Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`META PLATFORMS, INC.,
`Petitioner
`
`v.
`
`MULLEN INDUSTRIES LLC,
`Patent Owner.
`
`
`Case IPR2025-00743
`U.S. Patent No. 11,947,716 B2
`Issue Date: April 2, 2024
`
`Title: WIRELESS DEVICES WITH FLEXIBLE MONITORS AND
`KEYBOARDS
`
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 11,947,716 B2
`
`
`
`
`

`

`Table of Contents
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`
`Page
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`
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`I. 
`
`MANDATORY NOTICES UNDER §42.8(A)(1) ......................................... 1 
`A. 
`Real Party-In-Interest under §42.8.(b)(1) ............................................. 1 
`B. 
`Related Matters under §42.8(b)(2) ....................................................... 1 
`C. 
`Lead and Back-Up Counsel under §42.8(b)(3) .................................... 1 
`D. 
`Service Information .............................................................................. 2 
`FEE PAYMENT ............................................................................................. 2 
`II. 
`III.  REQUIREMENTS UNDER §§ 42.104 AND 42.108 AND
`CONSIDERATIONS UNDER §§ 314(A) AND 325(D) ............................... 3 
`A.  Grounds for Standing ........................................................................... 3 
`B. 
`Identification of Challenge and Statement of Precise Relief
`Requested ............................................................................................. 3 
`Considerations Under §§ 314(a) and 325(d) ........................................ 3 
`C. 
`IV.  OVERVIEW OF THE PATENT .................................................................... 4 
`A. 
`Level of Ordinary Skill ........................................................................ 4 
`B. 
`Specification Overview ........................................................................ 4 
`CLAIM CONSTRUCTION ........................................................................... 5 
`V. 
`VI.  THE CHALLENGED CLAIMS ARE UNPATENTABLE ........................... 6 
`A.  Overview of Grounds ........................................................................... 6 
`B. 
`Prior Art Status of Relied-Upon References ...................................... 11 
`A.  Ground 1: Claims Are Obvious Over Ronzani in View of
`Horton and Ohshima .......................................................................... 12 
`Independent Claim 16: “[a] head-mounted device
` 
`comprising:” (16[pre]) ............................................................ 12 
`(a) 
`“a head-mounted power source;” (Claim 16[a]) .......... 15 
`(b) 
`“a head-mounted manual input;” (Claim 16[b]) ........... 16 
`(c) 
`“a head-mounted processor;” (Claim 16[c])................. 19 
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`-i-
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`Table of Contents
`(continued)
`
`Page
`
`(d) 
`
`(e) 
`
`(f) 
`
`(g) 
`
`“a head-mounted movement sensor;” (Claim
`16[d]) ............................................................................. 24 
`“a top-of-the-head mounting structure;” (Claim
`16[e]) and “a behind-the-head mounting
`structure;” (Claim 16[f]) ................................................ 30 
`“a head-mounted display operable to cover at least
`a portion of at least one eye of a wearer of said
`head- mounted device, wherein a first virtual
`object is operable to be displayed on said head-
`mounted display and controlled with manual input
`and a second virtual object is operable to be
`displayed on said head mounted display and
`controlled autonomously by said processor; and”
`(Claim 16[g]) ................................................................. 33 
`“a head-mounted camera, wherein information
`from said head-mounted camera is operable to be
`displayed on said head-mounted display
`simultaneously with said first virtual object and
`said second virtual object.” (Claim 16[h]) ................... 43 
`Claim 18: “The apparatus of claim 16, wherein:” (Claim
`18[pre]) ..................................................................................... 48 
`(a) 
`“said head-mounted camera is pointed in a field-
`of- vision of said wearer and operable to capture
`said information, wherein said information
`comprises a portion of said wearer’s actual world
`environment; and” (Claim 18[a]) ................................. 49 
`“said display is operable to display said
`information comprising said portion of said
`wearer’s actual world environment captured by
`said camera simultaneously with said first virtual
`object and said second virtual object.” (Claim
`18[b]) ............................................................................. 50 
`Ground 2: Claims 1 and 8 Are Obvious Over Ronzani in view
`of Horton, Natoli, and Peli. ................................................................ 51 
`-ii-
` 
`
` 
`
`(b) 
`
`
`
`B. 
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`  
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`

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`Table of Contents
`(continued)
`
`Page
`
`
`
` 
`
`(b) 
`(c) 
`(d) 
`
`(e) 
`
`(f) 
`
`Independent Claim 1: “An apparatus comprising:”
`(Claim 1[pre]) .......................................................................... 51 
`(a) 
`“a head-wearable device comprising at least one
`housing, said at least one housing comprising:”
`(Claim 1[a]) ................................................................... 51 
`“a speaker” (Claim 1[b]) ............................................... 52 
`“a microphone; and” (Claim 1[c]) ................................ 56 
`“a movement sensor, wherein said movement
`sensor comprises an accelerometer;” (Claim 1[d]) ...... 58 
`“a manual input operably coupled to said head-
`wearable device;” (Claim 1[e])..................................... 59 
`“wherein said head-wearable device further
`comprises:” (Claim 1[f]) ............................................... 60 
`(1) 
`“a display operable to cover at least a
`portion of at least one eye of a wearer of
`said head-wearable device, wherein said
`display is operable to display a virtual object
`and to allow said wearer of said head-
`wearable device to view, simultaneously
`with said virtual object, a portion of said
`wearer’s actual world environment; and”
`(Claim 1[f][1]) ..................................................... 60 
`“a camera pointed in a field-of-vision of said
`wearer and operable to capture an image of
`said portion of said wearer’s actual world
`environment;” (Claim 1[f][2]) ............................ 68 
`“wherein said display is operable to display said
`image of said wearer’s actual world environment
`taken by said camera simultaneously with said
`virtual object.” (Claim 1[g]) ......................................... 76 
`
`(2) 
`
`(g) 
`
`  
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`-iii-
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`

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`Table of Contents
`(continued)
`
`Page
`
`
`
` 
`
`Claim 8: “The apparatus of claim 1, wherein said display
`comprises: a first display covering at least a portion of a
`first eye of said wearer; and a second display covering at
`least a portion of a second eye of said wearer.” (Claim
`8[pre]) ....................................................................................... 77 
`VII.  CONCLUSION ............................................................................................. 78 
`CERTIFICATE OF SERVICE ............................................................................... 80 
`
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`-iv-
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`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
`
`List of Exhibits
`
`
`
`
` 
`
`
`
`
`Exhibit
`Description of Document
`No.
`1001 U.S. Patent No. 11,947,716 B2 to Jeffrey David Mullen (filed Jan. 13,
`2023, issued Apr. 2, 2024) (“’716” or “’716 patent”)
`1002 Declaration of Jeremy Cooperstock, Ph.D. (“Cooperstock”)
`1003 U.S. Patent App. Pub. No. 2002/0163486 A1 to Peter A. Ronzani et al.
`(filed May 16, 1997; published Nov. 7, 2002) (“Ronzani”)
`1004 U.S. Patent No. 5,615,132 to Mike A. Horton et al., “Method and
`Apparatus for Determining Position and Orientation of a Movable
`Object Using Accelerometers” (filed Jan. 21, 1994; issued Mar. 25,
`1997) (“Horton”)
`1005 U.S. Patent No. 6,951,515 B2 to Toshikazu Ohshima et al., “Game
`Apparatus for Mixed Reality Space, Image Processing Method Thereof,
`and Program Storage Medium” (filed Feb. 17, 2000; issued Oct. 4,
`2005) (“Ohshima”)
`1006 U.S. Patent No. 6,611,618 B1 to Eliezer Peli, “Wide-Band Image
`Enhancement” (filed Jan. 22, 1999; issued Aug. 26, 2003) (“Peli”)
`1007 U.S. Patent No. 6,388,657 B1 to Anthony James Francis Natoli,
`“Virtual Reality Keyboard System and Method” (filed Dec. 31, 1998;
`issued May 14, 2002) (“Natoli”)
`1008 Proof of Service of Complaint
`
`‐i‐ 
`
` 
`
`

`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
`
`I. MANDATORY NOTICES UNDER §42.8(A)(1)
`A. Real Party-In-Interest under §42.8.(b)(1)
`Meta Platforms, Inc. is the real party-in-interest to this IPR petition.
`
`B. Related Matters under §42.8(b)(2)
`The ’716 patent is the subject of pending litigation involving Petitioner:
`
`Mullen Industries LLC v. Meta Platforms, Inc., Case No. 1:24-cv-00354-DAE (W.D.
`
`Tex.). Petitioner was served on April 5, 2024. (EX1008, p.003.)
`
`Petitioner is filing IPR petitions against twelve related patents asserted by
`
`Patent Owner in the pending litigation involving Petitioner:
`
`U.S. Patent No.
`8,585,476 B2
`9,744,448 B2
`10,179,277 B2
`10,828,559 B2
`10,967,270 B2
`11,033,821 B2
`11,376,493 B2
`11,904,243 B2
`11,947,716 B2
`12,019,791 B2
`9,662,582 B2
`10,974,151 B2
`
`IPR Case
`IPR2025-00737
`IPR2025-00738
`IPR2025-00739
`IPR2025-00740
`IPR2025-00702
`IPR2025-00703
`IPR2025-00741
`IPR2025-00742
`IPR2025-00743
`IPR2025-00744
`IPR2025-00745
`IPR2025-00746
`
`
`
`
`
` 
`
`C. Lead and Back-Up Counsel under §42.8(b)(3)
`Petitioner provides the following designation of counsel.
`-1-
` 
`
`

`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
`
`
`LEAD COUNSEL
`
`BACK-UP COUNSEL
`
`Heidi L. Keefe (Reg. No. 40,673)
`hkeefe@cooley.com
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, DC 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
`
`Phillip E. Morton (Reg. No. 57,835)
`pmorton@cooley.com
`
`Andrew C. Mace (Reg. No. 63,342)
`amace@cooley.com
`
`Mark R. Weinstein (Admission pro hac
`vice to be requested)
`mweinstein@cooley.com
`
`Lowell D. Mead (Admission pro hac vice
`to be requested)
`lmead@cooley.com
`
`Patrick Lauppe (Admission pro hac vice to
`be requested)
`plauppe@cooley.com
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave. NW, Suite 700
`Washington D.C. 20004
`
`
`
`D.
`Service Information
`This Petition is being served by Federal Express to the attorney of record for
`
`the ’716 patent, 32733 - JEFFREY D. MULLEN, 2212 Hassinger Lane, Glenshaw,
`
`PA 15116. Petitioner consents to electronic service at the addresses provided above
`
`for lead and back-up counsel.
`
`FEE PAYMENT
`Petitioner requests review of four claims, with a $51,875 payment.
`
`-2-
`
` 
`
`II.
`
` 
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`
`
`

`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
`
`III. REQUIREMENTS UNDER
`42.104 AND
`§§
`CONSIDERATIONS UNDER §§ 314(A) AND 325(D)
`A. Grounds for Standing
`Petitioner certifies that the ’716 patent is available for IPR and that Petitioner
`
`42.108 AND
`
`is not barred or otherwise estopped.
`
`B.
`
`Identification of Challenge and Statement of Precise Relief
`Requested
`Petitioner requests IPR institution based on:
`
`Ground
`
`Claims
`
`Basis for Challenge under §103
`
`1
`
`2
`
`16 and 18
`
`Ronzani in view of Horton and Ohshima
`
`1 and 8
`
`Ronzani in view of Horton, Natoli, and Peli
`
`Submitted herewith is the expert declaration of Jeremy Cooperstock, Ph.D.
`
`(EX1002) (“Cooperstock”). (EX1002, ¶¶1-18, Appendix A.)
`
`C. Considerations Under §§ 314(a) and 325(d)
`§314(a): The General Plastic factors are inapplicable as this is the first and
`
`only IPR petition filed regarding the ’716 patent.
`
`The Fintiv factors do not support discretionary denial under §314(a). The
`
`pending litigation against Petitioner is in early stages. Trial is scheduled for October
`
`5, 2026. Petitioner’s motion to transfer venue is pending, which if granted would
`
`likely move trial even later. Petitioner intends to move to stay the litigation pending
`
` 
`
`
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`-3-
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` 
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`

`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
`
`resolution of the IPRs. If IPR is instituted, Petitioner will not pursue in litigation
`
`any invalidity defense that was or could have been raised in IPR.
`
`§325(d): No §325(d) issue is raised here. No relied-upon reference was cited
`
`during prosecution. Ronzani is a continuation-in-part of cited U.S. Patent No.
`
`5,815,126, but both grounds raise obviousness combinations that were not cited and
`
`are not cumulative of any presented combinations.
`
`Petitioner reserves the right to address and respond to any assertions that
`
`Patent Owner may raise regarding discretionary factors.
`
`IV. OVERVIEW OF THE PATENT
`A. Level of Ordinary Skill
`A person of ordinary skill (“POSITA”) would have possessed a bachelor’s
`
`degree in electrical engineering, computer science, or similar field, with two years
`
`combined experience in designing and/or developing computer systems/software
`
`involving interactive graphical virtual and/or augmented reality. A person could
`
`also have qualified as a person of ordinary skill in the art with some combination of
`
`(1) more formal education (such as a master’s of science degree) and less technical
`
`experience, or (2) less formal education and more technical or professional
`
`experience. (Cooperstock, ¶¶21-25.)
`
`B.
`Specification Overview
`The ’716 patent “relates to improved portable devices” and “portable devices
`
` 
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`-4-
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`

`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`with enlarged, and improved, display and input components.” (’716, 1:30-32.) The
`
`patent purports to provide “[a]n improved portable device … that includes both a
`
`flexible display screen and a flexible keyboard.” (’716, 1:53-54.) According to the
`
`patent, “[a] number of systems and methods for displaying information to a user of
`
`a portable device is also provided. For example, virtual bifocals are provided in head-
`
`mounted systems such that a user can work in a virtual world (e.g., check email from
`
`an email server or surf the internet on a browser) while working in an actual world
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`(e.g., while walking to work in the morning).” (’716, 2:31-38.)
`
`The patent further contemplates a head-mounted camera to capture still or
`
`video images. (’716, 14:53-15:3.) An infrared camera could be used to capture an
`
`image that is displayed: “For example, infrared and night vision cameras can be
`
`utilized. The information received from these cameras can be displayed on the
`
`display screen.” (’716, 14:57-60.)
`
`V. CLAIM CONSTRUCTION
`Petitioner does not believe express claim construction is necessary at this
`
`time. The prior art renders the challenged claims obvious under any reasonable
`
`construction.
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` 
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`-5-
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`

`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
`
`VI. THE CHALLENGED CLAIMS ARE UNPATENTABLE
`A. Overview of Grounds
`The challenged claims attempt to lay claim to head-mounted displays with
`
`physical components and “virtual” display features that were well-known before the
`
`’716 patent.
`
`Both grounds rely on Ronzani (EX1003), which discloses most of the
`
`elements of the challenged claims. Ronzani describes head-mounted display
`
`(“HMD”) embodiments strikingly similar to those claimed by the ’716 patent.
`
`Ronzani teaches “head mounted displays” comprising display elements, “computer
`
`system,” “manually adjustable controls,” “user interface,” and other components
`
`“for numerous applications including commercial, industrial and entertainment
`
`purposes.” (Ronzani, ¶¶0005-0016.) Ronzani proceeds to describe numerous
`
`exemplary embodiments of a head-mounted display device as illustrated throughout
`
`Ronzani’s written description and figures. (Ronzani, ¶¶0017-0281, Figs. 1-70.)
`
`Ronzani explains that “the particular head and/or body mounted display systems
`
`embodying the invention [are] shown by way of illustration only” and “[t]he
`
`principles and features of this invention may be employed in varied and numerous
`
`embodiments without departing from the scope of the invention.” (Ronzani, ¶0017.)
`
`Ronzani also teaches the applicability of head-mounted displays to a wide
`
`variety of applications, including “simulation such as virtual imaging[,]”
`
` 
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`-6-
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`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`“entertainment purposes,” and other uses.1 (Ronzani, ¶¶0002, 0005 (“The present
`
`invention relates generally to systems and methods for mounting display and
`
`electronic systems on the human body for numerous applications including
`
`commercial, industrial and entertainment purposes.”).) Consistent with these
`
`teachings, Ronzani describes that its system may use “a virtual keyboard using
`
`motion sensitive gloves” and “a virtual reality data glove.” (Ronzani, ¶¶0007, 0170.)
`
`Both grounds rely on combination with Horton (EX1004). (Cooperstock,
`
`¶¶55-58.) Horton discloses and renders obvious claim elements that recite a head-
`
`mounted “movement sensor” that may comprise an “accelerometer,” namely
`
`Claim 16[d] (“a head-mounted movement sensor”) and Claim 1[d] (“a movement
`
`sensor, wherein said movement sensor comprises an accelerometer”). As noted
`
`previously, Ronzani discloses HMD devices for use in various applications such as
`
`virtual simulations and entertainment. Horton explains the need to accurately
`
`determine the user’s position and orientation in virtual reality or other simulated
`
`environments. (Horton, 1:13-22.) To address that stated need, Horton teaches the
`
`use of accelerometers to track movement. Horton specifically teaches that the
`
`accelerometers can be placed on an HMD to track movement of the user’s head.
`
`
`1 All underlining added to quoted material unless noted.
` 
`-7-
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`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`(Horton, 2:16-21, 3:41-62 (“the tracking invention could be implemented on an
`
`HMD and two data gloves to track head and hand movement of a user”).)
`
`Ground 1 further relies on Ohshima (EX1005), which describes a head-
`
`mounted mixed-reality game that displays “virtual” objects. (Cooperstock, ¶¶60-
`
`66.) Specifically, Ohshima teaches the “first virtual object . . . controlled with
`
`manual input” and “second virtual object . . . controlled autonomously” of
`
`Claims 16 and 18. Ohshima describes a game system including an HMD with a
`
`camera that displays images of the real world along with “virtual” objects in a
`
`“mixed reality” environment. (Ohshima, 1:8-14, 6:19-54, 7:17-38.) Specifically,
`
`Ohshima describes a mixed reality game where the player can use a simulated “gun”
`
`controller to shoot virtual “bullets” at virtual “spacemen” (also called “targets”).
`
`Figure 1 of Oshima
`
`illustrates
`
`the overall game environment
`
`including
`
`spacemen/targets 20-24 and virtual bullet 30.
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`-8-
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`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`
`
`
`(Ohshima, Fig. 1.)
`
`Disclosing the “first virtual object” being “controlled with manual input”
`
`per claim 16[g], Ohshima describes that when the user points the gun-shaped
`
`controller 1004 and performs an “action of a trigger” or “shooting action,” a virtual
`
`“bullet” is fired in the direction indicated by the user. (Ohshima, 5:64-67, 6:57-63.)
`
`Disclosing the “second virtual object” being controlled “autonomously” by
`
`a processor per Claim 16[g], each virtual spaceman/target
`
`is controlled
`
`autonomously by the system with behavior that appears to the user “as if it had its
`
`own will and objective” and “as if a virtual object (target) decided its own movement
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`pattern” without user control. (Ohshima, 5:57-59, 6:1-8, 8:18-29, 11:18-30.)
`
`Ground 2 relies on combination with Peli (EX1006), which describes a head-
`
`mounted display with infrared camera that captures and displays an image, much
`
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`-9-
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`

`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`like the ’716 patent. (Cooperstock, ¶¶68-71.) Peli discloses and renders obvious the
`
`features of Claim 1[f]-[g] regarding a head-wearable device with a “display is
`
`operable to display a virtual object and to allow said wearer of said head-
`
`wearable device to view, simultaneously with said virtual object, a portion of
`
`said wearer’s actual world environment” and “wherein said display is operable
`
`to display said image of said wearer’s actual world environment taken by said
`
`camera simultaneously with said virtual object.” Like the ’716 patent, Peli
`
`describes the use of head-mounted cameras to capture an image of a real-world scene
`
`in the user’s field of view and provide that image in a head-mounted display. Peli
`
`teaches multiple applications for enhancing a person’s view of the real-world
`
`environment, including by capturing an image of the scene in front of the user and
`
`displaying the image on a transparent “see-through” head-mounted display, enabling
`
`the user to simultaneously see both the actual world environment and the displayed
`
`image. (E.g., Peli, 9:23-55, 13:43-14:4, Figs. 4, 5, 13.) Similar to the ’716 patent’s
`
`disclosure of capturing and displaying an image using an infrared camera (’716,
`
`14:57-60), Peli teaches using a head-mounted infrared camera to capture an image
`
`that is displayed on the head-mounted display: “an infrared camera 70 obtains an
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`infrared image of a natural scene, and a display module 72 displays the image on a
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`screen, preferably spectacle mounted or mounted to move with the movement of the
`
`patient’s head, disposed in front of at least one of the patient’s eyes.” (Peli, 14:24-
`
` 
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`
`
`-10-
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`

`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
`
`49.)
`
`Finally, Ground 2 further relies on Natoli (EX1007) which teaches the
`
`claimed “virtual object” of claim 1[f]-[g] in the form of a virtual keyboard. Ronzani
`
`discloses that a “virtual keyboard” with a virtual reality glove may be used with a
`
`head-mounted display but does not describe details of the virtual keyboard.
`
`(Ronzani, ¶¶0007, 0010.) Natoli naturally builds upon Ronzani’s disclosure,
`
`teaching and motivating functionality for displaying on a semi-transparent head-
`
`mounted display a “VR keyboard” simulating a physical keyboard that overlays the
`
`wearer’s view of the real world environment, which can be controlled with a motion-
`
`sensitive VR glove. (Natoli, 2:34-48.)
`
`B.
`Prior Art Status of Relied-Upon References
`Pre-AIA law applies to the challenged claims, and each reference cited in the
`
`grounds qualifies as prior art to the ’716 patent. Ronzani, Horton, Peli, and Natoli
`
`qualify as prior art under § 102(b) because they were published and/or issued more
`
`than one year before the priority date.2 Ohshima qualifies as prior art under § 102(e)
`
`
`2 The ’716 patent claims priority to a provisional application (no. 60/603,481) filed
`
`August 20, 2004. For purposes of this Petition, Petitioner has assumed a priority
`
`date of August 20, 2004. Petitioner at this time expresses no opinion on whether the
`
`patent is actually entitled to the benefit of the provisional application filing date.
`
` 
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`
`-11-
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`

`

`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
`
`(and § 102(a)) because it was filed on February 17, 2000, four years before the
`
`earliest claimed priority date.
`
`A. Ground 1: Claims Are Obvious Over Ronzani in View of Horton
`and Ohshima
`
`Independent Claim 16: “[a] head-mounted device
`comprising:” (16[pre])
`Assuming the preamble provides a claim limitation, Ronzani discloses “a
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`head-mounted device” as explained further below. (Cooperstock, ¶¶76-82;
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`Ronzani, ¶¶0005-0016.) Figures 1 and 9 illustrate embodiments:
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`This issue is not relevant here because all the prior art references relied upon predate
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`August 20, 2004. In the event entitlement to the provisional filing date or another
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`earlier priority date may later become relevant, Petitioner reserves the right to
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`respond at that time.
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`(Ronzani, Fig. 1.)
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`(Ronzani, Fig. 9.)
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`This Petition cites various embodiments of Ronzani’s head-mounted device,
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`but Ronzani teaches, and a POSITA would have found it obvious, to combine the
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`components from these embodiments in a head-mounted display device like those
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`in Figures 1 and 9. (Ronzani, ¶¶0005-0016, 0017; Cooperstock, ¶¶76-79.) Ronzani
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`explains, for example, that “the particular head and/or body mounted display
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`systems embodying the invention [are] shown by way of illustration only” and “[t]he
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`principles and features of this invention may be employed in varied and numerous
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`embodiments without departing from the scope of the invention.” (Ronzani, ¶0017.)
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`The obviously combined components are discussed further below where applicable
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`for each element. “Combining two embodiments disclosed adjacent to each other in
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`a prior art patent does not require a leap of inventiveness.” Boston Scientific Scimed,
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`Inc. v. Cordis Corp., 554 F.3d 982, 991 (Fed. Cir. 2009).
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`(a)
`“a head-mounted power source;” (Claim 16[a])
`Ronzani discloses “a head-mounted power source” in a “self-contained”
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`head-mounted device with internal “power supply” such as battery module 529.
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`(Ronzani, ¶¶0094, 0148, Figs. 1, 31B, Cooperstock, ¶¶80-81.)
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`(Ronzani, Fig. 31B (highlighting added).)
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`Ronzani also renders obvious incorporating a head-mounted power source
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`(such as the “integrated” power source of the Figure 1 embodiment or a battery
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`module mounted in a headband as shown in Figure 31B) for the natural convenience
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`and benefits of a “self-contained” head-mounted display requiring “no physical
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`connection” to an external power supply. (Ronzani, ¶0094.) A POSITA would have
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`understood that a self-contained power supply would conveniently enable use of the
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`device in any location, regardless of the availability of an external power source such
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`as an electrical outlet, and by not requiring an external wire to connect to an external
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`power source such as an electrical outlet that would potentially be cumbersome and
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`interfere with the user’s movements. This teaching would also apply naturally to
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`Ronzani’s Figure 9 embodiment and other embodiments. (Cooperstock, ¶82.) A
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`self-contained power source is also consistent with Ohshima’s disclosed HMD,
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`discussed further below, which is not described as requiring any connection to an
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`external power source. Boston Scientific, 554 F.3d at 991.
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`(b)
`“a head-mounted manual input;” (Claim 16[b])
`Ronzani discloses its head-mounted device comprises “a head-mounted
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`manual input” in “manually adjustable controls” such as audio and video knobs.
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`(Ronzani, ¶¶0009, 0097, 0099, 0129, Figs. 2, 13; Cooperstock, ¶¶83-86.)
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`(Ronzani, Fig. 2 (highlighting added), ¶0097 (“volume control 36R” and “contrast
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`control 36L”).)
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`(Ronzani, Fig. 13 (highlighting added), ¶0129 (control knobs 86a and 86b).)
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`Ronzani also renders obvious incorporating head-mounted controls into each
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`embodiment of a head-mounted display for usability and convenience in adjusting
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`display and/or audio volume. It would have been obvious to include these types of
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`manually adjustable control inputs, such as display contrast and/or speaker volume
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`controls, in each embodiment of the head-mounted display device that includes a
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`display and/or speaker for the obvious benefit of the user being able to easily and
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`conveniently control the display contrast (for example, to account for different
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`contrast levels of displayed content and different daytime or nighttime lighting
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`conditions affecting visibility) and speaker volume (for example, to account for
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`different volume levels of played audio and different surrounding noise levels
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`affecting audibility). (Cooperstock, ¶87.) Boston Scientific, 554 F.3d at 991.
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`(c)
`“a head-mounted processor;” (Claim 16[c])
`Ronzani discloses that its head-mounted device comprises “a head-mounted
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`processor” such as a CPU. (Ronzani, ¶¶0009, 0148, 0154-0155, 0169, Figs. 31B,
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`33, 34A, 35; Cooperstock, ¶¶88-93.) Ronzani teaches that its head-mounted device
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`generally may contain a head-mounted “computer system,” which a person of
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`ordinary skill in the art would have understood to contain a processor. (Ronzani,
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`¶0007.) Ronzani also teaches specific examples of a head-mounted system including
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`a CPU. For example, Ronzani’s Figure 33 embodiment contains a CPU inside its
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`headband 512. (Ronzani, ¶0154 (“The CPU and video drive circuitry are fabricated
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`as an integral part of the head band 512″.”).)
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`(Ronzani, Fig. 33.)
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`Ronzani similarly describes other head-mounted device embodiments
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`containing a CPU inside the headband, as shown in Figures 31B and 34A.
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`(Ronzani, Fig. 31B, ¶0146 (“The computing assembly 512b includes a CPU . . .”).)
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`(Ronzani, Fig. 34A, ¶0155 (“The head band 512′″ includes a CPU, a disk drive 564
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`and expansion modules 525a, 525b, 525c all interconnected together by a flexible
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`
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`bus 563.”).)
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`Ronzani also illustrates in Figure 35 a functional block diagram for a head-
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`mounted computer architecture that includes a CPU and may also include additional
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`microprocessors in expansion modules:
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`(Ronzani, Fig. 35 (highlighting added), ¶0169.)
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`Ronzani also renders obvious incorporating a CPU into a head-mounted
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`display for the advantages of self-contained processing capability. A POSITA have
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`found it obvious that a head-mounted display device, including those in the Figure
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`1 and Figure 9 embodiments, would include a head-mounted processor for the
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`natural convenience and benefits that the device includes capability to process
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`input/output, communications, video/image processing, and other processing as may
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`be needed. A POSITA would have understood that implementing a processor in the
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`head-mounted device would make the device more convenient for the user than
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`requiring a connection to an external device or component containing a processor,
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`-23-
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`Petition for Inter Partes Review of
`U.S. Patent No. 11,947,716 B2
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`enabling use of a self-contained device in any location without requiring wiring to
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`an external processing system that could be cumbersome and interfere with the
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`user’s movements. (Cooperstock, ¶94.) Boston Scientific, 554 F.3d at 991.
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`(d)
`“a head-mounted movement sensor;” (Claim 16[d])
`Ronzani with Horton discloses and renders obvious the head-mounted device
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`comprising “a head-mounted movement sensor.”
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`Ronzani contemplates numerous applications for its head-mounted displays,
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`including “virtual reality,” simulations, and entertainment though does not provide
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`full details of implementations for those applications. (Ronzani, ¶¶0002, 0005,
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`0011, 0170; Cooperstock, ¶¶95-96.) Horton, which also discloses systems such as
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`head-mounted displays for “virtual” reality and “simulation” applications, further
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`discloses and motivates incorporating into a head-mounted device a movement
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`sensor comprising accelerometers to track the user’s head movements in “virtual”
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`reality and “simulation” applications. (Horton, 1:13-22, 2:16-35, 3:41-62, 5:7-15.)
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`Horton explains the need for accurate determination of the user’s position and
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`orientation for use in virtual reality or other simulated environments created by
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`computer. (Horton, 1:13-22.) To address that stated need, Horton teaches the use
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`of accelerometers to determine and track position and orientation. Horton teaches
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`that accelero