PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - i - IN THE UNITED STATES PATENT AND TRADEMARK OFFICE Patent: 7,167,731 : Atto
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 1 - I. INTRODUCTION The ‘731 Patent is directed to the display of emoticons in text
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 2 - the inventor of the ‘731 Patent filed his original application in August of 2001—
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 3 - The Background portion of the ‘731 Patent sets a baseline for what th
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 4 - forming characters one at a time. This disadvantage is amplified in situations
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 5 - During prosecution of the ‘991 Patent, the examiner rejected the claims in an off
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 6 - the claims to require a “list” of emoticons and a “mobile communication” device,
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 7 - A. Prior Art Patents and Printed Publications Petitioner relies on the following
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 8 - ● Exhibit 1017 – WO 00/57617 to Nokia (“Nokia”), published on Sep. 28, 2000 is p
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 9 - − GROUND 5. Claim 20 is Unpatentable Under 35 U.S.C. § 103(a) as Obvious over S
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 10 - III. Hawkins as Base Reference − GROUND 14. Claims 1, 4, 10-13, 15, 17-19, 21
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - i - TABLE OF CONTENTS LIST OF EXHIBITS……………………………………………………………...v I. INTRODUCTION..
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 11 - − GROUND 22. Claims 11-13 are Unpatentable Under § 103(a) as Obvious over Kenw
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 12 - “Emoticon.” For purposes of this inter partes review, the limitation
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 13 - current mode of the device). See ‘731 Patent, col. 6, lns. 39-59. (See Bederso
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 14 - indicates “while phone 100 is operating in the text mode, e.g. when
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 15 - science or computer engineering, with at least three years of experience in soft
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 16 - SPH-A5000 discloses a display embodied in the screen . (SPH-A5000: 1; see also
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 17 - SPH-A5000 discloses that the “Select” key can be used to display a list of emoti
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 18 - arrangement, a third top-to-bottom then left-to-right display arrangement, and a
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 19 - 17. The apparatus of claim 11, wherein said operating logic is further designed
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 20 - GROUND 2. Claims 2-8, 14, 16, 20, 22 and 25 are Unpatentable Under 35 U.S.C. §
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - ii - GROUND 5. Claim 20 is Unpatentable Under 35 U.S.C. § 103(a) as Obvious over SPH-
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 21 - would improve similar devices in the same way, using the technique is obvious u
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 22 - have been obvious to one of ordinary skill in the art to enable one of the 12-ke
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 23 - bold face, or otherwise modifying the appearance of a currently-selected list op
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 24 - 2. The apparatus of claim 1, wherein the first input key is an input key for ent
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 25 - voice/phone mode. (SPH-A5000: 1). This claim would have been obvious for the sa
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 26 - have been obvious to one of ordinary skill in the art to employ the input key wi
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 27 - 20. The apparatus of claim 19, wherein said highlighting comprises a selected on
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 28 - and Figure depicting “Emotion Icons”); and as described in Nokia in Fig. 5 below
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 29 - GROUND 8. Claims 1, 9-15, 17-18 and 21-24 are Unpatentable Under 35 U.S.C. § 10
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 30 - Philips discloses a list of emoticons for selection that can be displayed if the
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - iii - GROUND 14. Claims 1, 4, 10-13, 15, 17-19, 21 and 23-24 are Unpatentable Under 3
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 31 - said emoticons for selection in a selected one of a first left-to-right then top
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 32 - Philips discloses the user can use at least the left button, which is not the fi
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 33 - GROUND 9. Claims 2-6, 7-13, 19-20, and 25 are Unpatentable Under 35 U.S.C. § 1
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 34 - 6. The apparatus of claim 5, wherein said first input key is the input key occup
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 35 - 12. The apparatus of claim 11, wherein said operating logic is further designed
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 36 - emoticons to be displayed for user selection. See Ground 8 Claim 1 chart. Phili
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 37 - key because they are both related to efficient keyboard input on mobile devices,
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 38 - Philips discloses a 4×3 array input keypad, which is configured in a left-to-rig
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 39 - references, which apply equally here. (See Bederson Dec., at ¶117-8, 120-1). 2
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 40 - GROUND 14. Claims 1, 4, 10-13, 15, 17-19, 21 and 23-24 are Unpatentable
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - iv - GROUND 23. Claims 19-20 are Unpatentable Under 35 U.S.C. § 103(a) as Obvious ove
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 41 - first input key. (Hawkins: Col. 5, lns. 11-13; figure 3A; see also Bederson Dec
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 42 - FIG. 6C illustrates a pop-up menu display of examples of alternate symbols that
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 43 - 4. The apparatus of claim 1, wherein the first input key is an input key for ent
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 44 - lns. 31-34; figure 6C). 15. The apparatus of claim 12, wherein said apparatus fu
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 45 - programming instructions for the disclosed functionality. (Hawkins: Col. 4, lns
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 46 - key being one of said 12 input keys. See Ground 14 Claim 1 chart. Hawkins discl
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 47 - each of those keys, would have been obvious design choices to one of ordinary sk
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 48 - when the characters ‘:’ (colon), ‘=’ (equal sign) and ‘)’ (right parenthesis) ar
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 49 - keyboard and after these two or three special symbols. [and thereafter describin
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 50 - skill in the art to enable one of the 12-key input keys to be assigned alternate
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - v - LIST OF EXHIBITS Exhibit 1001 – U.S. Patent No. 7,167,731 Exhibit 1002 – File Hi
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 51 - See Ground 14 Claim 1 chart. Hawkins discloses at least a 12-key input pad, wit
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 52 - applies equally here. (See Bederson Dec., at ¶149-152). GROUND 18. Claim 20 i
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 53 - Philips because they are both related to efficient keyboard input on mobile devi
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 54 - ‘731 Claims vs. Kenwood 1. A mobile communication apparatus comprising: Kenwood
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 55 - number of times the Up/Down arrow is pressed. However, a group specification key
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 56 - 21. The apparatus of claim 18, wherein said selecting of the emoticon with the c
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 57 - for selection by the user, and the user of the number keys and arrow keys to cha
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 58 - equally here. (See Bederson Dec., at ¶188-191). 20. The apparatus of claim 19, w
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 59 - Counsel [37 C.F.R. § 42.8(b)(3)]: Lead Counsel: Neil P. Sirota (Reg. No. 38,306
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - 60 - certifies that Petitioner is not barred or estopped from requesting an inter par
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - vi - Exhibit 1020 – Declaration of Jonghoon Song Exhibit 1021 – U.S. Patent No. 5,987
CERTIFICATE OF SERVICE ON PATENT OWNER UNDER 37 C.F.R. § 42.105(a) Pursuant to 37 C.F.R. §§ 42.8(e) and 42.105(b), the undersigned cert
Facsimile: (212) 408-2501 [email protected] Bradley P. Williams Reg. No. 40,227 2001 Ross Avenue Dallas, Texas 75201-2980 Phone: (214)
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - vii - Exhibit 1032 – S. Hambridge, “Netiquette Guidelines”, Network Working Group R
PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,167,731 - viii - Exhibit 1041 – K. Perlin, “Quikwriting: Continuous Stylus-based Text Entry”, I
Comentarios a estos manuales