UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLE LLC
`
`Petitioner,
`
`v.
`
`DDC TECHNOLOGY, LLC,
`
`Patent Owner
`
`U.S. Patent No. 11,093,001
`
` Case No.: IPR2023-00711
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`PETITIONER’S DEMONSTRATIVE EXHIBITS
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`FOR ORAL ARGUMENT
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GOOGLE LLC
`
`Petitioner,
`
`v.
`
`DDC TECHNOLOGY, LLC,
`
`Patent Owner
`
`U.S. Patent No. 11,093,001
`
` Case No.: IPR2023-00711
`
`PETITIONER’S DEMONSTRATIVE EXHIBITS
`
`FOR ORAL ARGUMENT
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`Petitioner hereby submits its demonstrative exhibits for use at the oral
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`argument scheduled for August 7, 2024.
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`Dated: August 5, 2024
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`Respectfully submitted,
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`Michael L. Kiklis______
`
`Michael L. Kiklis
`Reg. No. 38,939
`Attorney for Petitioner
`Google LLC
`
`
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`
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`1
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`
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`Google LLC v. DDC Technology, LLC
`IPR2023-00707 (Patent 9,420,075)
`IPR2023-00708 (Patent 9,811,184)
`IPR2023-00709 (Patent 10,528,199)
`IPR2023-00711 (Patent 11,093,001)
`
`Petitioner Google’s Oral Hearing Demonstratives
`
`Michael L. Kiklis
`Kiklis Law Firm, PLLC
`Lead counsel for Petitioner
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`1
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`
`
`The Cases
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`Case No.
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`Patent No.
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`Challenged Claims
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`00707
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`00708
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`00709
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`00710
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`00711
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`9,420,075
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`1-12, 14, and 18-20
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`9,811,184
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`1-5, 7-10, 12, and 16-18
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`10,528,199
`
`11,093,000
`
`11,093,001
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`1, 2, 4–6, 17–26, 30, 34,
`35, and 37–39
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`1–6 and 8–33
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`1–30
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`2
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`
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`The Patents
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`Virtual Reality Viewer and Input Mechanism. EX1001, title.*
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`EX1001, 1:20-26.
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`*All exhibits refer to IPR2023-00707,
`unless noted otherwise. All annotations
`and highlighting to figures added,
`unless noted otherwise.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`3
`
`
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`The Patents (cont’d)
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`The ’075 patent describes and claims a virtual reality viewer (VR
`viewer) configured to hold a mobile electronic device and has an
`input device. The patent admits that VR viewers were well-known
`at the time of the alleged invention and so were input devices for
`interacting with these viewers. Pet., p. 1; EX1001, 1:30-2:10, cl. 1.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`4
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`
`
`The Patents (cont’d)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`5
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`EX1001, cl. 1.
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`
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`The Patents (cont’d)
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`Pet., p. 16; EX1001, Figs. 7C, 7E
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`6
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`
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`The Patents (cont’d)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`7
`
`EX1023, 29:6-13; Reply, fn 3.
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`
`
`The Patents (cont’d)
`PO claims its distinguishing feature is “the user input mechanism,”
`a conductive/capacitive input mechanism in general.
`Reply, p. 24; POR, p. 66; EX2054, ¶¶3, 4, 6, 7.
`
`During prosecution, PO faced an
`anticipation rejection based on Compton
`(US 2013/0141360) which discloses a
`conductive/capacitive input mechanism
`on a VR viewer. Reply, p. 24;
`EX1022, ¶¶0044-0050;
`cls. 1, 6, 9, 10, 11, 14; Figs. 1-6b.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`00711 Reply, p. 15; see also Pet. p. 18.
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`8
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`
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`The Patents (cont’d)
`PO has admitted that a conductive/capacitive input mechanism is not novel.
`Reply, p. 24.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`9
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`Pet., p. 17; Reply, p. 25; EX1008, p. 22.
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`
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`Claim Construction
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`Virtual Reality Viewer: “A viewer of an artificial environment, where
`“viewer” includes both handheld devices and headsets.
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`Electrical Shield/Electric Shield: “A material configured to induce a touch
`event that is electronically detectable by a touchscreen/device when at least
`a portion of the shield contacts or is in proximity to a touchscreen.
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`Lever: “A projecting piece by which a mechanism is operated or adjusted.”
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`Pet., pp. 22-23.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`10
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`
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`Claim Construction: Lever
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`11
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`Pet., p. 26
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`Claim Construction: Lever (cont’d)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`12
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`Pet., p. 27
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`
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`Claim Construction: Lever (cont’d)
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`“[T]he electro-mechanical input mechanism.”
`EX1001, Abstract; see also, 10:57-60.
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`POR, p. 12-13 (citing Oxford Dictionary of Mechanical Engineering)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`13
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`Claim Construction: Lever (cont’d)
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`POR, p. 16 (citing American Heritage Dictionary of the English Language)
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`14
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`Claim Construction: Lever (cont’d)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`15
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`Reply, p. 8 (citing POR, p. 92)
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`
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`Claim Construction: Lever (cont’d)
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`Reply, p. 9 (citing PO’s infringement contentions
`EX1011, p. 117 (annotations in original))
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`16
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`
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`Claim Construction: Claims 7 and 8
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`EX1001, cls. 7, 8.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`17
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`
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`Claim Construction: Claims 7 and 8 (cont’d)
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`EX1001, 7:52-56.
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`EX1001, 10:61-67.
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`EX1001, 8:52-55; see also 8:40-9:9, 10:39-45,
`10:45-54.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`18
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`
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`The Prior Art: Kondo
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`19
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`Pet., p. 46; EX1003, Fig. 1.
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`
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`The Prior Art: Kondo
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`Pet., p. 47; EX1003, Fig. 5.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Pet., p. 31; EX1003, Fig. 8(2).
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`EX1003, ¶¶0023-0024 (“the touch panel
`1506 is a projected capacitive touch
`panel”); Reply, p. 12.
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`20
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`
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`The Prior Art: Chu
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`21
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`Pet., p. 54; EX1004, Fig. 1.
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`
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`The Prior Art: Chu
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Pet., p. 57; EX1004, Figs. 4, 5.
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`22
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`The Prior Art: Chu
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`23
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`Pet., p. 35; EX1004, Figs. 7a, 7b.
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`
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`The Combination
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Pet., p. 40 (Chu’s input device Emb. 1 in Kondo’s Fig. 5)
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`24
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`
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`The Combination
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Pet., p. 40 (Chu’s input device Embs. 2, 3 in Kondo’s Fig. 5)
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`25
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`
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`Motivations to combine Kondo and Chu
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`1. To work with both capacitive and resistive touchscreens.
`2. Both Kondo and Chu face a similar problem, the external activation of the smartphone’s touchscreen
`enclosed in that device.
`3. The combination allows differing levels of pressure applied to input mechanism, which can be interpreted as
`differing inputs, thus providing a wider range of input at a single location, rather than just binary input.
`4. To add a swipe input.
`5. To provide waterproof capabilities, making the device less susceptible to damage from water and other
`environmental factors, like dirt and dust.
`6. To allow the device to be cleaned without the fear of cleaning fluid reaching the device’s inner parts. This
`can be important for use in a sanitary environment (e.g., during a medical procedure or in a manufacturing
`facility, like a semiconductor fabrication facility).
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`Reasonable expectation of success: Both Kondo and Chu are simple mechanical devices. Thus, a POSA
`would have a reasonable expectation of success. In fact, a POSA would consider the combination’s formation to
`be merely routine, requiring little skill.
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`Pet., pp. 38-39.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`26
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`
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`Claim 10: Chu discloses a compressible pad
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Reply p. 18; EX1004, Fig. 4.
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`27
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`
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`Claim 12: Kondo/Chu disclose a lever
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`Pet., p. 99 (Chu’s input device Embs. 2, 3 in Kondo’s Fig. 5)
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`28
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`
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`Claim 18: “disposed on” must encompass
`an indirect connection
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`EX1001, Cl. 18
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`29
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`
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`Claim 18 (cont’d):
`“disposed on”
`must encompass
`an indirect
`connection
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Pet., p. 101; EX1001, Fig. 7A.
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`30
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`
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`Claim 18 (cont’d):
`“disposed on” must encompass an indirect connection
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`EX1001, 10:67-11:4; POR, p. 48.
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`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`31
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`CERTIFICATE OF SERVICE
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`The undersigned certifies service pursuant to 37 C.F.R. §§ 42.6(e) of
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`PETITIONER’S DEMONSTRATIVE EXHIBITS FOR ORAL ARGUMENT by
`
`filing this document through the USPTO Patent Trial and Appeal Case Tracking
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`System and by emailing a copy to the following email addresses:
`
`cortneyalexander@kentrisley.com
`haller@haller-iplaw.com
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`Dated: August 5, 2024
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`
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`
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`Michael L. Kiklis______
`
`Respectfully Submitted,
`
`Michael L. Kiklis
`Reg. No. 38,939
`Attorney for Petitioner
`Google LLC
`
`2
`
`
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