Demonstratives of Petitioner Samsung
`
`Inter Partes Review
`U.S. Patent No. 8,170,583 (IPR2024-00153)
`
`U.S. Patent No. 8,594,698 (IPR2024-00154)
`
`U.S. Patent No. 10,341,811 (IPR2024-00155)
`
`Oral Hearing: January 21, 2025
`
`SAMSUNG EXHIBIT 1080
`Samsung Electronics Co., Ltd. v. Broadphone LLC
`IPR2024-00155
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`1
`
`

`

`IPR2024-00153 - ’583 Patent - Instituted Grounds
`
`• Ground 1: Claims 1-10 and 26 obvious in view of Spain-I,
`Hunzinger, and Nanda
`
`• Ground 2: Claims 3 and 5-6 obvious in view of Spain-I, Hunzinger,
`Nanda, and Damarla
`
`• Ground 3: Claims 7-10 obvious in view of Spain-I, Hunzinger,
`Nanda, and Houri
`
`• Ground 4: Claims 17-20 and 24-25 obvious in view of Spain-I,
`Hunzinger, Nanda, and Blomqvist
`
`-00153 Institution Decision at 6-7, 28
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`2
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`

`

`IPR2024-00154 - ’698 Patent - Instituted Grounds
`
`• Ground 1: Claims 1-7, 9-13, 15-16, and 21 obvious in view of
`Spain-I, Hunzinger, and Nanda
`
`• Ground 2: Claims 4 and 6-7 obvious in view of Spain-I, Hunzinger,
`Nanda, and Damarla
`
`• Ground 3: Claim 11 obvious in view of Spain-I, Hunzinger, Nanda,
`and Budampati
`
`• Ground 4: Claims 15-16 obvious in view of Spain-I, Hunzinger,
`Nanda, and Blomqvist
`
`-00154 Institution Decision at 6-7, 30
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`3
`
`

`

`IPR2024-00155 - ’811 Patent - Instituted Grounds
`
`• Ground 1: Claims 1, 8, 14-15, 22, 28 obvious in view of Spain-I, Hunzinger,
`and Nanda
`
`• Ground 2: Claims 4 and 18 obvious in view of Spain-I, Hunzinger, Nanda,
`and Blomqvist
`
`• Ground 3: Claims 5 and 19 obvious in view of Spain-I, Hunzinger, Nanda,
`and Tiwari
`
`• Ground 4: Claim 24 obvious in view of Spain-I, Hunzinger, Nanda, and
`Othmer
`
`• Ground 5: Claim 25 obvious in view of Spain-I, Hunzinger, Nanda, and
`Bates
`
`-00155 Institution Decision at 6, 29-30
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`4
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`

`

`Grounds/Claims Disputed by Patent Owner
`
`•
`
`IPR2024-00153, -00154
`
`• Whether the combination of Spain-I, Hunzinger, and Nanda renders claims 3 and
`5 of the ’583 patent, and claims 4 and 6 of the ’698 patent, obvious.
`
`• Whether the combination of Spain-I, Hunzinger, Nanda, and Damarla renders
`claim 5 of the ’583 patent, and claim 6 of the ’698 patent, obvious.
`
`•
`
`NOTE: Claim 3 of the ’583 patent and claim 4 of the ’698 patent are addressed by this combination,
`but Patent Owner does not present arguments directed to these claims for this ground.
`
`•
`
`IPR2024-00155
`
`• Whether the combination of Spain-I, Hunzinger, and Nanda renders claims 14
`and 28 of the ’811 patent obvious.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`5
`
`

`

`IPR2024-00153 - ’583 Patent - Claims At Issue
`
`3. The method of claim 1 wherein the chosen location signal strengths
`were measured by a second portable RF communication device, different
`from the first portable RF communication device.
`
`5. The method of claim 4 wherein the database is stored remotely, and not
`on the first portable RF communication device.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`6
`
`

`

`IPR2024-00154 - ’698 Patent - Claims At Issue
`
`4. The method of claim 2 wherein the chosen location signal strengths
`were measured by a second portable RF communication device.
`
`6. The method of claim 5 wherein the database is stored remotely from
`the first portable RF communications device.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`7
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`

`

`IPR2024-00155 - ’811 Patent - Claims At Issue
`
`14. The method of claim 1 wherein the determination of whether the
`portable RF communications device is within proximity of the device-
`specific target location is performed at a location remote from the
`portable RF communications device.
`
`28. The portable RF communications device of claim 15 wherein the
`determination of whether the portable RF communications device is
`within proximity of the device-specific target location is performed at a
`location remote from the portable RF communications device.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`8
`
`

`

`Grounds/Claims Disputed by Patent Owner
`
`•
`
`IPR2024-00153, -00154
`
`• Whether the combination of Spain-I, Hunzinger, and Nanda renders claims 3
`and 5 of the ’583 patent, and claims 4 and 6 of the ’698 patent, obvious.
`
`• Whether the combination of Spain-I, Hunzinger, Nanda, and Damarla renders
`claim 5 of the ’583 patent, and claim 6 of the ’698 patent, obvious.
`
`•
`
`NOTE: Claim 3 of the ’583 patent and claim 4 of the ’698 patent are addressed by this combination,
`but Patent Owner does not present arguments directed to these claims for this ground.
`
`•
`
`IPR2024-00155
`
`• Whether the combination of Spain-I, Hunzinger, and Nanda renders claims 14
`and 28 of the ’811 patent obvious.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`9
`
`

`

`IPR2024-00153 - ’583 Patent
`
`1. A signal-comparison based location-determining method, operable by a first portable RF communications
`device in conjunction with a plurality of fixed-location service-area antenna stations capable of RF
`communication with the first portable RF communications device wherein the antenna stations are
`substantially continuously operating, the method comprising:
`
`(a) the first portable RF communications device monitoring its location by (i) receiving
`communications signals from a first plurality of the antenna stations, (ii) identifying at least one ID
`within at least one of the received communications signals, and (iii) measuring the signal strengths
`associated with a received communications signal from the first plurality of antenna stations; and
`
`(b) the first portable RF communication device determining if a monitored location is within
`proximity of a location chosen by a user of the first portable RF communication device, as a result of
`(i) electronically comparing the at least one ID and at least one figure based on the signal strengths of
`the first plurality of antenna stations at the monitored location with the at least one ID and the at least
`one figure based on signal strengths of the first plurality of antenna stations at the location chosen
`by the user, and (ii) determining if the difference between the signal strengths measured at the
`monitored location and the signal strengths at the location chosen by the user is less than a
`predetermined threshold.
`
`3. The method of claim 1 wherein the chosen location signal strengths were measured by a second
`portable RF communication device, different from the first portable RF communication device.
`
`4. The method of claim 1 wherein the chosen location signal strengths and at least one ID originated from a
`database of geographic locations and corresponding signal strengths and IDs.
`
`5. The method of claim 4 wherein the database is stored remotely, and not on the first portable RF
`communication device.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`10
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`

`

`IPR2024-00154 - ’698 Patent
`
`1. A location-determining method, operable by a first portable RF communications device, the method
`comprising:
`
`(a) the first portable RF communications device monitoring its location by (i) receiving
`communications signals from a first plurality of fixed-location service-area antenna stations capable of
`RF communication with the first portable RF communications device wherein the antenna stations are
`substantially continuously operating, (ii) identifying at least one ID within at least one of the received
`communications signals, and (iii) measuring a varying signal characteristic other than ID, which signal
`characteristic is associated with a received communications signal from each of the first plurality of
`antenna stations; and
`
`(b) the first portable RF communications device determining if a first monitored location, monitored
`in accordance with part (a), is within proximity of a location chosen by a user of the first portable RF
`communications device, as a result of electronically comparing (i) the at least one ID at the first
`monitored location with at least one ID at the location chosen by the user and (ii) at least one number
`based on the varying signal characteristic of the communications signals from each of the first plurality
`of antenna stations at the first monitored location with at least one number based on corresponding
`varying signal characteristics of the communications signals from each of the first plurality of
`antenna stations at the location chosen by the user.
`
`2. The method of claim 1 wherein the characteristic is the communications signal’s strength, which varies
`over a range of an antenna station.
`
`4. The method of claim 2 wherein the chosen location signal strengths were measured by a second
`portable RF communication device.
`
`5. The method of claim 2 wherein the chosen location signal strengths and the at least one ID originated
`from a database of geographic locations and corresponding signal strengths and IDs.
`
`6. The method of claim 5 wherein the database is stored remotely from the first portable RF
`communications device.
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`11
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`

`

`Ground 1 (Spain-I, Hunzinger, Nanda): Claim 1
`
`In addressing claim 1’s determining step, the Petition analyzed key teachings of Spain-I, Hunzinger, and Nanda.
`
`•
`
`Spain-I
`
`•
`
`•
`
`•
`
`Describes generating/storing in a database fingerprints corresponding to selected location(s). Ex. 1011, FIG. 9, 3:42-4:63, 5:20-6:31,
`7:58-8:26, 13:16-14:37.
`
`Discloses configurations where a user can initiate a request that causes “the MU [to] capture[] the fingerprint of its current location.”
`Id., FIG. 3, 6:9-30, 6:43-47.
`
`Discloses comparing the “generated fingerprint,” which may include “signal strength” parameters, with “the fingerprints in the
`database” and choosing the MU location as the one corresponding to the “closest” matching fingerprint in the database. Id., 4:55-63,
`5:66-6:14.
`
`•
`
`Hunzinger
`
`•
`
`•
`
`Discloses a location determining system/process where a mobile device (with “position location technology”) is configured to allow a
`user to choose locations and related actions that are performed when the device is determined to be at such chosen locations. Ex. 1054,
`Abstract, FIGS. 1A-4, 1:38-2:6, 2:10-44, 3:4-67.
`
`Discloses the mobile device monitors its current location, and “compares” remembered location information with current location
`information to determine whether the device has left or entered a remembered location to execute particular actions. Id., 3:49-60, 4:21-
`57. Location information includes “station ID,” “signal conditions,” “signal strength,” etc. Id. at 4:1-12, 6:37-49, 7:9-22.
`
`•
`
`Nanda
`
`•
`
`•
`
`•
`
`Describes systems/processes that determine whether a mobile device is “in the vicinity of” a location by comparing fingerprint
`information. Ex. 1006, FIGS. 1A-1B, 2:16-59, 3:48-4:14, 5:50-7:28.
`
`Describes features that allow a mobile device user to select when to create a fingerprint, which causes fingerprint information (e.g.,
`strength/ID data) to be collected/measured while the MU is at a location chosen by the user. Ex-1006, 8:29-36, FIG. 2.
`
`Discloses storing previously monitored location information (IDs/signal strength). Ex-1006, 8:29-55, 8:56-9:13, 9:31-10:13. The
`device may “calculate a fingerprint for its current location and compare it” to the stored information. Id. at 9:17-20, 10:14-25.
`
`The Petition explained how the determining step was met regardless of where fingerprint data is stored.
`
`-00153 Petition at 11-41; -00153 Reply at 5-6; -00154 Petition at 12-41; -00154 Reply at 5-6
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`12
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`

`Ground 1 (Spain-I, Hunzinger, Nanda):
`Claims 3, 5 (-00153) / Claims 4, 6 (-00154)
`
`3. The method of claim 1 wherein the chosen location signal strengths were measured by a second
`portable RF communication device, different from the first portable RF communication device.
`
`-00153 Pet. at 42
`
`-00153 Pet. at 43
`
`-00153 Pet. at 44
`
`See also -00153 Ex. 1002 at ¶¶ 185-191; -00154 Petition at 42-45; -00154 Ex. 1002 at ¶¶ 184-190
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`13
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`

`

`Ground 1 (Spain-I, Hunzinger, Nanda):
`Claims 3, 5 (-00153) / Claims 4, 6 (-00154)
`
`Nanda Discloses Creating/Maintaining a Robust Database of
`Fingerprint Information Using Measurements From Multiple MUs
`
`Ex. 1006 at 12:14-31
`
`-00153 Petition at 41-45; -00154 Petition at 42-45
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`14
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`

`

`Ground 1 (Spain-I, Hunzinger, Nanda):
`Claims 3, 5 (-00153) / Claims 4, 6 (-00154)
`
`5. The method of claim 4 wherein the database is stored remotely, and not on the first portable RF
`communication device.
`
`-00153 Pet. at 47
`
`-00153 Pet. at 47
`
`See also -00153 Ex-1002 at ¶¶ 195-202; -00154 Ex-1002 at ¶¶ 194-201
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`15
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`

`

`Ground 1 (Spain-I, Hunzinger, Nanda):
`Claims 3, 5 (-00153) / Claims 4, 6 (-00154)
`
`5. The method of claim 4 wherein the database is stored remotely, and not on the first portable RF
`communication device.
`
`-00153 Pet. at 48
`
`Ex. 1028 at 16:42-63
`
`See also -00153 Ex. 1002 at ¶¶ 195-202; -00154 Petition at 47-48; -00154 Ex. 1002 at ¶¶ 194-201
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`16
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`

`

`Ground 1 (Spain-I, Hunzinger, Nanda):
`Claims 3, 5 (-00153) / Claims 4, 6 (-00154)
`
`Patent Owner’s Argument Regarding Drawbacks Is Misplaced
`
`• Patent Owner’s expert, Dr. Cooklev, conceded certain advantages to the
`combination.
`
`•
`
`“Q: So you agree that reducing processing requirements and reducing storage
`requirements are two separate benefits for storing the fingerprint database on the
`server, correct? A: I think I agree with that.” Ex-1079 at 93:14-18.
`
`• Even if moving the fingerprint database to a remote server may increase
`bandwidth and/or power consumption, there would still be a beneficial
`decrease in processing requirements for the MU and reduced storage
`requirements at the MU.
`
`• Medichem, S.A. v. Rolabo, S.L., 437 F.3d 1157, 1165 (Fed. Cir. 2006) (“[A] given
`course of action often has simultaneous advantages and disadvantages, and this does
`not necessarily obviate motivation to combine.”).
`
`• Winner Intern. Royalty Corp. v. Wang, 202 F.3d 1340, 1349 n.8 (Fed. Cir. 2000) (“The
`fact that the motivating benefit comes at the expense of another benefit, however,
`should not nullify its use as a basis to modify the disclosure of one reference with the
`teachings of another.”).
`
`-00153 Petition at 11-49; -00153 Reply at 6-18; -00154 Petition at 12-49; -00154 Reply at 6-18
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`17
`
`

`

`Grounds/Claims Disputed by Patent Owner
`
`•
`
`IPR2024-00153, -00154
`
`• Whether the combination of Spain-I, Hunzinger, and Nanda renders claims 3 and
`5 of the ’583 patent, and claims 4 and 6 of the ’698 patent, obvious.
`
`• Whether the combination of Spain-I, Hunzinger, Nanda, and Damarla
`renders claim 5 of the ’583 patent, and claim 6 of the ’698 patent, obvious.
`
`•
`
`NOTE: Claim 3 of the ’583 patent and claim 4 of the ’698 patent are addressed by this combination,
`but Patent Owner does not present arguments directed to these claims for this ground.
`
`•
`
`IPR2024-00155
`
`• Whether the combination of Spain-I, Hunzinger, and Nanda renders claims 14
`and 28 of the ’811 patent obvious.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`18
`
`

`

`Ground 2 (Spain-I, Hunzinger, Nanda, and Damarla):
`Claim 5 (-00153) / Claim 6 (-00154)
`
`The Petition Relied on Damarla
`
`-00153 Pet. at 62
`
`-00153 Pet. at 63
`
`-00153 Pet. at 64
`
`-00153 Pet. at 61-64; -00153 Ex. 1002 at ¶¶ 234-247; -00154 Petition at 64-67; -00154 Ex. 1002 at ¶¶ 230-243
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`

`

`Ground 2 (Spain-I, Hunzinger, Nanda, and Damarla):
`Claim 5 (-00153) / Claim 6 (-00154)
`
`Damarla Provides Additional Motivation for the Combination
`
`Ex. 1028 at 5:57-62
`
`-00153 Pet. at 61-64; -00153 Ex. 1002 at ¶¶ 234-247; -00154 Petition at 64-67; -00154 Ex. 1002 at ¶¶ 230-243
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`20
`
`Ex. 1028 at 16:42-63
`
`

`

`Ground 2 (Spain-I, Hunzinger, Nanda, and Damarla):
`Claim 5 (-00153) / Claim 6 (-00154)
`
`Patent Owner Neglects to Address Damarla
`
`• Patent Owner argues that Ground 2 does not show obviousness of
`claim 5 of the ’583 patent and claim 6 of the ’698 patent, but fails to
`address Damarla.
`
`• Patent Owner’s expert, Dr. Cooklev, similarly fails to address
`Damarla.
`
`-00153 Reply at 18-24; -00154 Reply at 18-23
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`21
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`

`

`Grounds/Claims Disputed by Patent Owner
`
`•
`
`IPR2024-00153, -00154
`
`• Whether the combination of Spain-I, Hunzinger, and Nanda renders claims 3 and
`5 of the ’583 patent, and claims 4 and 6 of the ’698 patent, obvious.
`
`• Whether the combination of Spain-I, Hunzinger, Nanda, and Damarla renders
`claim 5 of the ’583 patent, and claim 6 of the ’698 patent, obvious.
`
`•
`
`NOTE: Claim 3 of the ’583 patent and claim 4 of the ’698 patent are addressed by this combination,
`but Patent Owner does not present arguments directed to these claims for this ground.
`
`•
`
`IPR2024-00155
`
`• Whether the combination of Spain-I, Hunzinger, and Nanda renders claims
`14 and 28 of the ’811 patent obvious.
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`22
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`

`

`IPR2024-00155 - ’811 Patent
`
`1. A method of determining whether a portable RF communications device is present at a device-specific
`target location, the method comprising:
`
`with the portable RF communications device automatically:
`
`(a) receiving a first plurality of communications signals, each received from one of a first plurality of
`antenna stations within range of the portable RF communications device, wherein the antenna stations
`are fixed-location service-area antenna stations and are substantially continuously operating;
`
`(b) causing a determination of whether the portable RF communications device is within proximity of
`the device-specific target location by electronically comparing at least one number based on signal
`strengths of each of the first plurality of communications signals with at least one number based on
`corresponding signal strengths of each of a second plurality of communication signals from a second
`plurality of antenna stations that have been identified as being within range of the same location as the
`device-specific target location, which signal strengths have been determined for the same location as
`the device-specific target location; and
`
`(c) as a result of the determination that the portable RF communications device is within proximity of
`the device-specific target location, initiating, on the portable RF communications device, a location-
`based action associated with the device-specific target location.
`
`14. The method of claim 1 wherein the determination of whether the portable RF communications device is
`within proximity of the device-specific target location is performed at a location remote from the
`portable RF communications device.
`
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`23
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`

`

`IPR2024-00155 - ’811 Patent
`
`15. A portable RF communications device comprising an antenna, a user interface, and a storage device,
`wherein the storage device contains computer program code that, when executed by the portable device,
`controls the portable device to cause the portable device to perform a location-determining method, the
`method comprising automatically:
`
`(a) receiving a first plurality of communications signals, each received from one of a first plurality of
`antenna stations within range of the portable RF communications device, wherein the antenna stations
`are fixed-location service-area antenna stations and are substantially continuously operating;
`
`(b) causing a determination of whether the portable RF communications device is within proximity of
`the device-specific target location by electronically comparing at least one number based on signal
`strengths of each of the first plurality of communications signals with at least one number based on
`corresponding signal strengths of each of a second plurality of communication signals from a second
`plurality of antenna stations that have been identified as being within range of the same location as the
`device-specific target location, which signal strengths have been determined for the same location as
`the device-specific target location; and
`
`(c) as a result of the determination that the portable RF communications device is within proximity of
`the device-specific target location, initiating, on the portable RF communications device, a location-
`based action associated with the device-specific target location.
`
`28. The portable RF communications device of claim 15 wherein the determination of whether the portable
`RF communications device is within proximity of the device-specific target location is performed at a
`location remote from the portable RF communications device.
`
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`

`

`IPR2024-00155 - Claim Construction
`
`• Regarding the “device-specific target location” term, Broadphone
`argues:
`
`• “As explained by Dr. Cooklev [Broadphone’s expert], the plain
`meaning requires a target location that is specific to a particular
`device, not a location that is generally applicable to numerous
`devices.” -00155 POR at 5.
`
`• Broadphone’s interpretation of the claim term should be rejected
`because it is vague and, to the extent capable of being understood,
`inconsistent with the intrinsic record. -00155 Reply at 1-5.
`
`-00155 Reply at 1-5
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`

`

`IPR2024-00155 - Claim Construction
`
`Broadphone’s Construction Has Numerous Problems
`
`•
`
`It is unclear what type of location Broadphone is referring to when it refers to
`a location that is “specific to a particular device” and that is not “generally
`applicable to numerous devices.”
`
`• Under Broadphone’s construction:
`
`• A user-selected location may or may not be a device-specific target location. Ex. 1079
`at 51:9-54:9.
`
`• Whether two different devices can share the same device-specific target location
`“depends” on unknown factors. Id. at 109:7-21.
`
`• Unclear what constitutes “numerous devices.” Id. at 110:16-112:16, 113:12-22.
`
`• Unclear how a location can be “specific to a particular device.” Id. at 114:5-116:22,
`123:4-124:14.
`
`• Dr. Cooklev was unable to provide a single example of a target location that is
`specific to a particular device under his understanding. Id. at 117:5-122:13.
`
`• Dr. Cooklev repeatedly asserted that the boundaries of the claim element are
`not “crisply defined.” Id. at 120:3-8, 120:14-15, 121:4-11, 146:21-147:1.
`
`-00155 Reply at 2-3
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`

`

`IPR2024-00155 - Claim Construction
`
`The Specification Makes Clear a Device-Specific Target Location
`Can Apply to More Than One Device
`
`-00155 Ex. 1001 at 7:2-6
`
`-00155 Ex. 1001 at 9:7-14
`
`-00155 Ex. 1001 at 12:53-58
`
`-00155 Reply at 3-4
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`

`

`IPR2024-00155 - Claim Construction
`
`Broadphone’s Prosecution History Statements Indicate a
`Device-Specific Target Location Refers to a User-Selected Location
`
`-00155 Ex. 1004 at 128
`
`-00155 Ex. 1004 at 136
`
`-00155 Reply at 4-5
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`28
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`

`

`IPR2024-00155 - Claims 14 and 28
`
`The Petition Demonstrated the Spain-I-Hunzinger-Nanda Combination
`Teaches the Device-Specific Target Location of Claims 14 and 28
`
`-00155 Pet. at 10
`
`-00155 Pet. at 17
`
`-00155 Pet. at 21
`
`-00155 Pet. at 13
`
`-00155 Reply at 6-12
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`

`

`IPR2024-00155 - Claims 14 and 28
`
`The Petition Demonstrated the Spain-I-Hunzinger-Nanda Combination
`Teaches the Device-Specific Target Location of Claims 14 and 28
`
`-00155 Pet. at 58
`
`-00155 Pet. at 58
`
`-00155 Reply at 6-12
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`

`

`IPR2024-00155 - Claims 14 and 28
`
`The Petition Demonstrated the Spain-I-Hunzinger-Nanda Combination
`Teaches the Device-Specific Target Location of Claims 14 and 28
`
`Ex. 1011 (Spain-I) at 6:9-30
`
`-00155 Pet. at 58-60; -00155 Reply at 9-12
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`31
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`

`

`IPR2024-00155 - Claims 14 and 28
`
`The Petition Demonstrated the Spain-I-Hunzinger-Nanda Combination
`Teaches the Device-Specific Target Location of Claims 14 and 28
`
`Ex. 1006 (Nanda) at 12:14-31
`
`-00155 Pet. at 58-60; -00155 Reply at 9-12
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2024-00155 - Claims 14 and 28
`
`Broadphone’s Argument Against Claims 14 and 28
`Is Based on a False Premise
`
`• Broadphone argues that “the database of locations and fingerprints” of
`the proposed combination “would be applicable to multiple devices …
`which directly undermines the Petition’s contention that the stored
`locations would be device-specific.” POR at 7.
`
`• But the claims do not require “a database of device-specific locations.”
`
`• The claims require a determination as to “whether [a] portable RF
`communications device is within proximity of [a] device-specific target location”
`and doing so by comparing against signal strengths. Ex. 1001 at 26:60-27:5; see
`also id. at 28:18-29.
`
`• The claims do not say that the signal strengths are device-specific, as Broadphone
`appears to suggest.
`
`-00155 Reply at 6-7
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`IPR2024-00155 - Claims 14 and 28
`
`Broadphone’s Expert Agreed That Two Devices May Share
`the Same Device-Specific Target Location
`
`Ex. 1079 at 109:7-21
`
`-00155 Reply at 11-12
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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