`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`
`APPLE INC.,
`
`Petitioner
`
`v.
`
`SMITH INTERFACE TECHNOLOGIES, LLC,
`
`Patent Owner
`
`______________
`
`IPR2024-01256
`Patent No. 11,740,727
`______________
`
`
`DECLARATION OF RAJEEV SURATI, Ph.D.
`
`
`
`
`
`
`
`Apple Inc. v. Smith Interface Techs., LLC
`IPR2024-01256 | Smith EX2001
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`TABLE OF CONTENTS
`INTRODUCTION ................................................................................................................................. 1
`
`PROFESSIONAL BACKGROUND .......................................................................................................... 1
`
`COMPENSATION .............................................................................................................................. 10
`
`LEGAL CONSIDERATION ................................................................................................................... 10
`
`I.
`
`II.
`
`III.
`
`IV.
`
`A. Obviousness ................................................................................................................................... 10
`B.
`Claim Interpretation ...................................................................................................................... 11
`V.
`Overview of Task & Basis for Opinions ............................................................................................ 12
`
`VI.
`
`Level of Skill in the Relevant Art ...................................................................................................... 13
`
`VII. OVERVIEW OF THE ’727 PATENT ..................................................................................................... 14
`
`Independent Claim 1 ...................................................................................................................... 16
`A.
`VIII. OVERVIEW OF THE PRIOR ART ........................................................................................................ 17
`
`A. U.S. Patent App. No. 2008/0207188 (“Ahn”) ................................................................................. 17
`1.
`Directional Key Operation ......................................................................................................... 19
`2.
`Touch and Drag Operation ........................................................................................................ 20
`3.
`Start Position Operation ............................................................................................................ 22
`B. U.S. Patent App. No. 2007/0150842 (“Chaudhri-842”) ................................................................. 23
`1.
`Unlocking a Device via Gestures ................................................................................................ 24
`2.
`Indication of Progress Towards Satisfaction of a User Input Condition .................................... 26
`IX.
`GROUND 1: DR. TERVEEN’S ANALYSIS FAILS TO SHOW OBVIOUSNESS OF CLAIM 1 BY AHN AND
`CHAUDHRI-842 ............................................................................................................................................ 28
`
`Limitation [1.d] ............................................................................................................................... 28
`A.
`Dr. Terveen fails to Show Ahn’s Graphical Shadow Moves ....................................................... 29
`1.
`2.
`Ahn-Chaudhri-842 would not increase magnitude of the change in appearance of Ahn’s clock
`widget as a function of an increase in the distance magnitude of the gesture.................................. 31
`3.
`Ahn-Chaudhri-842 would not blur during detection of the gesture and before a completion of
`the gesture is detected ....................................................................................................................... 33
`4.
`Dr. Terveen’s Proposed Ahn-Chaudhri Combination does not flow from the teachings of Ahn
`or Chaudhri-842 .................................................................................................................................. 50
`5.
`Dr. Terveen’s Proposed Modification Would Not Achieve the Functionality Allegedly
`Motivating the Proposed Combination .............................................................................................. 60
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`X.
`x.
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`CONCLUSION ................................................................................................................................... 70
`CONCLUSION 0... cccesescseesseecseecseecsuecssscssscssusesrssersscesssnsssnesseeesaescaeecseecsessseusserseersesrssenssensssnsssneeseeeseeess 70
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`I.
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`INTRODUCTION
`1. My name is Dr. Rajeev Surati, Ph.D. I have been retained by Smith
`
`Interfaces Technologies, LLC as an independent expert consultant in this inter partes
`
`review (“IPR”) proceeding before the United States Patent and Trademark Office
`
`(“PTO”).
`
`II.
`
`PROFESSIONAL BACKGROUND
`All of my opinions stated in this Declaration are based on my own
`2.
`
`personal knowledge and professional judgment. In forming my opinions, I have
`
`relied on my knowledge and experience in designing, developing, and researching
`
`the technology referenced in this Declaration.
`
`3.
`
`I am over 18 years of age and, if I am called upon to do so, I would be
`
`competent to testify as to the matters set forth herein. I understand that a copy of
`
`my current curriculum vitae, which details my education and professional and
`
`academic experience, is being submitted as EX2002. The following provides a brief
`
`overview of some of my experience that is relevant to the matters set forth in this
`
`Declaration.
`
`4.
`
`I hold a Doctor of Philosophy (Ph.D.) degree in Electrical Engineering
`
`and Computer Science from the Massachusetts Institute of Technology (“MIT”)
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`(awarded in 1999) with a Grade Point Average of 5.0/5.0. I obtained a Master of
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`Science degree in Electrical Engineering and Computer Science from MIT (awarded
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`in 1995) with a Grade Point Average of 5.0/5.0. I have a Bachelor of Science degree
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`in Electrical Engineering from MIT (awarded 1992), graduating with a Grade Point
`
`Average of 4.9/5.0.
`
`5. My Ph.D. thesis was entitled “Scalable Self-Calibrating Technology for
`
`Large Scale Displays.” My master’s thesis was entitled “Practical Partial
`
`Evaluation.” My undergraduate thesis, for which I received MIT EECS’s William
`
`A. Martin thesis prize for best undergraduate thesis, was entitled “A Parallelizing
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`Compiler based on Partial Evaluation.” I was also awarded the Department of
`
`Energy’s highly-selective Computational Science Fellowship in 1995, which funded
`
`my Ph.D. studies.
`
`6.
`
`In 1989, I began programming embedded systems and, in 1995, built
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`one of the first publicly available Internet Coke Machines. During that time, I
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`worked on various user interfaces. For example, one to augment the coke machine
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`to dispense coke and another that became one of the early ecommerce mechanisms,
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`using standards-based protocols for tracking user consumption, payments, and drink
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`stock.
`
`7.
`
`In 1997, while at MIT pursuing my Ph.D., I started a company called
`
`Flash Communications. At Flash, I invented an instant messaging platform focused
`
`on enterprise needs. I had the idea while observing the popularity of the Zephyr
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`Instant Messaging Service at MIT beginning in 1988. Attracted by Flash’s
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`enterprise focus, Microsoft acquired Flash in 1998. With Microsoft, we built both a
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`client and server product. The basic protocol we invented became the foundation
`
`for the well-known XMPP protocol that was widely used in the mid-2000s among
`
`instant messaging providers. I developed both the client and server products and
`
`dealt with many, if not all, of the issues one might face when implementing user
`
`interfaces for instant messaging systems. In fact, we helped to build Microsoft’s
`
`famous MSN product, which adopted various user interface elements we created.
`
`8.
`
`As a result of this experience, I became heavily involved with User
`
`Interface design on desktop machines, experience that I have continued to develop
`
`by building desktop, mobile, and web-based applications used by millions of people.
`
`9.
`
`After graduating, I joined Microsoft (as was required by Microsoft in
`
`its acquisition of Flash Communications), where I worked on both client and server
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`technologies related to instant messaging. My work spanned both the Microsoft
`
`Exchange Instant Messaging product that was released in 2000 and MSN Messenger.
`
`10. From 2000 to 2007, I cofounded, led, and sold a business called
`
`photo.net to Namemedia, which is now part of GoDaddy.com. In early 2000,
`
`Photo.net was considered a top 1,000 website and it received large amounts of
`
`traffic. I built the site from its beginning as a single computer installed in a
`
`datacenter to a full rack of computers in that same data center. As a result, I became
`
`very familiar with the careful design and programming one must employ to build
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`and maintain systems that enable both engaging user interfaces and experiences at
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`scale.
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`11. At photo.net, we prototyped many fundamental Internet community
`
`features, such as photo sharing, social networking, and memberships. The photo.net
`
`system was written on top of Oracle SQL Database and served up many millions of
`
`web pages each day (corresponding to millions of records) with high-volume inserts.
`
`The system also incorporated an ecommerce platform used to bill subscriptions,
`
`track users, etc. I spent seven years running the site, both writing new features driven
`
`by the Oracle SQL database and maintaining tables containing the many millions of
`
`records generated by the site. I also served as the database administrator, which
`
`provided me with extensive operational experience running such a system. I dealt
`
`with everything from database query speedup to the more mundane day-to-day
`
`issues, such as the maintenance of relational databases, including backups. In
`
`addition to the web interface, we also ran a mobile version of the product based on
`
`WAP, which I helped to develop.
`
`12. After developing one of the first photo sharing sites, we further
`
`increased user engagement by designing an innovative photo rating interface. Our
`
`photo rating system became a huge draw for the site. The rating system increased
`
`engagement by four orders of magnitude, ultimately resulting in Sergey Brin,
`
`cofounder of Google, asking photo.net to provide imagery to Google for a screen
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`saver application. Joichi Ito, former head of the MIT Media Lab and a famous
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`internet luminary called it “the best photo sharing site” in 2001.
`
`13.
`
`I also innovated user interface technology at Nexaweb, where I was an
`
`investor and technical advisor. Nexaweb designed User Interfaces that worked well
`
`over the web. At Nexaweb, I spent a great deal of time solving underlying issues
`
`related to implementing a UI framework both in Java and Javascript. We also
`
`innovated a mechanism using server push prior to the AJAX becoming widely
`
`adopted.
`
`14.
`
`In 2004, I started Scalable Display Technologies based on the
`
`technology in my Ph.D. thesis and the related patent (U.S. Patent No. 6,456,339)
`
`entitled “Super-resolution Display.” As part of my Ph.D. thesis, I designed a special
`
`display that allows one to create ultra-high-resolution displays composed of multiple
`
`projectors tiled with a slight overlap. The system uses camera-based feedback to
`
`create an inverse map that drives the system such that a person can only see a
`
`continuous, seamless display. There is no visible bezel or overlap. During this
`
`project, I became familiar with how and why to drive content onto the display. Thus,
`
`I also became familiar with content encoding/decoding, user interfaces for driving
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`large displays, multimedia content storage, high resolution imagery, networks,
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`recording, GPUs, storage of content, etc.
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`15. At Scalable Display Technologies, I developed the core algorithms and
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`implemented—with a team—the entire software system, which included the core
`
`user interface, machine vision and embedded components, and a multimedia
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`playback system. Our first customer was Pixar. Today, the software is primarily
`
`used by the US military and commercial theme parks, such as Disney and Universal.
`
`Scalable is well-known in the industry for having some of the easiest and intuitive
`
`software to use.
`
`16.
`
`In parallel with my work at Scalable, I lectured at MIT on many
`
`subjects, including the Android operating system. In 2008, I worked with a group
`
`of MIT students on the development of mobile applications for Android with Rich
`
`Miner, a cofounder of Android. Since many students created applications involving
`
`Google Maps and localization, I became familiar with these technologies. I also
`
`served as a lecturer and mentor at MIT Play Labs, which was an incubator for
`
`augmented reality (AR) and virtual reality (VR) software for mobile handsets and
`
`headset applications. Notably, in addition to mobile handsets, Android runs on the
`
`Oculus headset. As part of that program, I worked with several startup companies
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`on mobile applications, including a startup that developed applications for Telegram,
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`which is a cross-platform, cloud-based instant messaging system.
`
`17. Since 2014, I have worked as an independent consultant for several
`
`companies including NEC, Hitachi, Hi Marley, and Estee Lauder.
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`18.
`
`In 2018, I became a senior partner at nCent Labs. In that role, I
`
`consulted on the development of an incentive-market-based platform for block
`
`chains and cryptocurrency. Another part of my work at nCent Labs focused on the
`
`development of SMS messaging applications for the nCent platform. In that part, I
`
`developed a full stack application around the protocol.
`
`19. From 2019 to 2020, I served as a Technical Lead of the Skunkworks at
`
`Hydrow, which is a startup company that develops indoor rowing machines. In this
`
`role, I worked on special projects, including the development of a VR experience
`
`using Magic Leap and Oculus that immersed users in a team-based rowing crew on
`
`a scull using VR cinematography. I leveraged my experience with user interfaces
`
`and Human-Computer Interaction (“HCI”) to develop a system that gives people a
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`sense of rowing on the water with others, while in reality, they were rowing on a
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`rowing machine.
`
` We accomplished our goal through a clever use of
`
`cinematography. The result was quite compelling and increased user engagement
`
`with their exercise program.
`
`20.
`
`In 2020, I started a company called Skyline Nav AI Inc. that develops
`
`technology that uses a visual location (i.e., the skyline) to geo-locate the place a
`
`picture was taken. At Skyline, I built and now maintain a full user experience
`
`centered around a workflow for people to snap a picture and use the image’s skyline
`
`and downloaded 3D mode to localize a person. I have written applications for both
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`Android and iOS that communicate with a backend server running the machine
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`vision algorithms.
`
`21. Over the past decade, I have served as a technical consultant and expert
`
`witness on patent litigation matters. In the course of this work, I have provided
`
`consulting services to a wide variety of technology companies, including
`
`BritishTelecom, Apple,
`
`IBM, Philips, Shopify, Zillow, Polaris Powered
`
`Technologies, Amazon, Salesforce, Hitachi, Slack, Harris Teeter, and others.
`
`22. During the course of my career, I was the inventor of the subject matter
`
`for approximately 15 U.S. Patents. I have also received additional patents,
`
`including: U.S. Patent No. 8,817,111, entitled “System and method of calibrating a
`
`display system free of variation in system input resolution,” U.S. Patent No.
`
`8,994,757, “System and method for providing improved display quality by display
`
`adjustment and image processing using optical feedback,” U.S. Patent No.
`
`9,215,455, “System and method of calibrating a display system free of variation in
`
`system input resolution,” U.S. Patent No. 9,369,683, “System and method for
`
`calibrating a display system using manual and semi-manual techniques,” and U.S.
`
`Patent No. 9,497,447, “System and method for color and intensity calibrating of a
`
`display system for practical usage.”
`
`23.
`
`I am also a co-inventor of patented technology related to instant
`
`messaging, including U.S. Patent No. 5,943,478, which describes associated
`
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`technology that I developed related to pop-up, two-way messaging over the Internet.
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`While at Microsoft, I was an inventor on several patents, including: U.S. Patent No.
`
`6,260,148 relating to methods and systems for message forwarding and property
`
`notifications using electronic subscriptions; and U.S. Patent Nos. 6,415,318 and
`
`6,604,133 relating to inter-enterprise messaging systems using bridgehead servers.
`
`Aspects of these patents relate specifically to messaging and notification technology
`
`in telecommunications systems.
`
`24.
`
`I serve on the advisory boards of several technology companies,
`
`including Paneve, which develops general purpose ASICs coupled with compiler
`
`technology; Nexaweb, which develops real-time web application frameworks using
`
`HTTPS; Antix Labs, which develops compiler technology for a universal gaming
`
`platform; and Permabit, which develops content-addressable storage.
`
`25.
`
`In addition to my above experience, I have published papers on subjects
`
`relating to computing systems, computer network communications, databases, and
`
`other subjects within the realm of electrical and computer engineering. I have also
`
`received several awards for my contributions as an inventor and entrepreneur,
`
`including the Global Indus. Technovator Award 2009 and Laureate of 2009
`
`Computer World Honors Program. My publication and award history are listed in
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`more detail on my CV.
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`III. COMPENSATION
`26. My work on this matter is being billed at my customary rate of $700 an
`
`hour. Also, I am being reimbursed for reasonable expenses I incur in relation to my
`
`services. I have no pecuniary interest in the outcome of this proceeding. I
`
`understand I will be paid regardless of the outcome of any proceeding in which my
`
`work is used.
`
`IV. LEGAL CONSIDERATION
`I am not an attorney. My understanding of the law is based on
`27.
`
`information provided by counsel for Smith Interface Technologies, LLC.
`
`A. Obviousness
`I understand that a claimed invention is obvious and, therefore, not
`28.
`
`patentable if the subject matter claimed would have been obvious to a person of
`
`ordinary skill in the art at the time that the invention of the ’727 Patent (a
`
`“POSITA”), which I have been asked to treat as August 5, 2011.
`
`29.
`
`I understand that a claim can be obvious in view of a single prior art
`
`reference (e.g., via modification of that prior art reference) or multiple prior art
`
`references (e.g., via a combination of two or more prior art references), if such a
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`modification or combination was within the skill of a POSITA. I understand that
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`there must be some articulated reasoning with some rational underpinning to support
`
`a conclusion of obviousness. I also understand that to establish a finding of
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`obviousness one must show that one of ordinary skill in the art would have had a
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`motivation to combine the prior art references to produce the claimed invention and
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`a reasonable expectation that the combination would be successful.
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`30.
`
` I further understand that exemplary rationales that may support a
`
`conclusion of obviousness include: (1) simply arranging old elements in a way in
`
`which each element performs the same function it was known to perform, and the
`
`arrangement yields expected results, (2) merely substituting one element for another
`
`known element in the field, if the substitution yields no more than a predictable
`
`result, (3) combining elements in a way that was “obvious to try” because of a design
`
`need or market pressure, where there was a finite number of identified, predictable
`
`solutions, (4) that design incentives or other market forces in a field would have
`
`prompted variations in a work that were predictable to a person of ordinary skill in
`
`the art, and (5) that there was some teaching, suggestion, or motivation in the prior
`
`art that would have led a POSITA to modify or combine prior art references to arrive
`
`at the claimed invention.
`
`B. Claim Interpretation
`I understand that a claim term is interpreted according to its ordinary
`31.
`
`and customary meaning as a POSITA would have understood the term in light of the
`
`surrounding claim language, other claims, the specification, and the patent’s
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`prosecution history, which are referred to as intrinsic evidence. I also understand
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`that prior art references cited in the patent’s prosecution history are considered
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`intrinsic evidence. I further understand that evidence outside the patent and its
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`prosecution history (e.g., dictionaries and technical articles), may inform the context
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`in which a POSITA would have understood the claims of a patent. I understand this
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`ordinary and customary meaning applies absent unique circumstances, such as
`
`where a patent clearly expresses an intent to set forth a special meaning for a term.
`
`V. Overview of Task & Basis for Opinions
`I have been asked to review the ’727 Patent. I have been asked to
`32.
`
`provide opinions related to certain issues from the perspective of a person of ordinary
`
`skill, having knowledge of the relevant art, as of August 5, 2011, and—except where
`
`otherwise noted—the opinions stated in this declaration are from that perspective.
`
`The qualifications and abilities of such a person are described in paragraph 38 below.
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`33. More particularly, I have been informed that this proceeding is
`
`currently at a preliminary stage during which the Patent Trial and Appeal Board (the
`
`Board) will decide whether the Petition establishes a reasonable likelihood of at least
`
`one claim of the ’727 Patent being invalid. I also understand that the Board may
`
`review the Petition under a stricter “compelling merits” standard that requires the
`
`Petition to make a stronger showing of invalidity; however, my analysis is not
`
`performed using this higher standard. At this preliminary stage, I have been asked
`
`to focus my analysis on the Petition’s proposed invalidity theories for the ’727
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`Patent’s independent claim 1.
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`34. My opinions are based on my education, training, and experience as
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`well as items that I reviewed to prepare my opinions, including the Petition, the
`
`documents listed in the Exhibit List included with the Petition, and any other items
`
`that I reference in my below analysis.
`
`35.
`
`I understand that other issues may arise that require further explanation,
`
`and I will provide that explanation if appropriate. As a result, I respectfully reserve
`
`the right to update and supplement this declaration and the information and opinions
`
`provided herein.
`
`VI. Level of Skill in the Relevant Art
`I understand that a patent must be analyzed from the perspective of a
`36.
`
`person of ordinary skill in the art (“POSITA”) as of the time of invention of the
`
`patent, which is typically considered to be the patent’s earliest filing date. While I
`
`do not necessarily agree with every aspect of Dr. Terveen’s explanation of the level
`
`of ordinary skill in the art, I do not currently believe the aspects of that explanation
`
`I would change or clarify would impact the analysis set forth in this declaration. For
`
`purposes of this declaration, my opinions are therefore provided from the perspective
`
`of the POSITA described by Dr. Terveen’s declaration (EX1003) as of August 5,
`
`2011, which is produced below:
`
`“a Bachelor of Science degree in computer science, computer
`
`engineering, electrical engineering, human-computer interaction, or a
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`comparable field and at least two years of professional experience in
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`the design and development of graphical user interfaces (GUIs),
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`human-computer interfaces, or equivalents thereof. Such experience
`
`could be obtained through research and study in a graduate program or
`
`through comparable exposure through industry employment, and
`
`additional years of experience could substitute for the advanced-level
`
`degree.”
`
`EX1003, ¶28.
`
`VII. OVERVIEW OF THE ’727 PATENT
`37. The ’727 Patent describes devices, methods, and graphical user
`
`interfaces for manipulating user interface objects with visual and/or haptic
`
`feedback. See EX1001, at Title.
`
`38. The ’727 Patent describes a mobile device having various components,
`
`including user interface devices such as a touch screen. EX1001, 13:41-58. In
`
`operation, signals can be received in association with the touch interface (e.g., touch
`
`screen) and can correspond to a signal indicative of a touch interface being
`
`touched. Id., 14:11-33. The user experience can then be altered utilizing these touch
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`signals. Id., 15:19-31, FIG. 3.
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`39. An example of these operations can be seen in FIG. 18, where attributes
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`of touch events are detected, and gesture inputs related to these touch event attributes
`
`(both initial and over time) can be identified. EX1001, 56:8-35.
`
`
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`EX1001, FIG. 18.
`
`
`
`40. These attributes can include the duration and/or distance of a gesture
`
`because often different gestures will be indistinguishable based on initial
`
`contact. EX1001, 56:8-35, 60:43-47. Once
`
`the gesture
`
`is
`
`identified, a
`
`corresponding operation can be performed (step 1808). EX1001, 56:50-51. Such
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`operations can include the modification of one or more display attributes such as
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`blurring the display attributes. EX1001, 57:9-10, 68:37-52.
`
`41.
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`In some operations, “a user may be given feedback as a gesture is
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`performed.” Id., 59:23-24. For example, some “gestures may be associated with
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`operations that are carried out as functions of the gesture input” EX1001, 58:58-
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`59:3. In this way, the device can provide a user with feedback as a gesture is
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`performed. See EX1001, Title (visual feedback), 59:23-29, FIG. 18 (step 1802
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`showing continuous detection of touch event as gesture is performed).
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`A.
`42.
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`Independent Claim 1
`Independent claim 1 is directed to a “device” having one or more
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`processors that are configured to execute instructions that cause the device to
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`perform functions. EX1001, 102:31-50. Specifically, claim 1 recites
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`[1.a] A device, comprising: at least one non-transitory memory; a touch
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`screen; and one or more processors in communication with the at least one
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`non-transitory memory, and the touch screen, wherein the one or more
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`processors execute instructions in the at least one non-transitory memory, to
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`cause the device to:
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`[1.b] display an object and at least one other object;
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`[1.c] detect at least part of a gesture on the touch screen; and
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`[1.d.i] during detection of at least a portion of the gesture before a
`completion thereof is detected, blur, based on a change in a distance
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`magnitude of the gesture being detected on the touch screen to thereby
`move the object on the touch screen, at least a portion of the at least one
`other object that is not overlapped
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`[1.d.ii] such that a magnitude of the blur itself, and not a magnitude of
`an area of the touch screen that is blurred, is increased as a function of
`an increase in the distance magnitude.
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`EX1001, 102:31-50.
`VIII. OVERVIEW OF THE PRIOR ART
`43. Dr. Terveen primarily relies on two cited references for his invalidity
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`analysis. See EX1003, ¶62 (the Ahn-Chaudhri combination).
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`A. U.S. Patent App. No. 2008/0207188 (“Ahn”)
`44. As depicted in FIG. 2 (inset below), Ahn discloses a mobile
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`communication terminal that includes a display 40 along with a key input device 30
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`and a touch input device (e.g., element 10 in FIG. 1). EX1004, Abstract, ¶[0027].
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`45. Ahn’s proposed operation attempts to solve the problem where device
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`characteristics are unavailable when a menu list is displayed. EX1004, ¶¶[0005]-
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`[0006]. In conventional browsers, the standby screen disappears when a menu
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`screen is displayed. Thus, Ahn proposes to provide menus that only take up a portion
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`of the display so that the standby screen can still be displayed concurrently with the
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`menu.
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`46. Against this backdrop, Ahn discloses a method of displaying menus in
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`a mobile communication terminal, where each menu can correspond with a selection
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`of one of a plurality of specific directions associated with the menus. EX1004,
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`Abstract (“menu corresponding to the selected specific direction on the standby
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`screen”). In Ahn, the menu is displayed after an input (e.g., after selection of
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`direction key (¶[0034]) or after a touch and drag operation (¶[0102])) is completed.
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`If the input is not completed, the menu will not open and will remain closed (i.e., not
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`displayed). See e.g., EX1004, ¶[0116] (menu can be displayed “if the touch and
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`drag operation of the user is completed”).1
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`47. As described in more detail below, Ahn discloses three separate
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`methods for displaying its menu via the use of directional keys, a simple touch and
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`drag operation, and via a start position operation.
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`Directional Key Operation
`1.
`In a first embodiment, Ahn describes a method of displaying a menu
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`48.
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`via a selection of a specific direction on a direction key. See EX1004, ¶¶[0030],
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`[0034]-[0035]. As shown in FIGs. 7A-7C, a menu (e.g., setting menu 720/820) can
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`be accessed “when a leftward direction key is selected.” Id., ¶[0062]. This operation
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`starts “when the standby screen 300 is displayed on the display 40.” Id., ¶[0063].
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`After the “user selects the leftward direction key 38,” an icon 710 is “displayed
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`around the center of the standby screen 300” and then “disappears while moving to
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`1 All emphasis added unless otherwise noted.
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`[the] left” side of the screen. Id. A menu associated with the direction of the user’s
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`completed input is then displayed. Id.
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`49. This operation is illustrated in greater detail below, in which three
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`graphical settings are displayed to the user.
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`First, the standby screen 300 is displayed. EX1004, ¶[0035]. Next, after the left
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`direction key is pressed (i.e., the gesture is completed), an icon 710 is displayed and
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`fades to the lefthand side of the screen to provide the user with feedback as to the
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`operation associated with the left direction key. Id., ¶[0063]. Finally, once the icon
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`710 disappears, a menu 720 is displayed on the lefthand side of the standby screen
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`300. Id.
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`Touch and Drag Operation
`2.
`In another embodiment, Ahn describes a method of displaying a menu
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`50.
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`via “a touch and drag operation of a specific direction.” Id., ¶[0101], see also
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`¶¶[0102]-[0104]. As shown in FIGs. 15A-15B of Ahn (inset below), “if the user
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`touches screen 10 and drags the touch in a rightward direction, a menu list 1500
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`matched to a right direction is displayed in the display 40.” Id., ¶[0103].
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`I