CON791 Request Reexam

Request for Ex Parte Reexamination, U.S.
Patent 10,142,791
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
In re patent of Pawel Aksamit § Attorney Docket No.: CON791

§
U.S. Patent 10,142,791 §
§
Issue Date: November 27, 2018 § Customer No.: 28120
§
Filing Date: September 29, 2017 §
§
For: METHOD AND SYSTEM FOR §
CONTEXT AWARENESS OF §
A MOBILE DEVICE §
REQUEST FOR EX PARTE REEXAMINATION OF

U.S. PATENT 10,142,791
Mail Stop “Ex Parte Reexam”

Attn: Central Reexamination Unit
Commissioner for Patents
P.O. Box 1450
Alexandria, VA 22313-1450
Dear Commissioner:
Pursuant to the provisions of 35 U.S.C. §§ 301-307, Unified Patents, LLC (“Requester”)

hereby requests an ex parte reexamination of claims 1-7, 10, 11, and 14, 15, 18, and 19 (the
“Challenged Claims”) of U.S. Patent 10,142,791 (the “’791 Patent, Ex. 1001), which issued on
November 27, 2018 to Pawel Aksamit from U.S. Patent Application 15/719,881 (the “’881
Application”), filed on September 29, 2017, and claims indirect priority to Polish Patent
Application No. P.398136, filed on February 17, 2012.1 The ’791 Patent is currently assigned to
Context Directions LLC (“Context”). The assignment is recorded in the U.S. Patent and Trademark
Office (“USPTO”) at reel/frame 051250/0968.
Requester submits that this Request presents prior art references and analyses that are
1
At this time, Requester assumes this foreign priority date is correct.
Request for Ex Parte Reexamination, U.S. Patent 10,142,791
noncumulative of the prior art that was before the Examiner during the original prosecution of the
’791 Patent and that the Challenged Claims are invalid over these references. Requester therefore
requests that an order for reexamination and an Office Action rejecting claims 1-7, 10, 11, and 14,
15, 18, and 19 be issued.
Ex Parte Patent Reexamination Filing Requirements
Pursuant to 37 C.F.R. § l.510(b)(l), statements pointing out at least one substantial new
question of patentability based on material, non-cumulative reference patents and printed
publications for the Challenged Claims of the ’791 Patent are provided in Section II of this Request.
Pursuant to 37 C.F.R. § l.510(b)(2), reexamination of the Challenged Claims of the ’791
Patent is requested, and a detailed explanation of the pertinence and manner of applying the cited
references to the Challenged Claims is provided in Section III of this Request.
Pursuant to 37 C.F.R. § 1.510(b)(3), copies of every patent or printed publication relied
upon or referred to in the statement pointing out each substantial new question of patentability or
in the detailed explanation of the pertinence and manner of applying the cited references are
provided as Exhibits 1001-1017 and AA-CC of this Request.
Pursuant to 37 C.F.R. §1.510(b)(4), a copy of the ’791 Patent is provided as Exhibit 1001
of this Request, along with a copy of any disclaimer, certificate of correction, and reexamination
certificate issued corresponding to the patent.
Pursuant to 37 C.F.R. § 1.510(b)(5), the attached Certificate of Service indicates that a
copy of this Request, in its entirety, has been served on Patent Owner at the following address of
record for Patent Owner, in accordance with 37 C.F.R. § l.33(c):
Sheridan Ross PC
Current Counsel: Patent Appl'n No. US15/719,881
1560 Broadway, Suite 1200
Denver CO 80202
Also submitted herewith is the fee set forth in 37 C.F.R. § l.20(c)(l).
Pursuant to 37 C.F.R. § 1.510(b)(6), Requester hereby certifies that the statutory estoppel
provisions of 35 U.S.C. § 315(e)(l) and 35 U.S.C. § 325(e)(l) do not prohibit Requester from filing
this ex parte patent reexamination request.
TABLE OF CONTENTS
Table of Exhibits ............................................................................................................................ iv

I. Substantial New Questions of Patentability ............................................................................. 1
A. U.S. Patent 10,142,791 ...................................................................................................... 1
1. Summary .................................................................................................................... 1
2. Prosecution History .................................................................................................... 6
B. Claim Construction ........................................................................................................... 6
1. “one or more contexts of the mobile device” (Claims 1, 14) .................................... 7
2. “adapt a configuration of a classifier” (Claims 1, 14) ............................................. 7
C. Listing of Prior Art Patents and Printed Publications ....................................................... 7
D. Lindquist Presents New Questions of Patentability .......................................................... 9
E. Lindquist in view of Dietz Presents Substantial New Questions of Patentability .......... 13
1. Overview of Dietz .................................................................................................... 13
2. Motivation to Combine Lindquist and Dietz ........................................................... 15
F. Soehren in view of Lindquist Presents Substantial New Questions of Patentability ...... 16
1. Overview of Soehren ............................................................................................... 16
2. Motivation to Combine Soehren and Lindquist ....................................................... 19
G. Soehren in view of Lau Presents Substantial New Questions of Patentability ............... 21
1. Overview of Lau ...................................................................................................... 21
2. Motivations to Combine Soehren and Lau .............................................................. 23
H. Chen Presents Substantial New Questions of Patentability ............................................ 24
1. Overview of Chen .................................................................................................... 24
II. Detailed Application of the Prior Art to Every Claim for which Reexamination is
Requested ............................................................................................................................... 29
A. Grounds 1-3 (Lindquist—§§102, 103); Lindquist and Dietz—§103) ............................ 29
B. Grounds 4-5 (Soehren and Lindquist—§103, Soehren and Lau—§103) ........................ 33
C. Grounds 6-7 (Chen—§§102, 103)................................................................................... 35
D. Secondary Considerations ............................................................................................... 36
III. Disclosure of Concurrent Litigation, Reexamination, and Related Proceedings ................... 37
IV. Conclusion .............................................................................................................................. 37
i
TABLE OF EXHIBITS
Exhibit Description
Ex. 1001 U.S. Patent 10,142,791
Ex. 1002 File History of U.S. Patent 10,142,791
Ex. 1003 Declaration of Scott Andrews, Ph.D.
Ex. 1004 File History of U.S. Patent 9,807,564
Ex. 1005 U.S. Publication 2009/0098880 to Lindquist
Ex. 1006 U.S. Publication 2010/0210301 to Dietz et al.
Ex. 1007 U.S. Patent 6,522,266 to Soehren et al.
Ex. 1008 U.S. Patent 5,592,173 to Lau et al.
Ex. 1009 U.S. Publication 2011/0310005 to Chen et al.
Ex. 1010 Tom Logsdon, Understanding the Navstar, 49-53 (2d Ed, 1995)
Ex. 1011 U.S. Patent No. 8,384,589 to Watanabe et al.
Ex. 1012 Fehmi Ben Abdesslem et al., Less is More: Energy-Efficient Mobile Sensing with
SenseLess, MobiHeld’09, Barcelona, Spain (Aug. 17, 2009)
Ex. 1013 Jeongyeup Paek et al., Energy-Efficient Rate-Adaptive GPS-based Positioning for
Smartphones, MobiSys’10, San Francisco, CA (June 15-18-2010)
Ex. 1014 S. Alban et al., Performance Analysis and Architectures for INS-Aided GPS
Tracking Loops, Proceedings of the 2003 National Technical Meeting of The
Institute of Navigation, Anaheim, CA, (January 2003), available at
https://www.ion.org/publications/abstract.cfm?articleID=3804
Ex. 1015 U.S. Publication 2010/0151916 to Baek et al.
Ex. 1016 Context Directions LLC v. LG Electronics Inc., Case 6:20-cv-01064, Doc. 1-2 (W.D.
Tex. Nov. 17, 2020)
Ex. 1017 Context Directions LLC v. Samsung Electronics Inc., Case 6:20-cv-01063 Doc.1-2
(W.D. Tex. Nov. 17, 2020)
ii
I. SUBSTANTIAL NEW QUESTIONS OF PATENTABILITY
Prior to describing the substantial new questions of patentability presented in this Request,
provided below is an overview of the ’791 Patent, a discussion of claim construction, and a
summary of the prior art being discussed in the present Request.
A. U.S. Patent 10,142,791
1. Summary
The ’791 Patent is directed to a “method for detecting context of a mobile device and to a
mobile device having a context detection module, especially to detect that the mobile device is
located in a moving vehicle. ’791 Patent (Ex. 1001), 1:22-25. Copies of the ’791 Patent and its file
history are provided as Exhibits 1001 and 1002, respectively. For the sake of reference, the claims
for which reexamination is requested are reproduced below. Claims 1 and 14 are the independent
claims, while the remaining challenged claims depend directly or indirectly from these claims.
1. A mobile device, comprising:
a plurality of sensors and a plurality of sensor groups, wherein each of the sensor groups
is assigned at least one of the sensors, and wherein the sensor groups are arranged
according to a hierarchy; and
a plurality of classifiers, wherein each classifier is assigned to a sensor group, and
wherein each classifier is configured to evaluate one or more contexts of the mobile
device based on signals from one or more sensors assigned to the same sensor group as
the classifier;
wherein the mobile device is configured to:
activate a classification by a classifier assigned to a first sensor group to evaluate a
first context of the mobile device, wherein the first sensor group is at a lowest level
in the hierarchy;
activate a classification by a classifier assigned to a second sensor group to evaluate
the first context of the mobile device after a result of the classification by the classifier
assigned to the first sensor group; and
adapt a configuration of the classifier assigned to the first sensor group based, at least
in part, on a result of the classification by the classifier assigned to the second sensor
group.
2. The mobile device of claim 1, wherein at least one of the sensor groups is assigned
1
two or more of the classifiers.
3. The mobile device of claim 2, wherein the two or more classifiers assigned to the
same sensor group are configured to evaluate different contexts of the mobile device.
4. The mobile device of claim 1, wherein at least one of the classifiers is configured to
evaluate a plurality of contexts of the mobile device.
5. The mobile device of claim 1, wherein one or more of the classifiers provide a
numerical result that directly or indirectly indicates a probability of an identified context
of the mobile device.
6. The mobile device of claim 5, wherein a result of a classification by the one or

more classifiers that provide a numerical result is determined by comparing the
numerical result to a threshold value.
7. The mobile device of claim 1, wherein classification by the classifier assigned to the
first sensor group to evaluate the first context of the mobile device is performed
continuously.
10. The mobile device of claim 1, wherein the mobile device is configured to change a
mode of operation of one or more sensors assigned to the second sensor group from a
first power state to a second power state when the classification by the classifier assigned
to the second sensor group is activated.
11. The mobile device of claim 1, wherein the mobile device is configured to activate
the classification by the classifier assigned to the second sensor group when the result
of the classification by the classifier assigned to the first sensor group is positive.
14. A mobile device, comprising:

a plurality of sensors and a plurality of sensor groups, wherein each of the sensor groups
is assigned at least one of the sensors, and wherein the sensor groups are arranged
according to a hierarchy; and
a plurality of classifiers, wherein each classifier is assigned to a sensor group, and
wherein each classifier is configured to evaluate one or more contexts of the mobile
device based on signals from one or more sensors assigned to the same sensor group as
the classifier;
2
wherein the mobile device is configured to:

evaluate a first context of the mobile device by activating classification using at least
two of the classifiers in sequence according to the hierarchy; and
adapt a configuration of a classifier assigned to a lower level sensor group in the
hierarchy based, at least in part, on a result of a classification by a classifier assigned
to a higher level sensor group in the hierarchy.
15. The mobile device of claim 14, wherein activating classification using at least two
of the classifiers in sequence comprises activating a classification by the classifier
assigned to the higher level sensor group after a positive classification by the classifier
assigned to the lower level sensor group.
18. The mobile device of claim 14, wherein the mobile device is further configured to
evaluate a second context of the mobile device by activating classification using at least
two of the classifiers in sequence according to the hierarchy.
19. The mobile device of claim 18, wherein the mobile device is configured to
activate classification by a classifier assigned to the higher level sensor group upon a
positive classification by a classifier assigned to the lower level sensor group for
either the first context or the second context.
In general, the claims of the ’791 Patent are directed to a mobile device that comprises a
hierarchy of “sensor groups” that each include at least one sensor and are assigned a “classifier”
that detects, in the form of a “classification” some context of the mobile device based on the
information received from the sensors. See id., claims 1, 14; see also Abstract. A first, lower-level
sensor group that demands less power may detect information about the context of the mobile
device and, when it makes a certain classification, a second, higher-level sensor group makes a
classification about the context of the mobile device. Id. The second sensor group, based on its
own classification, then adapts a configuration of the classifier of the first sensor group. In some
examples, a given classification result attributed to a first sensor group causes the second sensor
group to power on to make its classification. Id., 3:66-4:17; see also claim 10, 9:44-61, Fig. 3.
3
Id., Fig. 3.
In the exemplary embodiment, to detect the presence of a mobile device in a moving
vehicle, the ’791 Patent describes that it is “preferred when a satellite geographical positioning
system receiver [“GPS”] sensor belongs to the group of the highest level” in the hierarchy of sensor
groups because “[i]ts use results in a small uncertainty burden with respect to the question of
whether the mobile device is in a moving vehicle,” such as by comparing the speed of the device
to some threshold. Id., 9:30-39. However, using GPS receivers “involves significant energy
consumption, which is why it is used in a group of sensor switched on as the last one, only after a
positive classification of the classifiers of all antecedent groups.” Id., 9:39-43. Therefore, while
lower-level sensors that do not demand so much power, such as accelerometers, may be powered
on continuously, GPS receivers are only powered on when there is an indication from the other
sensors of a given context, such as the mobile device traveling a threshold speed. Id., 9:44-10:19;
see also 5:54-60, 5:50-55 (identifying possible sensors of a lower-level sensor group). In this
manner, the mobile device of the ’791 Patent reduces energy consumption. See, e.g., id. 8:15-23.
The mobile device also is configured to adapt classifiers assigned to lower-level groups.
4
The ’791 Patent acknowledges that the adaptation of classifiers was previously known using
feedback from a user, such as by having the user indicate whether or not a classification by a
classifier was correct or based on inferences from the actions taken by the user subsequent to a
classification. Id., 3:5-36 (citing, e.g., Int’l Publication WO 2010/133770). However, the ’791
automates this step using the positive or negative classification from the higher-level sensor group
and describes this adaptation step as “the key” to allowing lower-level sensors to accurately return
results and avoid powering on the more energy-demanding high level sensors:
[I]f the mobile device's user is found in circumstances that the classifier will
regularly classify incorrectly, it can lead to behaviour inconsistent with
expectations regarding the device or regular powering on sensors belonging to the
groups of high levels and subjecting to the classification the signal read from them,
which in turn will lead to faster than desired use of battery energy. Consequently,
the key is an adaptation mechanism for lower level classifier configuration based
on classification results returned by classifiers of a higher level. Significantly, it
is a mechanism which does not require any action from the user. Because of their
ability to adapt, regardless of their initial configuration, the lower level classifiers
adapt their configuration in such a way as to return results the most convergent
with the results returned by the classifiers of higher levels in the same
circumstances. After a certain number of adaptation cycles, dependent on the given
circumstances and the initial configuration of the classifier, there ceases to be
necessary enabling the sensors belonging to higher level groups, and subjecting the
signals originating from them to classification in order to obtain a correct result for
the given circumstances.
Id., 6:64-7:17; see also 11:44-53, Figs. 4-5.
The following table summarizes the specification of the ’791 Patent:
U.S. Patent 10,142,791
1:29-3:62 Background of invention
3:66-7:17 Summary of invention and preferred features
7:34-63 Description of example mobile device, depicted in Figure 1
7:64-9:43 Description of signal paths between sensors and sensor groups, depicted in
Figure 2
5
9:44-11:53 Description of flow diagram regarding a context detection method, depicted

in Figure 3
11:54-12:60 Description of an example of a classifier based on a set of patterns, depicted
in Figure 4
12:61-13:34 Description of a flow diagram regarding a method for adapting a classifier’s
configuration, depicted in Figure 5.
13:35-14:38 General description of applications of invention and preferred embodiments
2. Prosecution History
During prosecution, no office actions were filed; instead, the claims were allowed upon the
filing of a terminal disclaimer, given the similarity of the claims of the ’791 Patent to those of
family patents. See File History (Ex. 1002), 84. In a statement of the reasons for allowance, the
examiner explained that while the closest art of record (U.S. Publication 2013/0238535) disclosed
the concept of context models, classifiers, and adapting classification logic using, for example,
feedback from a user, but explained that they failed to teach all of the limitations of Claims 1 and
14.
The same prior art cited by the examiner of the ’881 Application was cited during
prosecution of the parent continuation patent, U.S. Patent 9,807,564 (the ’564 Patent). During
prosecution of the ’564 Patent, the applicant argued that this art failed to teach concepts that also
appear in the independent claims of the ’791 Patent, namely (1) a plurality of classifiers (rather
than a single classifier (2) “activating a classification by a classifier assigned to a second sensor
group after a result of a classification by a classifier assigned to a first sensor group” and (3)
“adapting a configuration of the classifier assigned to the first sensor group based, at least in part,
on a result of the classification by the classifier assigned to the second sensor group.” See ’564
File History (Ex. 1004), 103-10. The examiner cited the applicant’s arguments as the reasons for
allowance. Id., 119.
As shown below, the prior art of record teaches, or at least renders obvious, each of the
limitations of each of the challenged claims, including the concepts the applicant identified as
missing from the prior art cited by the examiner during prosecution.
B. Claim Construction
“During patent examination, the pending claims must be ‘given their broadest reasonable
6
interpretation consistent with the specification.’” MPEP § 2111. The present Request presents the
following claim analysis in a manner that is consistent with the broadest reasonable interpretation
consistent with the specification. Requester reserves the right to advocate a different claim
interpretation in any other forum if necessary. Certain claim terms are construed herein according
to the broadest reasonable interpretation consistent with the specification, to aid the examiner in
reexamination of the challenged claims.
1. “one or more contexts of the mobile device” (Claims 1, 14)
Requester does not think that a specific construction of this term is necessary to understand
the claims, but provides the following as examples of what may fall under the meaning of this term
based on the specification of the ’791 Patent. The specification describes a context of a mobile
device as including “awareness of the device regarding the environment in which it is located, the
current activity of the user and/or the circumstances in which the user finds himself.” Id., 1:29-35.
2. “adapt a configuration of a classifier” (Claims 1, 14)
During prosecution of a continuation parent, the applicant distinguished the prior art by
arguing that the adaptation limitation referred to improving a configuration of the classifier
assigned to the lower level sensor group “through an “‘independent review’ by a different classifier”
through feedback. ’564 File History (Ex. 1004), 108-109. Thus, “adapt a configuration of a
classifier” refers not to, for example, simply “increasing amounts of information” from different
sensors to reach a single result, but using a distinct result from a classifier assigned to a higher-
level so that “the configuration of the classifier assigned to the lower level sensor group can be
improved through an ‘independent review.’” Id. Thus “adapt a configuration of a classifier” should
be construed at least to include “improving a classifier.”
C. Listing of Prior Art Patents and Printed Publications
Reexamination of the Challenged Claims is requested in view of the following references:
• Ex. 1005 (Lindquist): U.S. Publication 2009/0098880 to Lindquist was filed on October 16,
2007 and published on April 16, 2009. Lindquist later issued as U.S. Patent 8,467,804.
Lindquist is prior art at least under 35 U.S.C. §§ 102(a), (b), and (e).
7
• Ex. 1006 (“Dietz”): U.S. Publication 2010/0210301 to Dietz et al. was filed on February 18,
2009 and published on August 19, 2010. Dietz later issued as U.S. Patent 8,355,751. Dietz is
therefore prior art at least under 35 U.S.C. §§ 102(a), (b), and (e).
• Ex. 1007 (“Soehren”): U.S. Patent 6,522,266 to Soehren et al. was filed on May 17, 2000 and
issued on Feb. 18, 2003. Soehren is prior art at least under 35 U.S.C. §§ 102(a), (b), and (e).
• Ex. 1008 (“Lau”): U.S. Patent 5,592,173 to Lau et al. was filed on July 18, 1994 and issued
on January 7, 1997. Lau is prior art at least under 35 U.S.C. §§ 102(a), (b), and (e).
• Ex. 1009 (“Chen”): U.S. Publication 2011/0310005 to Chen et al. was filed on June 16, 2011
and published on December 22, 2011, and claims priority to provisional applications filed on
June 17, 2010 and August 10, 2020. Chen is prior art at least under 35 U.S.C. §§ 102(a) and
(e).
None of the references listed above were cited during prosecution of the ’791 Patent. A
Form SB-08 and copies of the cited references are submitted herewith. This request is also
supported by the declaration of Mr. Scott Andrews (Ex. 1003). To the extent that additional
references are discussed in Mr. Andrews’s declaration, copies of these additional references are
also being submitted, and are included on Form SB-08.
As shown below, Requester submits that the prior art references raise a new “substantial
question of patentability” because “the teaching of the (prior art) patents and printed publications
is such that a reasonable examiner would consider the teaching to be important in deciding whether
or not the claim is patentable.” See MPEP 2242. For example, the references discussed below and
in further detail in the attached charts, when considered as an ordered combination, teach each
limitation of the Challenged Claims, including the idea of a plurality of classifiers assigned to
different sensor groups, activating classification of a classifier assigned to a second sensor group
after a result of the classification by the classifier assigned to the first sensor group, and adapting
a configuration of a classifier assigned to a first sensor group based at least in part on a result of
the classification by the classifier assigned to the second sensor group. Further, they are new;
these references were not previously considered; the “same question of patentability as to the claim
has not been decided by the Office in an earlier concluded examination or review of the patent” at
least because none of the art referenced in this request was before the Office during prosecution of
the ’791 Patent or during a prior post-grant proceeding challenging any claim of the ’791 Patent,
any of which that are known to Requester have been listed below in Section III, infra.
8
D. Lindquist Presents New Questions of Patentability

Lindquist (Ex. 1005, U.S. Publication 2009/0098880) discloses a mobile terminal (i.e., a
mobile device) that is configured to regulate the powering on and off of a global positioning system
(“GPS”), often referred to as a GPS receiver circuit. See Lindquist (Ex. 1005), Abstract; see also
[0001]-[0002]. The mobile device regulates power to the GPS receiver circuit based on “trigger
events” determined based on information received from one or more lower-level sensor circuits
that demand less power or are required to be active anyway, such as sensors that detect acceleration,
position assistance from a cellular system, the presence/absence of a WLAN/Bluetooth device,
and/or a new cellular base station ID. Id., Abstract; see also [0007]-[0018]. In this way, the
different sensors of the mobile terminal are grouped hierarchically, such as sequentially or by level
of accuracy/importance. By placing the GPS receiver circuit at a higher level such that it is only
powered on when necessary, mobile device may conserve power. See, e.g., id. [0068]; see also
[0062] (“Significant reduction in power consumption by the mobile terminal 100 may be achieved
by selectively powering off the GPS receiver circuit 200.).
In one example discussed in more detail below and illustrated in Figure 2, Lindquist
discloses a mobile terminal that includes both an acceleration measurement circuit comprising
accelerometers and/or tilt sensors (220, i.e., a first sensor group) GPS receiver circuit comprising
a satellite GPS receiver (200, i.e., a second sensor group), which are both connected to a controller
circuit (210) that dictates the powering on and off of the GPS circuit based on determinations (i.e.,
classifications) made by other sensor circuits, including the acceleration measurement circuit. See,
e.g., Fig. 3.
9
Id., Fig. 2 (annotated to highlight the mobile terminal in yellow, a first sensor group that includes
accelerometers and/or a tilt-sensor in blue, and a second sensor group that includes a GPS receiver
in red); see also [0040] (explaining that each block represents a circuit element, module, or portion
of code which comprises one or more executable instructions for implementing the specified
logical function(s)”).
The acceleration measurement circuit generates acceleration information and is assigned
“determination circuits” (i.e., classifiers) configured to make classifications about a context of a
10
mobile device. Id., [0019]-[0023]. For example, an “acceleration-based position determination

circuit” is configured to make a determination (i.e., classification) about the user’s location and
whether they have traveled a threshold distance. Id., [0020]-[0021]; see also [0058]-[0062],
[0007]-[0010]. And a “velocity determination circuit” (i.e., a classifier) is configured to make a
determination (i.e., a classification), such as regarding how fast the mobile device is traveling,
such as to indicate that it the user is driving. Id., [0023], [0063]; see also [0011]-[0012].
In the first example trigger event, if the acceleration-based position determination circuit
determines that the user has traveled above some threshold distance, for example, to indicate that
the mobile terminal user has left their home, work, or a location with poor reception for GPS
sensors, the mobile terminal will power on the GPS receiver circuit to make its own, independent
determination (i.e., classification) about the user’s position and distance traveled. Id., [0059]; see
also [0019]-[0021], [0007]-[0010]. After a threshold time since the previous GPS determination
(i.e., classification), if the mobile terminal is still “less than a previously determined GPS position,”
the unit will power off the GPS receiver circuit. Id., [0058].
In a second example trigger event, if the acceleration-based velocity determination circuit
makes a determination that the user has exceeded some velocity, the system will power on the GPS
receiver circuit to make its own determinations and maintain the GPS receiver circuit on when the
mobile terminal is being moved quickly, such as when the “mobile terminal 100 is within a faster
moving car.” Id., [0063]; see also [0023], [0011]-[0012]. Then, if the GPS receiver circuit makes
a determination that the mobile terminal user is below a threshold velocity, such as when walking
or stationary, a mobile device controller will power off the GPS receiver circuit. Id., [0063]. In
other examples, the combination of distance, velocity, and/or other parameters, such as time, are
used to indicate a context. Id., [0060], [0064].
Further, Lindquist discloses that the GPS receiver circuit may be used to calibrate (i.e.,
adapt) a configuration of the acceleration measurement circuit’s determination circuits based on
its own estimates regarding position “to calibrate how [the accelerometer measurement circuit]
determines location using the acceleration information.” Id. [0070]. Such calibration may be
performed by “filtering (e.g., scaling, smoothing, and/or combining a known value/functional
relationship with) the acceleration information and/or by adjusting clock timing used to double
integrate the acceleration information over time.). Id., [0070]; see also [0022]. In this way, the
processing components (i.e., the position and velocity determination circuits, or classifiers) of the
11
acceleration measurement circuit would become more accurate in making future determinations
when the GPS receiver circuit is powered off. Like the ’791 Patent, and as the applicant described
during prosecution of the parent application to the ’791 Patent, Lindquist does not simply
supplement classifications made by the processing components of the acceleration measurement
circuit, but it also improves the accuracy of the classifications made by determination circuits
assigned to the acceleration measurement circuit by using an independent review by the GPS
receiver circuit, a separate sensor group with its own processor for making classifications. See,
e.g., Andrews (Ex. 1003), ¶52.
Lindquist is analogous art to the ’791 Patent. Andrews (Ex. 1003), ¶53. The ’791 Patent is
in the field of “detecting context of a mobile device,” especially detecting that the mobile device
is in a moving vehicle. ’791 Patent (Ex. 1001), 1:22-25. Just like the ’791 Patent, Lindquist is in
the field of detecting the context of a mobile terminal, such as detecting whether the mobile device
is near a specific location (Lindquist, Ex. 1005, [0073]-[0074]), has traveled a given distance
([0058]-[0059]), or is traveling a particular velocity to indicate that a user is stationary, moving
slowly, or in a faster moving car. See, e.g., Lindquist (Ex. 1005), [0063]. Further, Lindquist is
reasonably pertinent to at least two problems concerning the inventor of the ’791 Patent. For
example, the specification of the ’791 Patent describes the need for a system that efficiently uses
battery power prior to activating a global satellite positioning system, and Lindquist discloses that
its selective powering on and off of the GPS receiver circuit based on trigger events conserves
power for the mobile terminal. ’791 Patent (Ex. 1001), 2:6-21, 6:44-58; see also Lindquist (Ex.
1005), [0062], [0068]. Additionally, the ’791 Patent describes the need for a system that includes
an “adaptation mechanism” for classifiers assigned to lower-level sensor groups “based on
classification results returned by classifiers of a higher level,” and Lindquist discloses that the
configuration of acceleration-based position and velocity determination circuits (i.e., classifiers)
are adapted based on results of classifications about a user’s position and distance traveled, for
example, determined by the GPS receiver circuit. Lindquist (Ex. 1005), [0062].
Lindquist anticipates claim 1-4, 7, 10, 11, 14, 15, 18, and 19. Additionally, Lindquist
renders obvious, each and every element of claims 1-7, 10, 11, and 14, 15, 18, and 19. Therefore,
Lindquist presents a substantial new question of patentability. A reasonable examiner would
consider the combined teachings of these references important in determining whether claims 1-7,
10, 11, and 14, 15, 18, and 19 are patentable because Lindquist was never cited or otherwise
12
considered during prosecution. Exhibit AA shows in greater detail how Lindquist discloses or
renders obvious each and every element of claims 1-7, 10, 11, and 14, 15, 18, and 19. To the extent
Patent Owner argues that Lindquist does not literally teach each and every element, Requester
submits that any differences between Lindquist and the claims of the ’791 Patent would have been
minor and obvious in view of the knowledge of a person having ordinary skill in the art at the time
of the earliest priority date of the ’791 Patent. See Andrews (Ex. 1003), ¶32.
E. Lindquist in view of Dietz Presents Substantial New Questions of Patentability
1. Overview of Dietz
Dietz (Ex. 1006, U.S. Publication 2010/0210301) discloses a mobile device that monitors
for an indicium that indicates that the speed of a mobile device is above an initial threshold, upon
which the mobile device activates a speed sensor, such as a GPS satellite navigation system. See
Dietz (Ex. 1006), Abstract; see also [0036], Figs. 3, 5. A monitor may include sensors that measure
the Doppler shift measurements of a timing signal, the timing advance of a cellular radio signal,
the number of base stations visible to the mobile device, the frequency of base station handover,
or a combination of different motion indicia. Id., [0056]-[0057]. A GPS receiver is activated when
the indication is greater than an initial threshold; at that point, the monitor is disregarded for the
purposes of determining speed, and the GPS measures whether the speed of the device drops below
the initial threshold, at which point the GPS receiver is powered down again. Id., [0041]-[0044].
For example, Figure 1 of Dietz, illustrated on the following page, provides a flow chart
showing that an activation of a classification to be made by the GPS receiver (e.g., Steps 120, 140,
and 145—whether the mobile device is traveling above or below a threshold speed) is only made
upon a similar classification (i.e., Steps 100, 110, and 115) by a lower-level sensor group.
13
Dietz, Fig. 1.
Dietz discloses that GPS devices were “common in mobile devices” for providing
“accurate speed measurement,” and, like the ’791 Patent, Dietz also observes that GPS units
“consume considerable power.” Id., [0004]. By activating GPS only after determining that the
device above an initial threshold speed, such as a speed that would indicate that the mobile device
14
is in a moving vehicle, the mobile device may accurately determine when to, as examples, disable
certain functions that may be distracting to a driver or engage a mapping module, without
unnecessarily draining power from the mobile device. Id., [0003], [0046]-[0047].
Dietz is analogous art to the ’791 Patent. Andrews (Ex. 1003), ¶57. Dietz is within the field
of endeavor of the ’791 Patent because it relates to methods of detecting the context of a mobile
device, such as whether it is located in a moving vehicle. See, e.g., Dietz (Ex. 1005), Abstract,
[0003]-[0004], [0041]-[0046]. Further, Dietz is reasonably pertinent to at least one problem
concerning the inventor of the ’791 Patent. For example Dietz discloses that its techniques of
powering on a power-intensive GPS receiver only after the mobile device receives an indicia of a
threshold speed from other sensors may “conserve battery power.” Id., [0044]; see also [0050],
[0053]; see also ’791 Patent (Ex. 1001), 2:6-21, 6:44-58. Dietz is cited in this Request for its
teachings related to the use of GPS receivers to make context determinations related to the speed
of its mobile device, such as to indicate whether a user is in a moving vehicle or not.
2. Motivation to Combine Lindquist and Dietz
Combined with Dietz, Lindquist discloses a mobile device that not only makes context
determinations based on a mobile device’s position and distance traveled using a GPS receiver
circuit, but also determinations (i.e., classifications) based on the speed of the mobile device. A
person having ordinary skill in the art would have been motivated to incorporate Dietz’s teachings
related to using a GPS receiver as a speed sensor for at least three reasons. First, Dietz provides
express motivation to incorporate its teachings regarding using GPS as a speed sensor into
Lindquist’s system, as Dietz explains that the use of GPS receivers were “becoming increasingly
more common in mobile devices” and were known to “provide accurate speed measurements.”
Dietz (Ex. 1006), [0004]; see also Andrews (Ex. 1003), ¶¶37-41, 59.
Second, modifying Lindquist’s GPS receiver circuit to include a classifier for making
classifications based on speed would have simply been a matter of using a known technique (e.g.,
using a GPS receiver to determine speed) to improve a similar device (e.g., mobile
devices/terminals) in the same way (e.g., to make measurements using data from a GPS receiver).
Andrews (Ex. 1003), ¶60.
Third, a POSA would have been motivated to modify Lindquist’s receiver circuit to
measure speed because such would have been a matter of applying a known technique (i.e., using
15
a GPS receiver as a speed sensor) to a known device (e.g., mobile devices with GPS receivers were
common) ready for improvement to yield predictable results (e.g., Dietz discloses that it was
common to use GPS receivers to accurately measure speed). Id., ¶61.
Further, a POSA would have had a reasonable expectation of success in making the
proposed modification, at least because both Lindquist and Dietz discloses similar systems (GPS-
enabled mobile devices) with similar goals (e.g., both Lindquist and Dietz disclose conserving
device power and providing accurate measurements of a user’s activity as goals). Id., ¶62. Further,
implementing Lindquist’s GPS receiver circuit to make determinations about a user’s speed would
have required at most minor modifications in software programming of the mobile device and
would have yielded predictable results related to the measurement of speed by a GPS receiver only
after the mobile device detects some threshold speed by the acceleration measurement circuit. Id.
The combination of Lindquist and Dietz renders obvious, each and every element of claims
1-7, 10, 11, and 14, 15, 18, and 19, and therefore presents a substantial new question of
patentability. A reasonable examiner would consider the combined teachings of these references
important in determining whether claims 1-7, 10, 11, and 14, 15, 18, and 19 are patentable because
neither Lindquist nor Dietz was cited or otherwise considered during prosecution. Exhibit AA
shows in greater detail how the combination of Lindquist and Dietz renders obvious each and every
element of claims 1-7, 10, 11, and 14, 15, 18, and 19.
F. Soehren in view of Lindquist Presents Substantial New Questions of
Patentability
1. Overview of Soehren
Soehren (Ex. 1007, U.S. Patent 6,522,266) discloses a navigation system that may be
mounted on or carried by a human, such as a portable device. Soehren (Ex. 1007), Abstract; see
also 14:22-24. As discussed in more detail below and shown in the chart at Exhibit BB, Soehren
discloses a first, lower-level sensor group consisting of motion sensors and a second, higher-level
sensor group consisting of a position indicator. Signals from the sensor groups are processed
separately at first (i.e., using different classifiers to make independent classifications), then
together using a Kalman filter. Then the classifications by the second sensor group are used to
adapt a configuration of at least one classifier assigned to a first sensor group using the Kalman
filter.
The navigation device includes one or more motion sensors 410 (i.e., a first, lower level
16
sensor group) that outputs a signal to a device processor, which includes an inertial processing unit
and a motion classifier. The inertial processing unit (i.e., a classifier assigned to the first sensor
group) creates a first position estimate, such as regarding the type of movement, attitude, or
distance traveled by the user (i.e., a classification) based on information from inertial sensors 414
in the motion sensor group 410, such as accelerometers and gyroscopes. Id., 6:40-67; see also
2:36-43. A motion classifier (i.e., a classifier assigned to the first sensor group) also makes a
second distance estimate and classifies the user’s movement as walking, running, climbing stairs,
etc. (i.e., classifications) using information from both inertial navigation sensors and dead-
reckoning sensors 418 in motion sensor group 410. Id., 7:1-14 (describing making a distance
estimate using step information; see also 14:37-15:12 (the motion classifier may provide a first
position estimate and use information from the sensors about the user’s movement to execute a
comparison against motion models), 2:43-49. Based on information received from the motion
classifier, a Kalman filter 440 provides corrective feedback to the inertial processing unit based on
to update the first position estimate for presenting to the user. Id., 2:50-65.
The navigation device also includes a second sensor group comprising a “position indicator”
510, such as a satellite global positioning system (GPS), which includes a “global positioning
receiver/processor” (i.e., a classifier) to make a third position estimate (i.e., classification), which
is independent of the first two position estimates generated by the first motion sensor group 410.
Id., 8:46-9:6; see also 2:57-65; see also Andrews Ex. 1003, ¶¶37-38 (explaining the general
makeup of a GPS receiver).
Soehren discloses that when satellite signals are available, the GPS provides the third
position estimate to the Kalman filter, which uses the position estimate to provide “corrections
(e.g., modifications) to parameters of the motion model based on the errors in the distance
estimate” made by the motion classifier and inertial processing unit (i.e., adapt a configuration of
the classifier assigned to the first sensor group based on a result of the classification by the second
sensor group). Id., 9:16-23. Because the motion models are adapted based on information from the
GPS, Soehren explains that the motion sensor group 410 are able to yield more accurate results
when GPS signals become unavailable. See, e.g., id., ; see also 2:10-19 (GPS used to “control
error growth,” so the system “still provides a useful level of navigation performance” when GPS
17
is unavailable), 2:57-65. 2 The estimates from the GPS are considered “superior” to either the
inertial navigation or motion classifier; hence, the GPS estimates are used to correct (i.e. adapt)
future estimates attributed to the motion sensor groups, and the GPS would be “higher” in a
hierarchy of sensor groups. Id., 9:3-6; see also Andrews (Ex. 1003), ¶64. Figure 5 of Soehren
discloses an embodiment of the navigation unit that includes a GPS unit and a Kalman filter that
is used to correct or modify (i.e., adapt) the motion model parameters (i.e., a configuration) of a
motion classifier and inertial processing unit assigned to the less accurate motion sensors:
2
To be clear, Soehren does not just describe providing a single, merged estimate based on inputs
from various sensor groups (although it does disclose this, 9:7-16), the concept distinguished in
the prior art during prosecution of the ’791 Patent’s parent application. Rather, the cited passages
show how Soehren improves a motion model used by a motion classifier based on an independent
classification by a GPS receiver. Id., 9:16-23; see also Andrews (Ex. 1003), ¶¶64-66; see also ¶45.
18
Id., Fig. 5.
Soehren is analogous art to the ’791 Patent. Andrews (Ex. 1003), ¶66. First, Soehren is
within the field of endeavor of the ’791 Patent because, as shown in the preceding paragraphs,
Soehren relates to a method of detecting a context of a mobile device, such as the current activity
of the user and/or the circumstances/environment in which the user and the mobile device are. See,
e.g., ’791 Patent (Ex. 1001), 1:22-25; see also 1:29-35 (describing “mobile device” as including,
for example, navigation devices); see also Soehren (Ex. 1005), Abstract, 14:22-31 (describing
embodiments of the navigation system, including as a portable unit that, as examples, may be
carried by the user or worn around the user’s arm). Additionally, Soehren is reasonable pertinent
to at least one problem concerning the inventor of the ’791 Patent, such as the problem with
inaccuracies by “energy-cheap” sensor groups. For example, Soehren discloses how to use
readings from a “highly accurate” GPS receiver to “control error growth” for motion sensors by
correcting the parameters used by classifiers assigned to such motion sensors so that the motion
sensors can provide more accurate readings when GPS signals are unavailable, much like the ’791
Patent uses classifications by a classifier assigned to a higher level sensor group to adapt a
configuration of a classifier assigned to a lower level sensor group, without any action from a user.
Soehren (Ex. 1007) 1:51-56, 2:10-19; also compare Soehren, 2:56-65 and 9:16-25; with, e.g., ’791
Patent (Ex. 1001), 6:63-7:7.
2. Motivation to Combine Soehren and Lindquist
Lindquist was discussed above in Section I.D, supra. Combined with Lindquist, Soehren
discloses that a mobile device would not activate a power-consuming GPS receiver unit unless the
classifiers assigned to the motion sensors 410 (e.g., the motion classifier and/or the inertial
processing unit) made a positive indication that the user had, for example, moved a certain distance
since the last GPS measurement. Andrews (Ex. 1003), ¶67. A POSA would have been motivated
to modify Soehren’s system to incorporate Lindquist’s teachings for at least two reasons. First,
Lindquist provides express motivation to combine, explaining how powering off a GPS receiver
circuit until a threshold distance has been reached can achieve “[s]ignificant reduction in power
consumption” by a mobile device. Lindquist (Ex. 1005), [0062]; see also [0068]; Andrews (Ex.
1003) ¶68, 42-44. A POSA would have recognized that such power conservation would have been
a desirable trait for a portable navigation system, which consumers would often use when
19
additional power sources to charge a portable unit were available. Andrews (Ex. 1003) ¶68.
Second, modifying Soehren’s portable navigation unit to activate a GPS receiver circuit
only after a positive classification by less accurate, but less power-demanding motion sensor
circuit, would have simply been a matter of using a known technique (e.g., selectively diverting
power to and from a sensor circuit based on a binary result) to improve a similar device (e.g.,
improving Soehren’s analogous portable navigation unit’s ability to conserve power) to operate in
the same way (e.g., to provide position and distance estimates over time). Andrews (Ex. 1003),
¶69. Further, waiting to employ GPS until the user has traveled greater distances would reduce the
effect of non-cumulative random error from a GPS while still accounting for cumulative errors
applicable to dead-reckoning systems. See id., ¶¶69, 40, 42. Thus, by waiting to turn on the GPS
receiver only after the accelerometers have indicated that the user has traveled some threshold
distance would allow Soehren’s system to conserve power while still correcting for errors from
motion sensors without introducing significant random error from a GPS. Id. Indeed, Soehren
already describes that its navigation system is designed to work when GPS signals are unavailable
(see, e.g., Soehren, 2:17-19); thus, employing Lindquist’s power conservation techniques using
threshold comparisons would enhance Soehren’s system. Andrews (Ex. 1003), ¶69
proposed modification, at least because both Soehren and Lindquist disclose similar systems
(position-locating mobile devices using a hierarchy of sensor groups) with similar goals (e.g.,
tracking the position and activity of a user). Id., ¶70. Implementing Soehren’s system to trigger
GPS information only when the user has traveled a certain distance or speed, as disclosed by
Lindquist, would have required at most minor modifications in software programming of the
mobile device and would have yielded predictable results related to the activation of a GPS circuit
only upon a positive result of a binary determination by the device. Id.
Thus, the combination of Soehren and Lindquist renders obvious each and every element
of claims 1, 2, 4, 7, 10, 11, 14, and 15, and therefore presents a substantial new question of
important in determining whether claims 1, 2, 4, 7, 10, 11, 14, and 15 are patentable because neither
Soehren nor Lindquist was cited or otherwise considered during prosecution. Exhibit BB shows in
greater detail how the combination of Soehren and Lindquist renders obvious each and every
element of claims 1, 2, 4, 7, 10, 11, 14, and 15.
20
G. Soehren in view of Lau Presents Substantial New Questions of Patentability
1. Overview of Lau
Lau (Ex. 1008, U.S. Patent 5,592,173) relates to a navigation device, such as a handheld
GPS receiver device, that has a “normal mode” for receiving satellite signals and providing
location information to a user and a “low power standby mode” in which such signals are inhibited
to “reduce the average power consumption” of the device. Lau (Ex. 1008), Abstract; see also In
one embodiment, the wakeup interrupt signal is generated by a “dead reckoning device” 20 when
“a selected limit within the dead reckoning device is exceeded.” Id., 11:15-17. For example,
accelerometer sensors within a dead reckoning device may generate a wakeup signal to a GPS unit
after a threshold rate of rate of change of location is detected. Id. 11:45-57. Figure 4 of Lau
illustrates the steps and associated components of the GPS standby/wakeup process:
21
Id., Fig. 4.
Lau is analogous art to the ’791 Patent. Andrews (Ex. 1003), ¶73. For example, Lau is
within the field of endeavor of the ’791 patent because it relates to a mobile device, such as a
handheld navigation device that includes a GPS receiver. See, e.g., Lau (Ex. 1009), 4:16-25; see
also 1:47-58. Lau is also reasonably pertinent to at least one problem concerning the inventor of
22
the ’791 Patent, such as power conservation of a handheld device. See id.; see also Abstract; see
also ’791 Patent, (Ex. 1001), 2:6-21, 6:44-58.
2. Motivations to Combine Soehren and Lau
Soehren was discussed above in Section I.H, supra. Combined with Lau, Soehren discloses
that a mobile device would not activate a power-consuming GPS receiver unit unless the classifiers
assigned to the motion sensors 410 (e.g., the motion classifier and/or the inertial processing unit)
made a positive indication that the device experienced a threshold rate of rate of change, such as
in position. Andrews (Ex. 1003), ¶74. A POSA would have been motivated to modify Soehren’s
system to incorporate Lau’s teachings for at least two reasons. First, Lau provides express
motivation to combine, explaining how inhibiting power to a GPS unit until a condition has been
met can “reduce the average power consumption” in a navigation device. Lau (Ex. 1005), Abstract;
see also 4:10-15 (describing the failure to use dead reckoning devices to conserve power or
reawaken a GPS receiver as a shortcoming of existing systems), 5:16-21; see also Andrews (Ex.
1003) ¶74. As mentioned above with respect to Lindquist, a POSA would have recognized that
such power conservation would have been a desirable trait for a portable navigation system.
Andrews (Ex. 1003) ¶42.
Second, modifying Soehren’s portable navigation unit to activate a GPS receiver circuit
only after a positive classification by less accurate, but less power-demanding motion sensor
circuit, would have simply been a matter of using a known technique (e.g., selectively diverting
power to and from a sensor circuit based on a binary result) to improve a similar device (e.g.,
improving Soehren’s analogous portable navigation unit’s ability to conserve power) to operate in
the same way (e.g., to provide navigation information). Andrews (Ex. 1003), ¶75. As mentioned
above, waiting to employ GPS until the user has traveled greater distances would reduce the effect
of non-cumulative random error from a GPS while still accounting for cumulative errors applicable
to dead-reckoning systems. See id., ¶¶40, 42, 75. Indeed, Soehren already describes that its
navigation system is designed to work when GPS signals are unavailable (see, e.g., Soehren, 2:17-
19); thus, employing Lau’s power conservation techniques using threshold comparisons would
simply enhance Soehren’s system. Andrews (Ex. 1003), ¶75
proposed modification, at least because both Soehren and Lau disclose similar systems (portable
23
navigation devices) with similar goals (e.g., tracking the position and activity of a user). Id., ¶76.
Further, implementing Soehren’s system to “wakeup” a GPS circuit only when some condition has
been met, such as a threshold rate of rate of change in location, would have required at most minor
modifications in software programming of the mobile device and would have yielded predictable
results related to activation of a GPS receiver/processor upon a positive result of a binary
determination by the device. Id.
Thus, the combination of Soehren and Lau renders obvious each and every element of
claims 1, 2, 4, 7, 10, 11, 14, and 15, and therefore presents a substantial new question of
important in determining whether claims 1, 2, 4, 7, 10, 11, 14, and 15 are patentable because neither
Soehren and Lau was cited or otherwise considered during prosecution. Exhibit BB shows in
greater detail how the combination of Soehren and Lau renders obvious each and every element
of claims 1, 2, 4, 7, 10, 11, 14, and 15.
H. Chen Presents Substantial New Questions of Patentability
1. Overview of Chen
Chen (Ex. 1009, U.S. Publication 2011/0310005) relates to systems and methods for
performing contactless gesture recognition for a mobile computing device, such as a phone or
tablet. See Chen (Ex. 1009), Abstract, [0040]; see also Fig. 4. Chen anticipates claims 1, 5, and 14,
or at least renders obvious claims 1, 5 and 14 because any differences between claims 1, 5 and 14
and Chen’s disclosure would have been minor and obvious variations that would have yielded
predictable results related to the operation of a device that performs contactless gesture recognition
functions. Andrews (Ex. 1003), ¶84; see also ¶¶77-82. Chen is cited in this Request in part because
it reads on concepts that Context Directions is presently reading onto the claims, and “that which
would literally infringes if later anticipates if earlier.” Bristol-Myers Squibb Co. v. Ben Venue
Labs., Inc., 246 F. 3d 1368, 1378 (Fed. Cir. 2001); see also Ex. 1016 (claim chart mapping similar
limitations of related patent to proximity sensing system for gesture input). Pursuant to MPEP
2282, and to the extent they may be relevant to the examination unit’s consideration, Requester
has included Patent Owner’s mappings of its claims in such proceedings as Exhibits 1016 and
1017.
Chen discloses a device that includes sensor system(s) 20 comprising a set of proximity
sensors such as an ambient light sensor and infrared proximity sensor (i.e., a first sensor group).
24
The proximity sensor communicates signals to a gesture recognition module (i.e., a second sensor
group), which detects and classifies detected movements as a gesture. These sensor groups are
activated in sequence, with the gesture recognition module performing a more specific function to
elaborate on the classification by the proximity sensor; thus, are part of a hierarchy of sensor
groups.
Id., Fig. 2 (a functional block diagram of a mobile device).
25
Id., Fig. 5 (example proximity sensor).

A sensor power control module of the mobile device activates a proximity sensor to sense
a context of a mobile device, such as whether an object is moving near the device, indicating user
movement intended for gesture input. See, e.g., id., [0038] (a sensor power control module
activates a proximity sensor depending on the device’s orientation); see also Fig. 20. If the
proximity sensing element (i.e., a classifier) assigned to the proximity sensor of the sensor
system(s) group determines (i.e., makes a classification) that signal level is below a certain
threshold variance, then no action is recorded. Id., [0045]; see also [0054]-[0055], [0058], [0008],
[0011], Figs. 13-15.
26
Id., Fig. 3. (sensor system(s) 20 interacting with a power control system)

However, if the proximity sensor detects an object above this threshold variance, then the
movement information is sent to and prompts a gesture recognition control module to execute a
gesture recognition algorithm (i.e., a classifier) for detecting whether the movement is a gesture
and classifying the gesture (i.e., makes a classification) so that it can be used as an input to the
mobile device. Id., [0054]-[0055]; see also [0008], [0011]. As an example, the gesture recognition
module may classify movement as swiping a hand right or left, which can be used as an input to
an e-reader application to turn a page. See, e.g., Figs. 7-10 (providing example gesture inputs based
on a classification by a gesture recognition module). After the process of gesture recognition is
completed, the process is returned to the beginning for the proximity sensor to make a new
classification about whether an object is moving near the device, effectively resetting the process.
See, e.g., id., [0067]; see also Fig. 15.
27
Id., Fig. 11.

Chen discloses that the gesture recognition module adapts the configuration of the
proximity sensing element in two ways. First, using a signal statistics module based on a user’s
historical movement, the gesture recognition module compares the frames of movement with a
history of standard frames, which a POSA would appreciate would apply to the initial
28
determination made by a proximity sensor regarding whether a movement exceeds a threshold

variance in order to avoid false inputs. See also id., [0045] (if a proximity signal level falls below
a “predetermined threshold” no action is recorded); see also [0058] (a signal statistics module
employs a user’s history to determine whether a high or low variance exists, such when a user’s
hand is not present or is present but not moving); Figs. 13-15. Thus, information related to the
history of the gesture recognition classifications impacts a classification of a proximity sensor
related to the appropriate threshold movements. Andrews (Ex. 1003), ¶82. Second, when the device
completes a gesture recognition sequence, the device is configured to return to a previous state to
determine whether a user is moving using a proximity sensor, thus resetting (or adapting) the
configuration of the proximity sensing element. Id., [0067]; see also Fig. 15.
Chen is analogous art to the ’791 Patent. Andrews (Ex. 1003), ¶83. Chen is within the field
of endeavor of the ’791 Patent because, as shown above, it relates to the detection of a context of
a mobile device, such as whether an object is near the device, the orientation of the device, and
whether the user of the device is inputting a recognized gesture into the device. Additionally, Chen
is reasonable pertinent to at least one issue concerning the inventor of the ’791 Patent, such as
reducing power consumption by the mobile device. Id., [0036]-[0038]; see also [0040], [0070],
[0077].
Thus, Chen anticipates, or at least renders obvious, each and every element of claims 1, 5
and 14, and therefore presents a substantial new question of patentability. A reasonable examiner
would consider the combined teachings of these references important in determining whether
claims 1, 5 and 14 are patentable because Chen was never cited or otherwise considered during
prosecution. Exhibit CC shows in greater detail how the combination of Soehren and Lau renders
obvious each and every element of claims 1, 5, and 14.
II. DETAILED APPLICATION OF THE PRIOR ART TO EVERY CLAIM FOR
WHICH REEXAMINATION IS REQUESTED
A. Grounds 1-3 (Lindquist—§§102, 103; Lindquist and Dietz—§103)
Lindquist anticipates claim 1-4, 7, 10, 11, 14, 15, 18, and 19. Additionally, Lindquist
renders obvious, each and every element of claims 1-7, 10, 11, and 14, 15, 18, and 19. Finally, the
combination of Lindquist and Dietz renders obvious each and every element of claims 1-7, 10, 11,
and 14, 15, 18, and 19. For ease of reference, Requester outlines examples from each reference
that disclose or render obvious an associated limitation. Further, a framework for a POSITA’s
29
background knowledge and motivations to combine are provided by Requester’s expert, Scott
Andrews (see Ex. 1003, ¶¶37-46, 47-62). A more detailed mapping of Grounds 1-3 is provided in
Exhibit AA.
Regarding claim 1, Lindquist, or the combination of Lindquist and Dietz, discloses or
renders obvious a mobile device (see, e.g., Ex. 1005, Abstract, [0001]-[0002]), comprising a
plurality of sensors and a plurality of sensor groups, wherein each of the sensor groups is
assigned at least one of the sensors (see, e.g., Ex. 1005, Abstract, [0061]-[0063], [0010]-[0012],
[0042], Fig. 2), and wherein the sensor groups are arranged according to a hierarchy (see, e.g.,
Ex. 1005, [0007]-[0008], [0010]-[0012], [0041]); and a plurality of classifiers, wherein each
classifier is assigned to a sensor group (see, e.g., Ex. 1005, [0021], [0023], [0061], [0063]; see
also, e.g., Ex. 1006, [0027]-[0031], [0041]-[0042], [0049]-[0050]), and wherein each classifier is
configured to evaluate one or more contexts of the mobile device based on signals from one or
more sensors assigned to the same sensor group as the classifier (see, e.g., Ex. 1005, [0020],
[0058]-[0060], [0063], see also, e.g., Ex. 1006, [0041]-[0051]); wherein the mobile device is
configured to: activate a classification by a classifier assigned to a first sensor group to evaluate
a first context of the mobile device, wherein the first sensor group is at a lowest level in the
hierarchy (see, e.g., Ex. 1005, [0007], [0010]-[0012], [0020], [0023], [0058]-[0063]); activate a
classification by a classifier assigned to a second sensor group to evaluate the first context of
the mobile device after a result of the classification by the classifier assigned to the first sensor
group (see, e.g., Ex. 1005, [0007], [0010]-[0012], [0020], [0023], [0059]-[0063], [0073], [0080];
see also, e.g., Ex. 1006, [0041]-[0051]); and adapt a configuration of the classifier assigned to
the first sensor group based, at least in part, on a result of the classification by the classifier
assigned to the second sensor group (see, e.g., Ex. 1005, [0069]-[0070]).
Regarding claim 2 (which depends from claim 1), Lindquist, or the combination of
Lindquist and Dietz, discloses or renders obvious wherein at least one of the sensor groups is
assigned two or more of the classifiers (see, e.g., Ex. 1005, [0058]- [0063], see also, e.g., Ex.
1006, [0041]-[0051]),
Lindquist and Dietz, discloses or renders obvious wherein the two or more classifiers assigned to
the same sensor group are configured to evaluate different contexts of the mobile device (see,
e.g., Ex. 1005, [0058]-[0063], [0073]; see also, e.g., Ex. 1006, [0041]-[0051]).
30
Regarding claim 4 (which depends from claim 1), Lindquist further discloses, or at least
renders obvious, wherein at least one of the classifiers is configured to evaluate a plurality of
contexts of the mobile device (see, e.g., Ex. 1005, [0073]-[0074]).
Lindquist and Dietz renders obvious wherein one or more of the classifiers provide a numerical
result that directly or indirectly indicates a probability of an identified context of the mobile
device (see, e.g., Ex. 1005, [0063]; see also Ex. 1006, [0039], [0046]; see also Ex. 1003, ¶¶55, 58).
Regarding claim 6 (which depends from claim 5), Lindquist or the combination of
Lindquist and Dietz renders obvious wherein a result of a classification by the one or more
classifiers that provide a numerical result is determined by comparing the numerical result to a
threshold value (see, e.g., Ex. 1005, [0063]; see also Ex. 1006, [0039], [0046]; see also Ex. 1003,
¶¶55, 58).
Regarding claim 7 (which depends from claim 1), Lindquist further discloses or renders
obvious wherein classification by the classifier assigned to the first sensor group to evaluate the
first context of the mobile device is performed continuously (see, e.g., Ex. 1005, [0062]).
Lindquist and Dietz, discloses or renders obvious wherein the mobile device is configured to
change a mode of operation of one or more sensors assigned to the second sensor group from a
first power state to a second power state when the classification by the classifier assigned to the
second sensor group is activated (see, e.g., Ex. 1005, [0010]-[0012], [0059]-[0063]; see also, e.g.,
Ex. 1006, [0044], [0050]-[0053]).
activate the classification by the classifier assigned to the second sensor group when the result
of the classification by the classifier assigned to the first sensor group is positive (see, e.g., Ex.
1005, [0058]-[0063]; see also Ex. 1006, [0041]-[0051]).
Regarding claim 14, Lindquist, or the combination of Lindquist and Dietz, discloses or
renders obvious a mobile device (see, e.g., Ex. 1005, Abstract, [0001]-[0002]), comprising a
plurality of sensors and a plurality of sensor groups, wherein each of the sensor groups is
31
assigned at least one of the sensors (see, e.g., Ex. 1005, Abstract, [0061]-[0063], [0010]-[0012],
[0042], Fig. 2), and wherein the sensor groups are arranged according to a hierarchy (see, e.g.,
Ex. 1005, [0007]-[0008], [0010]-[0012], [0041]); and a plurality of classifiers, wherein each
classifier is assigned to a sensor group (see, e.g., Ex. 1005, [0021], [0023], [0061], [0063]; see
also, e.g., Ex. 1006, [0027]-[0031], [0041]-[0042], [0049]-[0050]), and wherein each classifier is
configured to evaluate one or more contexts of the mobile device based on signals from one or
more sensors assigned to the same sensor group as the classifier (see, e.g., Ex. 1005, [0020],
[0058]-[0060], [0063], see also, e.g., Ex. 1006, [0041]-[0051]); wherein the mobile device is
configured to evaluate a first context of the mobile device by activating classification using at
least two of the classifiers in sequence according to the hierarchy (see, e.g., Ex. 1005, [0007],
[0010]-[0012], [0020], [0023], [0059]-[0063], [0073], [0080]; see also, e.g., Ex. 1006, [0041]-
[0051]); and adapt a configuration of a classifier assigned to a lower level sensor group in the
hierarchy based, at least in part, on a result of a classification by a classifier assigned to a higher
level sensor group in the hierarchy (see, e.g., Ex. 1005, [0069]-[0070]).
Lindquist and Dietz, discloses or renders obvious wherein activating classification using at least
two of the classifiers in sequence comprises activating a classification by the classifier assigned
to the higher level sensor group after a positive classification by the classifier assigned to the
lower level sensor group (see, e.g., Ex. 1005, [0058]-[0063]; see also Ex. 1006, [0041]-[0051]).
Lindquist and Dietz, discloses or renders obvious wherein the mobile device is further configured
to evaluate a second context of the mobile device by activating classification using at least two
of the classifiers in sequence according to the hierarchy (see, e.g., Ex. 1005, [0007], [0010]-
[0012], [0020], [0023], [0059]-[0063], [0073], [0080]; see also, e.g., Ex. 1006, [0041]-[0051]).
activate classification by a classifier assigned to the higher level sensor group upon a positive
classification by a classifier assigned to the lower level sensor group for either the first context
or the second context. (see, e.g., Ex. 1005, [0058]-[0063]; see also Ex. 1006, [0041]-[0051]).
32
B. Grounds 4-5 (Soehren and Lindquist—§103; Soehren and Lau—§103)
Soehren in view of Lindquist renders obvious each and every element of claims 1, 2, 4, 7,
10, 11, 14, and 15. Additionally the combination of Soehren and Lau renders obvious each and
every element of claims 1, 2, 4, 7, 10, 11, 14, and 15. For ease of reference, Requester outlines
examples from each reference that disclose or render obvious an associated limitation. Further, a
framework for a POSITA’s background knowledge and motivations to combine are provided by
Requester’s expert, Scott Andrews (see Ex. 1003, ¶¶37-46, 47-52, 63-76). A more detailed
mapping of Grounds 4-5 is provided in Exhibit BB.
Regarding claim 1, the combination of Soehren and Lindquist and the combination of
Soehren and Lau each renders obvious a mobile device (see, e.g., Ex. 1007, Abstract, 14:23-31),
comprising a plurality of sensors and a plurality of sensor groups, wherein each of the sensor
groups is assigned at least one of the sensors (see, e.g., Ex. 1007, Abstract, 6:8-48, 8:45-60, Fig.
5), and wherein the sensor groups are arranged according to a hierarchy (see, e.g., Ex. 1007,
3:55-63, 8:45-9:35, Abstract); and a plurality of classifiers, wherein each classifier is assigned
to a sensor group (see, e.g., Ex. 1007, Abstract, 2:36-49, 2:66-3:17, 6:8-39, 8:46-9:6, Fig. 5), and
wherein each classifier is configured to evaluate one or more contexts of the mobile device based
on signals from one or more sensors assigned to the same sensor group as the classifier (see,
e.g., Ex. 1007, Abstract, 6:54-67, 14:37-57); wherein the mobile device is configured to: activate
a classification by a classifier assigned to a first sensor group to evaluate a first context of the
mobile device, wherein the first sensor group is at a lowest level in the hierarchy (see, e.g., Ex.
1007, Abstract, 6:54-7:14, 2:66-3:17, 14:38-65); activate a classification by a classifier assigned
to a second sensor group to evaluate the first context of the mobile device after a result of the
classification by the classifier assigned to the first sensor group (see, e.g., Ex. 1005, [0007],
[0010]-[0012], [0020], [0023], [0059]-[0063], [0073], [0080]; see also, e.g., Ex. 1008, 5:16-21,
11:19-57, Fig. 4); and adapt a configuration of the classifier assigned to the first sensor group
based, at least in part, on a result of the classification by the classifier assigned to the second
sensor group (see, e.g., Ex. 1007, 9:7-34, 2:50-65, 5:60-67, 4:21-30).
Regarding claim 2 (which depends from claim 1), Soehren further discloses, or at least
renders obvious, wherein at least one of the sensor groups is assigned two or more of the
classifiers (see, e.g., Ex. 1007, Abstract, 2:36-49, 2:66-3:17 Fig. 5).
33
Regarding claim 4 (which depends from claim 1), Soehren further discloses, or at least
renders obvious, wherein at least one of the classifiers is configured to evaluate a plurality of
contexts of the mobile device (see, e.g., Ex. 1007, Abstract, 2:36-49, 2:66-3:17).
Regarding claim 7 (which depends from claim 1), the combinations of Soehren and
Lindquist and Soehren and Lau render obvious wherein classification by the classifier assigned
to the first sensor group to evaluate the first context of the mobile device is performed
continuously (see, e.g., Ex. 1005, [0062]; see also Ex. 1008, 7:25-34).
Lindquist and Soehren and Lau render obvious wherein the mobile device is configured to change
a mode of operation of one or more sensors assigned to the second sensor group from a first
power state to a second power state when the classification by the classifier assigned to the
second sensor group is activated (see, e.g., Ex. 1005, [0010]-[0012], [0059]-[0063]; see also, e.g.,
Ex. 1008, 5:16-21, 11:19-57, Fig. 4).
Lindquist and Soehren and Lau render obvious wherein the mobile device is configured to activate
the classification by the classifier assigned to the second sensor group when the result of the
classification by the classifier assigned to the first sensor group is positive (see, e.g., Ex. 1005,
[0058]-[0063]; see also Ex. 1008, 11:19-57).
Regarding claim 14, the combination of Soehren and Lindquist and the combination of
Soehren and Lau each renders obvious a mobile device (see, e.g., Ex. 1007, Abstract, 14:23-31),
comprising a plurality of sensors and a plurality of sensor groups, wherein each of the sensor
groups is assigned at least one of the sensors (see, e.g., Ex. 1007, Abstract, 6:8-48, 8:45-60, Fig.
5), and wherein the sensor groups are arranged according to a hierarchy (see, e.g., Ex. 1007,
3:55-63, 8:45-9:35, Abstract); and a plurality of classifiers, wherein each classifier is assigned
to a sensor group (see, e.g., Ex. 1007, Abstract, 2:36-49, 2:66-3:17, 6:8-39, 8:46-9:6, Fig. 5), and
wherein each classifier is configured to evaluate one or more contexts of the mobile device based
on signals from one or more sensors assigned to the same sensor group as the classifier (see,
e.g., Ex. 1007, Abstract, 6:54-67, 14:37-57); wherein the mobile device is configured to evaluate
a first context of the mobile device by activating classification using at least two of the classifiers
in sequence according to the hierarchy (see, e.g., Ex. 1007, Abstract, 6:54-7:14, 2:66-3:17, 14:38-
34
65; see also, e.g., Ex. 1005, [0007], [0010]-[0012], [0020], [0023], [0059]-[0063], [0073], [0080];
see also, e.g., Ex. 1008, 5:16-21, 11:19-57, Fig. 4);); and adapt a configuration of a classifier
assigned to a lower level sensor group in the hierarchy based, at least in part, on a result of a
classification by a classifier assigned to a higher level sensor group in the hierarchy (see, e.g.,
Ex. 1007, 9:7-34, 2:50-65, 5:60-67, 4:21-30)).
Lindquist and Soehren and Lau render obvious wherein activating classification using at least
two of the classifiers in sequence comprises activating a classification by the classifier assigned
to the higher level sensor group after a positive classification by the classifier assigned to the
lower level sensor group (see, e.g., Ex. 1005, [0058]-[0063]; see also Ex. 1008, 11:19-57).
C. Grounds 6-7 (Chen—§§102, 103)
Chen discloses or, alternatively, renders obvious each and every element of claims 1, 5,
and 14. For ease of reference, Requester outlines examples from each reference that disclose or
render obvious an associated limitation. Further, a framework for a POSITA’s background
knowledge and understanding of Chen are provided by Requester’s expert, Scott Andrews (see
Ex. 1003, ¶¶37-46, 77-84). A more detailed mapping of Grounds 6-7 is provided in Exhibit CC.
Regarding claim 1, Chen discloses or renders obvious a mobile device (see, e.g., Ex. 1009,
Abstract, [0002], Figs. 4, 19), comprising a plurality of sensors and a plurality of sensor groups,
wherein each of the sensor groups is assigned at least one of the sensors (see, e.g., Ex. 1009,
[0005], [0035], [0037], [0038, [0046], Figs. 2, 3, 5, 6), and wherein the sensor groups are
arranged according to a hierarchy (see, e.g., Ex. 1009, [0035]-[0037], [0054]-[0055]); and a
plurality of classifiers, wherein each classifier is assigned to a sensor group (see, e.g., Ex. 1009,
[0054]-[0055], Fig. 11), and wherein each classifier is configured to evaluate one or more
contexts of the mobile device based on signals from one or more sensors assigned to the same
sensor group as the classifier (see, e.g., Ex. 1009, [0033], [0044]-[0045], [0035], [0041], [0054]-
[0055], Figs. 7-10); wherein the mobile device is configured to: activate a classification by a
classifier assigned to a first sensor group to evaluate a first context of the mobile device, wherein
the first sensor group is at a lowest level in the hierarchy (see, e.g., Ex. 1009, [0037]-[0038,
[0075]-[0077], Fig. 20]); activate a classification by a classifier assigned to a second sensor
group to evaluate the first context of the mobile device after a result of the classification by the
35
classifier assigned to the first sensor group (see, e.g., Ex. 1009, [0045], [0059]-[0060], [0054]-
[0055], [0035], Figs. 11-15); and adapt a configuration of the classifier assigned to the first
sensor group based, at least in part, on a result of the classification by the classifier assigned to
the second sensor group (see, e.g., Ex. 1009, [0058], [0045], [0043], [0054], [0066]-[0067], Fig.
15).
Regarding claim 5 (which depends from claim 1), Chen discloses or renders obvious
wherein one or more of the classifiers provide a numerical result that directly or indirectly
indicates a probability of an identified context of the mobile device (see, e.g., Ex. 1009, [0005],
[0010], [0059]).
Regarding claim 14, Chen discloses or renders obvious a mobile device (see, e.g., Ex. 1009,
Abstract, [0002], Figs. 4, 19), comprising a plurality of sensors and a plurality of sensor groups,
wherein each of the sensor groups is assigned at least one of the sensors (see, e.g., Ex. 1009,
[0005], [0035], [0037], [0038, [0046], Figs. 2, 3, 5, 6), and wherein the sensor groups are
arranged according to a hierarchy (see, e.g., Ex. 1009, [0035]-[0037], [0054]-[0055]); and a
plurality of classifiers, wherein each classifier is assigned to a sensor group (see, e.g., Ex. 1009,
[0054]-[0055], Fig. 11), and wherein each classifier is configured to evaluate one or more
contexts of the mobile device based on signals from one or more sensors assigned to the same
sensor group as the classifier (see, e.g., Ex. 1009, [0033], [0044]-[0045], [0035], [0041], [0054]-
[0055], Figs. 7-10); wherein the mobile device is configured to: evaluate a first context of the
mobile device by activating classification using at least two of the classifiers in sequence
according to the hierarchy (see, e.g., Ex. 1009, [0045], [0059]-[0060], [0054]-[0055], [0035],
[0037]-[0038], Figs. 11-15); and adapt a configuration of a classifier assigned to a lower level
sensor group in the hierarchy based, at least in part, on a result of a classification by a classifier
assigned to a higher level sensor group in the hierarchy (see, e.g., Ex. 1009, [0058], [0045],
[0043], [0054], [0066]-[0067], Fig. 15).
D. Secondary Considerations
This Request demonstrates that the Challenged Claims of the ’397 Patent are unpatentable
as obvious in view of the prior art references. The Applicant did not identify any evidence of
secondary considerations during prosecution. Further, the clear teachings in the prior art cannot be
overcome by any supposed “secondary considerations.” Andrews (Ex. 1003), ¶¶22-24.
36
III. DISCLOSURE OF CONCURRENT LITIGATION, REEXAMINATION, AND

RELATED PROCEEDINGS
Based on information available to Requester, the ’791 Patent is the subject of 2 prior
District Court litigations, as listed in the below table. Requester is unaware of any prior
reexaminations or other post-grant proceedings in which the ’791 Patent is or has been involved.
• Context Directions, LLC v. Samsung Electronics Co., Ltd., 6:20-cv-01063 (W.D.Tex.); and
• Context Directions, LLC v. LG Electronics, Inc., 6:20-cv-01064 (W.D.Tex.).
IV. CONCLUSION
The Commissioner is hereby authorized to charge Deposit Account 50-6990 under Order
No. CON791 the Ex Parte Reexamination fee of $12,000 under 37 C.F.R. § 1.20(c)(1). Requester
believes no other fee is due with this submission, however the Commissioner is hereby authorized
to charge any fee deficiency or credit any over-payment to Deposit Account 50-6990.
Please direct all correspondence in this matter to the undersigned.
Dated: 3/29/21 Respectfully submitted,
By: /Michelle Aspen/

Michelle Aspen (Reg. 75,665)
P.O. Box 53345
Washington, D.C. 20009
559.214.3388
michelle@unifiedpatents.com
Ashraf Fawzy (Reg. 67,914)
afawzy@unifiedpatents.com
Counsel for Requester Unified Patents, LLC
37

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Request for Ex Parte Reexamination, U.S.

IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

In re patent of Pawel Aksamit § Attorney Docket No.: CON791

REQUEST FOR EX PARTE REEXAMINATION OF

Mail Stop “Ex Parte Reexam”

Pursuant to the provisions of 35 U.S.C. §§ 301-307, Unified Patents, LLC (“Requester”)

Table of Exhibits ............................................................................................................................ iv

I. SUBSTANTIAL NEW QUESTIONS OF PATENTABILITY

two or more of the classifiers.

6. The mobile device of claim 5, wherein a result of a classification by the one or

14. A mobile device, comprising:

wherein the mobile device is configured to:

9:44-11:53 Description of flow diagram regarding a context detection method, depicted

1. “one or more contexts of the mobile device” (Claims 1, 14)

2. “adapt a configuration of a classifier” (Claims 1, 14)

D. Lindquist Presents New Questions of Patentability

mobile device. Id., [0019]-[0023]. For example, an “acceleration-based position determination

2. Motivation to Combine Lindquist and Dietz

2. Motivation to Combine Soehren and Lindquist

G. Soehren in view of Lau Presents Substantial New Questions of Patentability

2. Motivations to Combine Soehren and Lau

Id., Fig. 2 (a functional block diagram of a mobile device).

Id., Fig. 5 (example proximity sensor).

Id., Fig. 3. (sensor system(s) 20 interacting with a power control system)

Id., Fig. 11.

determination made by a proximity sensor regarding whether a movement exceeds a threshold

A. Grounds 1-3 (Lindquist—§§102, 103; Lindquist and Dietz—§103)

B. Grounds 4-5 (Soehren and Lindquist—§103; Soehren and Lau—§103)

C. Grounds 6-7 (Chen—§§102, 103)

III. DISCLOSURE OF CONCURRENT LITIGATION, REEXAMINATION, AND

Dated: 3/29/21 Respectfully submitted,

By: /Michelle Aspen/

Counsel for Requester Unified Patents, LLC

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