognition and
`did not have “acoustic model memory”
`
`Motorola DSP56000 did not have the recited “acoustic
`model memory” on single IC with its processor
`
`Toyoda never teaches its processor and acoustic model
`memory were on a single IC
`
`Sur-reply at 12-15; Ex. 2020 ¶¶ 34-45
`
`14
`
`
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