[00:00:00] Speaker 02:
Imperial or Imperium IP holdings versus Samsung Electronics and again start with Mr. Edel.

[00:00:29] Speaker 04:
Thank you, your honors, and may it please the court.

[00:00:36] Speaker 04:
For the 290 patent, the board erroneously adopted Samsung's motivations for obviousness.

[00:00:43] Speaker 04:
Prior to the 290 patent, CMOS sensors connected to processors using either a single-ended interface or a differential interface.

[00:00:54] Speaker 04:
The 290 invention was the first CMOS sensor that connected using a

[00:00:59] Speaker 04:
selective interface circuit for data transmission.

[00:01:02] Speaker 04:
A helpful way to think about single-ended and differential interfaces, Your Honors, and the contrast between them, is a bicycle and a race car.

[00:01:12] Speaker 04:
Single-ended, like a bicycle, is slow but cheap.

[00:01:16] Speaker 04:
Differential, like a race car, is fast but expensive.

[00:01:20] Speaker 04:
In essence, Samsung argues that combining a bicycle and a race car would have been obvious because one could do it.

[00:01:26] Speaker 04:
But the proper question is whether

[00:01:28] Speaker 04:
a skilled artisan would have been motivated to do so?

[00:01:31] Speaker 04:
And the answer is no.

[00:01:33] Speaker 04:
Samsung's three motivation theories are cost, performance, and versatility.

[00:01:40] Speaker 04:
If you look at cost, they argue that the prior art expressed concerns over cost and using interfaces.

[00:01:48] Speaker 04:
But cost can't be a motivation here, because if cost is a concern, one would use the cheaper bicycle, the single-ended interface.

[00:01:58] Speaker 04:
Samsung has failed to show that using a selectable interface would be cheaper than using the cheaper, simpler bicycle, the single-ended.

[00:02:07] Speaker 04:
Without such evidence, the board cannot rely on cost as a motivation to use a more expensive, complicated, selective interface circuit to add that to the primary references.

[00:02:18] Speaker 01:
Is cost really that, I don't know, cabined as a notion if you had a

[00:02:27] Speaker 01:
very much less versatile circuit.

[00:02:30] Speaker 01:
And the cost I would think in trying to serve a number of different needs would be the cost of one circuit that could, comparing the cost of one circuit that could serve a variety of needs versus the cost of multiple different circuits to serve the variety of needs.

[00:02:50] Speaker 01:
So the fact that one is cheaper than the other doesn't account for the fact that you may need lots of the singlets.

[00:02:56] Speaker 04:
Well, actually, Your Honor, if we look at UMIDA and the 290 patent, UMIDA is one of the primary references.

[00:03:02] Speaker 04:
The column one that Samsung relies on for the cost premise speaks to the fact that the main cost issue relates to the amount of pins that are used to connect the sensor to the processor.

[00:03:13] Speaker 01:
You equate the cost and the number of pins.

[00:03:14] Speaker 04:
And that the number of pins as it goes up, the bigger the chip area, the higher the cost.

[00:03:19] Speaker 04:
That is Samsung's motivation theory on cost.

[00:03:22] Speaker 04:
But all that evidence points to is using

[00:03:25] Speaker 04:
the cheaper bicycle using the single-ended interface, which both parties agree provides the minimal amount of pins.

[00:03:32] Speaker 04:
Samsung in its own briefing says that you can transmit data using a single pin with a single-ended interface.

[00:03:40] Speaker 04:
And it was Samsung's burden to show that the primary references would want to use these more costly and more pin-based selective interface circuits.

[00:03:51] Speaker 04:
And that has not been shown here, Your Honors.

[00:03:54] Speaker 00:
multiple combinations, right?

[00:03:57] Speaker 04:
Yes, your honor, but the idea of this pin count issue on cost is intrinsically true for all sensors.

[00:04:04] Speaker 04:
And so there's no discussion in the secondary references of Rho and Toshiba that any sort of increase in cost would justify the throughput that could supposedly be used with a selective interface.

[00:04:16] Speaker 02:
Well, I'm going to say I'm a little confused here.

[00:04:18] Speaker 02:
My understanding is that Rho and Toshiba

[00:04:23] Speaker 02:
suggest that it would be useful to have both single and dual approaches to this.

[00:04:32] Speaker 02:
But those references don't say how to do it.

[00:04:36] Speaker 02:
And what the board found was that Emeda and Sears showed how to do that so that you had the choice between the single and dual.

[00:04:49] Speaker 02:
and that that would be the motivation to combine so that you would have the ability to do the things that Ro and Toshiba say is desirable.

[00:04:59] Speaker 02:
Am I misunderstanding it?

[00:05:01] Speaker 04:
Respectfully, yes, Your Honor.

[00:05:02] Speaker 04:
I mean, like a lot of inventions, the elements are already out there in the prior art.

[00:05:08] Speaker 04:
We have to look at, now, motivation.

[00:05:10] Speaker 04:
Wait, wait, wait.

[00:05:11] Speaker 04:
What's wrong with what I said?

[00:05:13] Speaker 04:
So both the board and Samsung

[00:05:15] Speaker 04:
their motivation theories focus solely on the design needs of Umida and Sears.

[00:05:21] Speaker 04:
Every single site to motivation refers to motivations coming from... I'm sorry, I don't think you're addressing what I said.

[00:05:28] Speaker 02:
What I said was that Rowan Toshiba said it would be desirable to be able to have either a single or a dual approach here because, you know, some systems use one, some use another, correct?

[00:05:45] Speaker 04:
No, Your Honor, that's not what the board or Samsung relies on for their motivation.

[00:05:49] Speaker 04:
While it's intrinsically true that... That's what I said is true, isn't it?

[00:05:53] Speaker 04:
It is true that that's what those references teach, but that's not what the board relies on for its analysis.

[00:05:58] Speaker 00:
Well, are you saying that the board was wrong when it said that you could increase Sears throughput by use of Toshiba or Roe?

[00:06:10] Speaker 04:
It's wrong as a technical matter.

[00:06:12] Speaker 04:
Again, this is why speculation on the board is so harmful here, because there's nothing in the evidence that shows that the type of... That's debating a factual finding of the board, right?

[00:06:22] Speaker 04:
Well, yeah, Your Honor, but yes, Your Honor, you're correct.

[00:06:25] Speaker 04:
But if we look at what's actually in the art, UMIDA and SEERS already provide systems that operate.

[00:06:31] Speaker 04:
There's nothing in the teachings that show that the addition of the secondary references interfaces provides a net benefit

[00:06:39] Speaker 01:
And those are the image sensor systems.

[00:06:41] Speaker 01:
And then Ro and Toshiba are the ones that have the paired single line and differential line circuit.

[00:06:50] Speaker 01:
And the whole idea is why not use those circuits in the image sensors of the other two?

[00:07:01] Speaker 04:
Yes, Your Honor.

[00:07:02] Speaker 04:
The borer fell into the trap of why not?

[00:07:04] Speaker 04:
Why not do this?

[00:07:05] Speaker 02:
But it was to provide the alternative circuits.

[00:07:08] Speaker 02:
that were disclosed in Umeda and Sears, right?

[00:07:15] Speaker 02:
Those two references set here, you know, you can have a chip that provides the two alternatives, right?

[00:07:24] Speaker 02:
The single or the dual.

[00:07:25] Speaker 02:
You're absolutely right, Your Honor.

[00:07:26] Speaker 02:
That's what the secondary references teach.

[00:07:28] Speaker 02:
Okay, so what the board said, if I understand correctly, is that it would have been obvious to combine one of those two approaches

[00:07:37] Speaker 02:
with the primary references in order to offer this alternative.

[00:07:43] Speaker 04:
But the rationale for the benefits alternative are the costs.

[00:07:46] Speaker 04:
That's correct, right?

[00:07:47] Speaker 04:
Was that correct?

[00:07:48] Speaker 04:
Yes, your honor.

[00:07:48] Speaker 04:
But the actual logical underpinnings the board used were the cost, performance, and versatility.

[00:07:54] Speaker 00:
Right.

[00:07:55] Speaker 00:
And then they cited to test money from SAMHSA expert to support that conclusion, even if you submitted

[00:08:02] Speaker 00:
alternative evidence, how do we get around the fact that the board made that specific finding a fact?

[00:08:10] Speaker 04:
The reason is, Your Honor, if we look at versatility.

[00:08:12] Speaker 04:
So, versatility argued what Samsung argues for the first time.

[00:08:17] Speaker 02:
Versatility means that you can either use the single or the double approach, right?

[00:08:25] Speaker 04:
That's certainly Samsung's position, yes, Your Honor.

[00:08:27] Speaker 02:
Yeah, and that's what the board said.

[00:08:29] Speaker 04:
Yes, and I'll address that issue why that's wrong, but if we take a step back and look at Samsung's red brief, Samsung argues for the first time there that there is a tension between the benefits of saving on cost on the one hand versus the benefits of versatility on the other.

[00:08:50] Speaker 04:
But this shows why versatility cannot be a motivation, because Samsung has failed to show that the benefits to

[00:08:58] Speaker 04:
versatility outweigh the resulting increasing costs from using this more expensive selective interface circuit.

[00:09:06] Speaker 04:
Because Samsung failed to show that there's a net benefit economically to use these more expensive selective interface circuits, there's no justification for using these based on versatility.

[00:09:20] Speaker 00:
That's assuming that things like increased compatibility versus versatility and throughput are not

[00:09:28] Speaker 00:
intrinsically valuable if they might also increase cost to some extent.

[00:09:34] Speaker 00:
I mean, sometimes if you get better performance, you don't mind if there's an increase in cost.

[00:09:40] Speaker 04:
And I think the court's Enrique Schweiker decision is instructive here, Your Honor, because in that case, all that the primary reference lacked was a memory that was selectable between locking and unlocking.

[00:09:52] Speaker 04:
And the secondary references taught this feature.

[00:09:55] Speaker 04:
But here the court reversed because there was no showing that the added functionality of versatility from this locking selection added, and to quote your honor, it would do little more than add unwanted cost and complexity to the system.

[00:10:13] Speaker 04:
That's exactly what's going on here.

[00:10:14] Speaker 04:
No, it's not what's going on here.

[00:10:16] Speaker 04:
It's not unwanted versatility.

[00:10:18] Speaker 04:
It's wanted versatility.

[00:10:20] Speaker 04:
And that brings me to what I pre-deleted to, Your Honor, addressing the actual merits of the facts on versatility.

[00:10:28] Speaker 04:
So if we actually look at Samsung's facts on versatility, they don't show motivation because the versatility that is relied on comes from the UMIDA reference, the column one of UMIDA, where UMIDA discusses that in the prior art,

[00:10:46] Speaker 04:
There was an issue where the functionality for these sort of video processors were external to CMOS sensors.

[00:10:52] Speaker 04:
They were on the user's computer.

[00:10:54] Speaker 04:
And the versatility that UMIDA desires is moving and migrating all these different functionalities for video processing and putting those onto a single chip.

[00:11:04] Speaker 04:
That sort of versatility doesn't relate at all to interface circuits, your honor, or how the data gets from the CMOS sensor to the processor.

[00:11:11] Speaker 00:
Are you saying the board was wrong in concluding that there was actually an industry demand to support both single and differential interfaces?

[00:11:21] Speaker 04:
Absolutely, Your Honor.

[00:11:22] Speaker 04:
The first person to recognize that were the inventors here at the 290 patent.

[00:11:26] Speaker 04:
There's nothing in the record, either from naked arguments by Dr. Baker or the actual references that shows that there is a desire or market pressure

[00:11:38] Speaker 04:
to have the sort of selectable interface circuits incorporated into CMOS sensors.

[00:11:43] Speaker 04:
The first person to realize this benefit were the inventors of the 290 pad.

[00:11:48] Speaker 01:
Did you just say that their witness, Dr. Baker, made this assertion that you think he didn't have support for it?

[00:11:55] Speaker 04:
I know, Your Honor.

[00:11:55] Speaker 04:
What I was trying to say is there is no evidence coming from, or rationales coming from Dr. Baker that address this market need or pressure point.

[00:12:07] Speaker 04:
What Dr. Baker did in his analysis was look at each one of these motivations in a nutshell and talks about the need to balance these, but doesn't explain how this balance would provide a net benefit over the prior art, which already had CMOS sensors that used single-ended interfaces and CMOS sensors that used differential interfaces.

[00:12:29] Speaker 04:
Without any showing that the versatility that Samsung asserts outweighs the added cost that using these sort of interfaces

[00:12:36] Speaker 04:
We're left with the situation in Ray Schweikert, where there's no showing of any benefit to this supposed added functionality.

[00:12:44] Speaker 00:
But as I understand Dr. Baker's testimony, what he was saying is that the best balance of cost, throughput, and versatility came from this combination.

[00:12:55] Speaker 00:
So cost isn't the only factor.

[00:12:58] Speaker 00:
So why is that testimony so wrong that we should have to say that

[00:13:05] Speaker 00:
the board doesn't have sufficient evidence to support it, given our differential standard of review.

[00:13:12] Speaker 04:
So, first, Your Honor, the summary of Dr. Baker's analysis is accurate.

[00:13:17] Speaker 04:
But Dr. Baker was looking at the cost-benefit of including both a single-ended interface as well as a differential interface on the chip.

[00:13:27] Speaker 04:
But that presupposes that there was a need in the art for this.

[00:13:30] Speaker 04:
There's nothing in the actual references that talks about

[00:13:33] Speaker 04:
that there's added performance provided by including this sort of doubling up of a single-ended interface, as well as a differential interface.

[00:13:45] Speaker 04:
There's nothing that shows that the primary references cannot use a purely single-ended interface.

[00:13:52] Speaker 04:
So, Dr. Baker's analysis on balancing is fundamentally flawed from the onset, and there's nothing that backstops that with any sort of cost analysis that compares

[00:14:03] Speaker 04:
the single selective interface with a purely single, sorry, there's nothing in the analysis that looks at a selectable interface's cost versus using a purely single ended interface.

[00:14:17] Speaker 02:
Without that sort of evidence.

[00:14:32] Speaker 02:
Sir, Pepe, is that it?

[00:14:33] Speaker 02:
Pepe, yes.

[00:14:40] Speaker 03:
May it please the court.

[00:14:44] Speaker 03:
The board here found four separate combinations render Claim 10 obvious.

[00:14:51] Speaker 03:
This court only needs to find one of those combinations supported by substantial evidence to affirm the board's decision.

[00:14:59] Speaker 03:
I want to take a step back for a moment because it's important to put claim one into perspective to correct something that Council stated at the beginning of his argument.

[00:15:08] Speaker 03:
He stated that it was the inventors of the 290 patent that first came up with and recognized the benefits of a selectable combined interface, an interface with a single-ended and differential signaling path.

[00:15:23] Speaker 03:
That's incorrect.

[00:15:24] Speaker 03:
Roe and Toshiba disclose exactly that.

[00:15:28] Speaker 03:
That's what claim one of the 290 patent is all about, a combined, selectable, single-ended, and differential interface.

[00:15:37] Speaker 03:
The board found that claim anticipated by Rowe and Toshiba.

[00:15:43] Speaker 03:
And in Rowe and Toshiba, they discussed the advantages to having single-ended and differential interfaces in one circuit.

[00:15:50] Speaker 03:
Claim 10, which is that issue here, simply takes this, and they did not appeal

[00:15:57] Speaker 03:
Claim 1.

[00:15:58] Speaker 00:
Yeah, I forgot to ask about that reference to jurisdictional questions, but nobody's appealed Claim 1, right?

[00:16:07] Speaker 00:
That's correct.

[00:16:08] Speaker 03:
It was in their notice of appeal.

[00:16:11] Speaker 03:
They chose not to brief it.

[00:16:13] Speaker 03:
They raised a jurisdictional issue that we disagree with.

[00:16:16] Speaker 03:
They could have argued it.

[00:16:18] Speaker 03:
They chose not to.

[00:16:19] Speaker 03:
Claim 1 is anticipated by Rowan Toshiba.

[00:16:22] Speaker 03:
What Claim 10 does is take this anticipated interface of Claim 1.

[00:16:27] Speaker 03:
and simply use it to connect an image sensor and an image processor.

[00:16:32] Speaker 03:
That's it.

[00:16:32] Speaker 03:
If you look in our brief on page 15, we show that the vast majority of the limitations of claim 10 overlap identically with claim one.

[00:16:42] Speaker 03:
The only new limitations are a sensor and a processor.

[00:16:47] Speaker 03:
The board found it would be obvious with four separate combinations to take the RO or Toshiba interfaces

[00:16:55] Speaker 03:
and use them in either the UNITA or Sears imaging systems.

[00:17:00] Speaker 03:
And that is what's at issue here, is whether or not there was a motivation to make those four separate combinations.

[00:17:09] Speaker 03:
What's the best combination, do you think?

[00:17:12] Speaker 03:
In our view, they're all great combinations.

[00:17:16] Speaker 00:
That's like a waiter saying everything on the menu.

[00:17:21] Speaker 03:
Sears and Roe is a simple combination.

[00:17:25] Speaker 03:
to deal with.

[00:17:28] Speaker 03:
Sears says we want a system that has high throughput, minimal cost.

[00:17:37] Speaker 03:
What Dr. Baker said, and what the board agreed with, is that if you use the interfaces of Rho or Toshiba, let's focus on Rho, you're going to get a high throughput interface that will have minimal cost.

[00:17:51] Speaker 03:
It looked at all of these factors.

[00:17:53] Speaker 03:
Why is it high throughput?

[00:17:54] Speaker 03:
It's high throughput because it has a differential interface.

[00:17:59] Speaker 00:
So the quote that I referred back to that the board said is that Dr. Baker talked about this combination.

[00:18:07] Speaker 00:
I think it was Sears and Rowe or Sears and Toshiba.

[00:18:11] Speaker 00:
But as having the Dr. Baker said, it's the best combination of throughput, versatility, and cost.

[00:18:20] Speaker 00:
So he didn't necessarily say it was going to overall

[00:18:24] Speaker 00:
make the cost less, but he said you get the benefits without a lot of cost increase, as I read it.

[00:18:30] Speaker 03:
That's correct.

[00:18:31] Speaker 03:
There's a balancing here of all of these factors.

[00:18:35] Speaker 03:
Versatility was something that was specifically called out by the Umida reference.

[00:18:40] Speaker 00:
So would you agree with your friend on the other side that it doesn't necessarily have an absolute reduction in cost?

[00:18:46] Speaker 03:
We believe it does because you're getting a highly versatile interface because it's compatible with both single-ended

[00:18:54] Speaker 03:
and differential, but you're getting a lower cost interface because you're combining those single-ended and differential interfaces into one circuit.

[00:19:03] Speaker 03:
Otherwise, if you had separate interfaces, a separate single-ended, separate differential, you would have at least three, possibly four or five pins.

[00:19:14] Speaker 03:
By combining them, you're down to two.

[00:19:17] Speaker 03:
You're down to two, which saves pin count, it saves cost, it saves package size,

[00:19:23] Speaker 03:
It saves chip size, which are all things that UMIDA wants in an interface.

[00:19:30] Speaker 00:
That was presented by- So you mean the relationship between pin count and these other benefits.

[00:19:36] Speaker 03:
So when you have multiple pins, the pin is a pretty large item on a circuit or on a chip.

[00:19:44] Speaker 03:
If you have to have three, four or five pins, the chip has to be bigger.

[00:19:50] Speaker 03:
The package size has to be bigger.

[00:19:52] Speaker 03:
By eliminating a pin, it doesn't sound like a lot, but it is significant because the pin takes up so much size within the chip.

[00:20:01] Speaker 03:
So going from three to two allows you to shrink that chip, shrink the package size, and save costs, save manufacturing costs.

[00:20:11] Speaker 03:
That was the beauty of Rowan Toshiba.

[00:20:14] Speaker 03:
By combining the single-ended and differential and minimizing the pin count,

[00:20:20] Speaker 03:
You also got the versatility and high performance that Yamita wanted.

[00:20:25] Speaker 03:
Yamita says, give me high performance, give me versatility.

[00:20:30] Speaker 03:
Yamita says, we want to be able to communicate single ended signals.

[00:20:35] Speaker 03:
We want to be able to communicate differential signals.

[00:20:39] Speaker 03:
If you have separate single ended, separate differential interfaces, that's going to cost money.

[00:20:44] Speaker 03:
It's going to be bigger.

[00:20:45] Speaker 03:
There's going to be more pins.

[00:20:48] Speaker 03:
If you just have a single-ended, like Hansel was suggesting, you're not gonna get hard performance.

[00:20:53] Speaker 03:
Single-ended is a bicycle, it's slow.

[00:20:57] Speaker 03:
Differential is fast, it's like a jet engine.

[00:21:00] Speaker 03:
By having both the bicycle and the jet engine in the same circuit, you're getting versatility, you're getting performance, while at the same time, you're getting a cheaper, smaller, less pin interface.

[00:21:17] Speaker 03:
That's the balancing

[00:21:18] Speaker 03:
that Dr. Baker did, and I could direct your attention to APX 3837 paragraph 114, where he specifically discusses the balancing of all these various factors.

[00:21:33] Speaker 03:
He talks about the fact that UMIDA wants a circuit that has a reduced number of pins, but at the same time, it wants high versatility

[00:21:48] Speaker 03:
and high performance.

[00:21:50] Speaker 03:
What he says, and what the board agreed with, is that by balancing all these various needs, there would be a motivation to use Roe and Toshiba in the circuit of Umida and Sears.

[00:22:03] Speaker 03:
Why?

[00:22:04] Speaker 03:
Because it meets all of those desires that Umida is seeking.

[00:22:09] Speaker 03:
Same thing with Sears.

[00:22:10] Speaker 03:
Sears wants high throughput, it wants compatibility, and it wants low cost.

[00:22:17] Speaker 03:
You take Rowan Toshiba, which has the high throughput because it has a differential interface.

[00:22:22] Speaker 03:
It has low cost because it's combining the circuits into one and combining the pins.

[00:22:28] Speaker 03:
And you're increasing compatibility because you're going to be able to use single-ended signals as well as differential signals.

[00:22:34] Speaker 00:
What's your response to your friend's argument on the other side that there was no evidentiary basis for the board to conclude that there was an industry demand for this?

[00:22:48] Speaker 03:
Your Honor, that is presented in multiple locations, both in the petition as well in Dr. Baker's declaration.

[00:22:57] Speaker 03:
For example, APPX 79, which is the petition.

[00:23:09] Speaker 03:
Hold on.

[00:23:09] Speaker 03:
Let me focus you on 128 instead, APPX 128.

[00:23:28] Speaker 03:
APPX 128 and 129 talks about implementing SEERS using Rowan Toshiba's interfaces.

[00:23:37] Speaker 03:
And it talks about, in 129, it talks about Posita, and I'm looking at the last paragraph, Your Honors, about halfway down.

[00:23:47] Speaker 03:
Posita also would have understood that even though the industry in April 99 was trending toward differential interfaces,

[00:23:54] Speaker 03:
The industry also placed importance on the option for a single-ended interface to short compatibility with existing devices that used single-ended interfaces.

[00:24:04] Speaker 03:
The industry demands to support both single-ended and differential interfaces while minimizing pin costs was a further motivation.

[00:24:14] Speaker 03:
Moreover, APPX 860 talks again about

[00:24:24] Speaker 03:
In fact, it's 861, talks about industry demands.

[00:24:28] Speaker 03:
And this is Dr. Baker's declaration.

[00:24:32] Speaker 03:
He says, and this is at the top in that first box about the fourth line, this substitution would have been obvious to try and would have been a simple design choice driven by market demands that would lead to predictable results with a reasonable expectation of success.

[00:24:51] Speaker 03:
So the record, and these are just two examples,

[00:24:53] Speaker 03:
of where Dr. Baker and Samsung pointed to market pressures, pointed to design needs.

[00:25:02] Speaker 03:
I could point you to other locations.

[00:25:05] Speaker 03:
APPX 901, 902 have similar statements about market demand and industry demands and market pressures.

[00:25:17] Speaker 03:
And finally, I believe also in APPX 3841, there's additional discussion there.

[00:25:23] Speaker 03:
So I just pointed you to a few, but there are others within the record which show and support that.

[00:25:31] Speaker 03:
One other statement that was made by my colleague here that I have to address more thoroughly was this notion of only a single entered interface could have been used, and that would have been the lower cost.

[00:25:47] Speaker 03:
And again, circling back to my point earlier, just using a single entered interface looks at

[00:25:53] Speaker 03:
cost in isolation without considering all the other desires and demands that Yamita and Sears were looking for.

[00:26:03] Speaker 03:
You can't just look at cost alone.

[00:26:06] Speaker 03:
As Judge O'Malley pointed out, our expert, our petition talks about looking at all of these factors, looking at it holistically, balancing all of them.

[00:26:17] Speaker 03:
And when you look at them as a whole,

[00:26:21] Speaker 03:
Just using a purely single-ended interface would not meet any of the other goals.

[00:26:26] Speaker 03:
It's not the ideal interface to be used for UMIDA and Sears.

[00:26:30] Speaker 03:
There's no motivation to use just purely single-ended.

[00:26:33] Speaker 03:
UMIDA and Sears want versatility.

[00:26:36] Speaker 03:
They want performance.

[00:26:37] Speaker 03:
They want low cost.

[00:26:39] Speaker 03:
We can get all these factors, Rowan Toshiba, meet them, and that's the motivation to combine.

[00:26:45] Speaker 03:
Unless there's other questions.

[00:26:49] Speaker 03:
OK.

[00:26:49] Speaker 03:
Thank you, Mr. Pepe.

[00:26:51] Speaker 02:
Adeline?

[00:27:20] Speaker 04:
Your Honors, my friend focuses on performance and throughput from Sears, so that's where I like to start our discussion here.

[00:27:28] Speaker 04:
There is no performance gain from using a selected interface circuit over using standard circuits, because a differential interface provides the same performance as a dual-use interface.

[00:27:42] Speaker 04:
So the premise that there was a trend in the art toward higher performance doesn't get us to a motivation.

[00:27:48] Speaker 04:
If there's a desire for higher performance,

[00:27:50] Speaker 04:
you use a standard off-the-shelf interface, the differential interface.

[00:27:55] Speaker 04:
So the idea that there are market trends in the art does not support Samsung's position.

[00:28:03] Speaker 04:
The 290 patent, like many inventions, is novel because it's counterintuitive.

[00:28:08] Speaker 04:
It's counterintuitive to use a selectable interface and these sort of CMOS sensors because the prior art focused on, when you needed performance, you used a

[00:28:19] Speaker 04:
differential interface, but those have higher costs than a single-ended interface.

[00:28:26] Speaker 04:
The 290 inventors were the first to recognize that this counterintuitive combination of a CMOS sensor with a selectable interface provides a justifiable benefit.

[00:28:38] Speaker 04:
All the evidence that the board and Samsung point to look at these naked ideas of cost, performance, and versatility.

[00:28:47] Speaker 04:
They don't look at them together and actually show

[00:28:49] Speaker 04:
that the added benefit to versatility outweighs the detrimental impact it has on higher costs.