Case Nos. IPR2015-01470, -01471, -01472, -01473, -01474 and -01475 25 requisite information. Miluzzo and the disputed patents, on the other hand, use data from sensors to drive an understanding of the surrounding context without a preconceived notion as to the result. 57. Robarts’ scheme is therefore more about providing a user a display (see Ex. GOOG 1008 at Fig. 11A) with information that the user may find relevant, rather than about determining complex contextual awareness and providing information or taking action to a hierarchy. 58. Because the processes of Robarts and Miluzzo flow in opposition directions, combination of the two references is impossible without a complete restructuring of the process of one or the other of the references. D. The Combination of Miluzzo and Robarts is Missing the “Unique Social Signature” of the Disputed Patents 59. The disputed claims of the patents at issue in these IPRs require a memory that stores social templates corresponding to unique social signatures, which in the disputed patents, are comprised of sensor value ranges against which the detected social signature is compared in order to arrive at a context classification. (See, e.g., ’522 patent at Abstract, claim 1 and passim.) 60. Robarts on the other hand allows multiple themes to match the same attributes. (Ex. GOOG 1008 at ¶ [0160].) By teaching attributes that can match multiple themes, Robarts effectively teaches away from the “unique social signature” of the disputed patents. e.Digital Corporation Exhibit 2015 - Page 27 Case Nos. IPR2015-01470, -01471, -01472, -01473, -01474 and -01475 26 61. In addition, attributes in Robarts are selected to identify themes that match a “current context.” (Id. at ¶ [0160].) A POSA would understand that it would be impossible to control “matching attributes” if independent vendors are supplying themes. It is very likely that vendors could come up with the same attributes for different themes, again resulting in non-unique social signatures. E. There is no TSM for a POSA to Combine Miluzzo with Robarts 62. I understand that Petitioners assert that Miluzzo does not disclose or teach 1) how to infer user status, 2) where to store user status, 3) how to organize user status, and 4) how to retrieve user status. However, a POSA would not be motivated to combine Miluzzo with Robarts because Robarts does not disclose how to infer user status, and Miluzzo – contrary to Petitioners’ assertions – does in fact disclose the other purportedly missing components. 63. Robarts does not explain how the Context Clients (“CCs) determine context (or activity) and Miluzzo already discloses “storage 210” in figure 2. (Ex. GOOG 1007.) Unlike an inference engine, storage is not complicated. A POSA would therefore know storage to mean memory, a hard drive, or disk, or any other well known forms of mobile and server storage mediums. Miluzzo also discloses how to organize user status as evidenced by the fact that Miluzzo lists several applications (e.g. MySpace) and “plugins” that use status. (Id. at ¶ [0051].) Miluzzo also discloses user status retrieval. It states that “presence server 116” e.Digital Corporation Exhibit 2015 - Page 28 Case Nos. IPR2015-01470, -01471, -01472, -01473, -01474 and -01475 27 sends status to applications like “Facebook.” (Id. at ¶ [0058].) Miluzzo is therefore a complete, functional invention apart from explaining the functionality of its “inference engine.” 64. Accordingly, a POSA would have understood that there is no reason to combine Miluzzo with Robarts. The only justification Petitioners’ would have for combining Robarts with Miluzzo is to satisfy a post hoc, hindsight obviousness analysis. F. The “Social Hierarchy” of the Dependent Claims Involves Nonobvious Complexity 65. I understand that Petitioners assert that the combination of Miluzzo and Robarts renders certain dependent claims of the disputed patents obvious. These dependent claims include claims covering a form of “social hierarchy” described in, for example, dependent claim 3 of the ’522 patent, dependent claim 3 of the ’523 patent, dependent claim 5 of the ’524 patent, dependent claim 3 of the ’618 patent, and dependent claim 3 of the ’619 patent. 66. Both Miluzzo and Robarts disclose and teach a simple “on/off” privacy type sharing in response to the presence sensed or current theme. 67. Robarts provides that there is a “user’s desired scope of audience for information being output.” (Ex. 1008 at ¶ [0065].) The user in Robarts sets privacy and audience permissions and scope. (Id., see also id. at ¶ [0100].) 68. Miluzzo teaches the use of pre-determined privacy policies and buddy e.Digital Corporation Exhibit 2015 - Page 29