Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 1 of 35 Page ID #:34
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 1 of 35 Page ID #:34
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`EXHIBIT C
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`EXHIBIT C
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`

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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 2 of 35 Page ID #:35
`
`Infringement of U.S. Patent No. 8,378,875 via UEI Accused Products
`
`
`As used in this claim chart, “UEI Accused Products” include without limitation the products and models identified in the Complaint as
`infringing U.S. Patent No. 8,378,875, as well as any other product that operates in a manner reasonably similar to the specific theory of
`infringement identified in the claim chart below.
`
`Roku, Inc. (“Roku”) contends that UEI (as defined in the Complaint) directly infringes the method claims listed below when UEI or
`those acting on UEI’s behalf, such as employees, officers, directors, principals, agents, consultants, and/or representatives use, test or
`demonstrate the UEI Accused Products in the United States.
`
`Roku contends that UEI directly infringes the asserted product claims by making, using, offering to sell, or selling within the United
`States or importing into the United States the UEI Accused Products.
`
`Further, Roku contends that UEI’s customers and/or end users directly infringe the method and product claims listed below by making,
`using, offering to sell, or selling within the United States or importing into the United States the UEI Accused Products, and UEI
`therefore indirectly infringes by way of inducement and/or contributory infringement.
`
`Roku contends that each of the following limitations is met literally, and, to the extent a limitation is not met literally, it is met under
`the doctrine of equivalents.
`
`This claim chart is based on the information currently available to Roku and is intended to be exemplary in nature. The information
`cited herein related to the UEI URC 7935 is representative in all material aspects for other UEI Accused Products with respect to any of
`the charted claims that are asserted against any of the other UEI Accused Products. Based on information presently available to Roku,
`each of the UEI Accused Products is understood to operate in the same manner with respect to the contentions provided in this chart for
`each asserted claim. Roku reserves all rights to update and elaborate its infringement positions, including as Roku obtains additional
`information during the course of discovery.
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 3 of 35 Page ID #:36
`
`U.S. Patent No. 8,378,875
`
`1pre A method for setting up a
`Remote Control that
`includes a keyboard, a
`processor, a memory, and
`a transmitter, the method
`comprising the steps of:
`
`UEI Accused Products
`To the extent the preamble is construed as limiting, the UEI Accused Products provide a
`method for setting up a remote control that includes a keyboard, a processor, a memory, and a
`transmitter.
`
`The Streamer Remote URC 7935 is a remote control that includes a keyboard, processor, a
`memory, and a transmitter.
`
`For example, during the setup process, holding down a key on the keyboard causes the
`processor to retrieve codes stored in a remote control memory and transmit function signals
`via an IR transmitter.
`
`Tear-down photographs and Maxim datasheet below provide evidence that the URC 7935
`includes a keyboard, a Maxim MAXQ610 processor, which contains memory, and IR
`transmitters.
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 4 of 35 Page ID #:37
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`
`
`U.S. Patent No. 8,378,875
`
`UEI Accused Products
`
`See Streamer Remote URC 7935 User Manual.
`
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 5 of 35 Page ID #:38
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`
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`U.S. Patent No. 8,378,875
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`
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`UEI Accused Products
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`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 6 of 35 Page ID #:39
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`
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`U.S. Patent No. 8,378,875
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`UEI Accused Products
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 7 of 35 Page ID #:40
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`
`
`U.S. Patent No. 8,378,875
`
`UEI Accused Products
`
`See URC 7935 Teardown Images.
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 8 of 35 Page ID #:41
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`
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`U.S. Patent No. 8,378,875
`
`UEI Accused Products
`
`See MAXQ610 Datasheet at 1.
`
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 9 of 35 Page ID #:42
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`
`
`U.S. Patent No. 8,378,875
`
`UEI Accused Products
`
`
`See Streamer Remote URC 7935 User Manual.
`
`
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 10 of 35 Page ID #:43
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 11 of 35 Page ID #:44
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`
`
`U.S. Patent No. 8,378,875
`
`UEI Accused Products
`See Streamer Remote URC 7935 User Manual.
`
`
`
`1a
`
`entering, via the keyboard
`and processor, a
`configuration mode;
`
`
`
`See Streamer Remote URC 7935 User Manual.
`
`
`The UEI Accused Products provide the step of entering, via the keyboard and processor, a
`configuration mode.
`
`For example, when the “TV Power” and “BACK” keys on the keyboard are held down, the
`remote control enters a configuration mode for controlling a TV.
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 12 of 35 Page ID #:45
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 13 of 35 Page ID #:46
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 14 of 35 Page ID #:47
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`
`
`U.S. Patent No. 8,378,875
`
`1b
`
`accepting, via the
`keyboard and processor,
`an identifier-entry; and
`
`UEI Accused Products
`See Streamer Remote URC 7935 User Manual.
`
`The Accused Products provide the step of accepting, via the keyboard and processor, an
`identifier-entry.
`
`The remote control accepts keyboard entries that are identifier-entries. For example, to set up
`the remote control to control a Samsung TV, a “Replay” button entry is accepted as an
`identifier-entry. In another example, to set up the remote control to control a Zenith TV, a 5
`digit code entry is accepted as an identifier-entry.
`
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 15 of 35 Page ID #:48
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`
`
`U.S. Patent No. 8,378,875
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`UEI Accused Products
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`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 16 of 35 Page ID #:49
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`
`
`U.S. Patent No. 8,378,875
`
`UEI Accused Products
`
`1c
`
`scanning, via the processor
`and memory, though
`remote control code-sets in
`a database stored in the
`
`See Streamer Remote URC 7935 User Manual.
`
`The UEI Accused Products provide the step of scanning, via the processor and memory,
`though remote control code-sets in a database stored in the memory of the remote control.
`
`
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 17 of 35 Page ID #:50
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`
`
`U.S. Patent No. 8,378,875
`memory of the Remote
`Control, wherein the step
`of scanning comprises:
`
`UEI Accused Products
`For example, the remote control via the processor and memory scans through remote control
`code-sets in a database stored in the memory of the remote control.
`
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 18 of 35 Page ID #:51
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 19 of 35 Page ID #:52
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 20 of 35 Page ID #:53
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`
`
`U.S. Patent No. 8,378,875
`
`1d
`
`in case that the identifier-
`entry is a brand-identifier
`that identifies a brand, (i)
`iterating, via the processor
`and memory, through the
`remote control code-sets
`corresponding to the brand
`and (ii) testing said remote
`control code-sets by
`sending, via the
`transmitter, to a Consumer
`Electronic device for a
`given iteration, one or
`more specific control code
`functions of a
`corresponding remote
`control code-set, and
`
`UEI Accused Products
`See Streamer Remote URC7935 User Manual.
`
`In case that the identifier-entry is a brand-identifier that identifies a brand, the UEI Accused
`Products provide the step of (i) iterating, via the processor and memory, through the remote
`control code-sets corresponding to the brand and (ii) testing said remote control code-sets by
`sending, via the transmitter, to a Consumer Electronic device for a given iteration, one or more
`specific control code functions of a corresponding remote control code-set.
`
`For example, during the “SimpleSet” setup procedure, the identifier-entry corresponds to a
`brand-identifier (e.g., the “Replay” button corresponds to Samsung). In that case, the remote
`control locates an appropriate code-set by iterating through code-sets and testing a current
`code-set by transmitting a control function.
`
`For example, during the setup procedure for a TV, the remote control tries code-sets for the
`identified brand in succession , sending the “Power” key for each code-set every 3 seconds,
`until the TV reacts, indicating that the appropriate code-set has been located.
`
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 21 of 35 Page ID #:54
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 22 of 35 Page ID #:55
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`
`
`1e
`
`U.S. Patent No. 8,378,875
`
`in case that the identifier-
`entry is a code-set-
`identifier that identifies a
`single remote control
`code-set which in not
`pointed to by a brand-
`identifier, testing the
`single remote control
`code-set corresponding to
`the code-set-identifier by
`sending, via the
`transmitter, to the
`Consumer Electronic
`device one or more
`specific control code
`functions of the
`corresponding single
`remote control code-set.
`
`UEI Accused Products
`See Streamer Remote URC7935 User Manual.
`
`In case that the identifier-entry is a code-set-identifier that identifies a single remote control
`code-set which in not pointed to by a brand-identifier, the UEI Accused Products provide the
`step of testing the single remote control code-set corresponding to the code-set-identifier by
`sending, via the transmitter, to the consumer electronic device one or more specific control
`code functions of the corresponding single remote control code-set.
`
`For example, during the “Setup by Code” setup procedure for the remote control, the
`identifier-entry is a code-set identifier that corresponds to a single code-set for a device whose
`brand is not listed in the “SimpleSet” procedure (e.g. 11565 for a Zenith TV). The remote
`control tests the single code-set identified by the code-set-identifier by transmitting to the
`consumer electronics device a control code for either “Power” or “Mute,” depending on the
`type of device being controlled.
`
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 23 of 35 Page ID #:56
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 24 of 35 Page ID #:57
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`
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`
`
`10
`
`U.S. Patent No. 8,378,875
`
`Claim 10
`
`A non-transitory
`computer-readable
`medium embodied with a
`computer program that
`comprises computer
`program code executable
`by a processor to perform
`the steps of setting up a
`Remote Control of claim
`1.
`
`UEI Accused Products
`See Streamer Remote URC7935 User Manual.
`
`
`
`The UEI Accused Products comprise a non-transitory computer-readable medium embodied
`with a computer program that comprises computer program code executable by a processor to
`perform the steps of setting up a remote control of claim 1.
`
`The UEI Accused Products have a processor and memory containing computer code that when
`executed performs the steps of setting up a remote control as set forth in claim 1.
`
`See evidence for claim 1.
`
`
`
`Claim 11
`
`
`
`11pre A method for setting up a
`Remote Control that
`includes a keyboard, a
`processor, a memory, and
`a transmitter, the method
`comprising the steps of
`
`To the extent the preamble is construed as limiting, the UEI Accused Products provide a
`method for setting up a Remote Control that includes a keyboard, a processor, a memory, and
`a transmitter.
`
`See evidence for claim 1 preamble.
`
`11a
`
`11b
`
`entering, via the keyboard
`and processor, a
`configuration mode;
`
`scanning, via the processor
`and memory, though
`remote control code-sets in
`
`The UEI Accused Products provide the step of entering, via the keyboard and processor, a
`configuration mode.
`
`See evidence for claim element 1a.
`
`The UEI Accused Products provide the step of scanning, via the processor and memory,
`though remote control code-sets in a database stored in the memory of the remote control.
`
`
`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 25 of 35 Page ID #:58
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`
`
`11c
`
`U.S. Patent No. 8,378,875
`a database stored in the
`memory of the Remote
`Control;
`
`UEI Accused Products
`See evidence for claim element 1c.
`
`
`testing, via the keyboard,
`if individuals keys of a
`code set send, via the
`transmitter, correct codes
`and receiving, via the
`keyboard, user-feedback
`on the correct and/or
`incorrect working of the
`tested keys;
`
`The UEI Accused Products provide the step of testing, via the keyboard, if individual keys of a
`code set send, via the transmitter, correct codes and receiving, via the keyboard, user-feedback
`on the correct and/or incorrect working of the tested keys.
`
`For example, during the “SimpleSet” setup procedure for a TV, the remote control tries code-
`sets in succession, sending the “Power” key for each code-set every 3 seconds, to test one of
`the codes in a current code-set. If successful, the User’s Manual invites the user to test other
`remote keys to “find [if] one or more keys do not work as you expect. . . .”
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 26 of 35 Page ID #:59
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 27 of 35 Page ID #:60
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`
`
`U.S. Patent No. 8,378,875
`
`UEI Accused Products
`See Streamer Remote URC7935 User Manual.
`
`The user may then provide feedback that the key did not work by entering the Learning Mode.
`
`
`11d
`
`replacing, via the
`processor and memory,
`
`See Streamer Remote URC 7935 User Manual.
`
`The UEI Accused Products provide the step of replacing, via the processor and memory, non-
`working codes with codes from at least a further remote control code-set.
`
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 28 of 35 Page ID #:61
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`
`
`U.S. Patent No. 8,378,875
`non-working codes with
`codes from at least a
`further remote control
`code-set; and
`
`UEI Accused Products
`
`
`For example, the UEI Accused Products can learn any function from any other working remote
`control using a “Learning” procedure which is performed using the processor and memory.
`For instance, when a “Power” key is not working correctly to control a TV, a user can use the
`“Learning” procedure to replace the incorrectly working “Power” code with a newly learned
`code.
`
`
`See Streamer Remote URC 7935 User Manual.
`
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 29 of 35 Page ID #:62
`
`UEI Accused Products
`The UEI Accused Products provide the step of combining, via the processor and memory,
`correct working codes from the scanned remote control code-sets into a new custom
`configuration code set and installing, via the processor and memory the combined correct
`working codes of the new custom configuration code set for use by the remote control.
`
`For example, after a “Learning” procedure, a newly learned code is combined with existing
`codes, to provide a new custom configuration code set.
`
`
`11e
`
`U.S. Patent No. 8,378,875
`combining, via the
`processor and memory,
`correct working codes
`from the scanned remote
`control code-sets into a
`new custom configuration
`code set and installing, via
`the processor and memory,
`the combined correct
`working codes of the new
`custom configuration code
`set for use by the remote
`control.
`
`See Streamer Remote URC 7935
`
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 30 of 35 Page ID #:63
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`
`
`
`U.S. Patent No. 8,378,875
`Claim 14
`
`
`
`UEI Accused Products
`
`14pre Remote Control
`comprising:
`
`To the extent the preamble is construed as limiting, the UEI Accused Products are remote
`controls.
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 31 of 35 Page ID #:64
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`
`
`U.S. Patent No. 8,378,875
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`UEI Accused Products
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`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 32 of 35 Page ID #:65
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`
`
`U.S. Patent No. 8,378,875
`
`UEI Accused Products
`
`14a means for entering a
`configuration mode;
`
`
`
`See Streamer Remote URC 7935 User Manual.
`
`The UEI Accused Products comprise means for entering a configuration mode.
`
`For example, when the “TV Power” and “BACK” keys are pressed simultaneously, the
`processor initiates a configuration mode.
`
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`Infringement of U.S. Pat. No. 8,378,875 via UEI Accused Products
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 33 of 35 Page ID #:66
`
`UEI Accused Products
`
`See evidence for claim element 1a.
`
`The UEI Accused Products comprise means for accepting an identifier-entry.
`
`The remote control has a keyboard and processor that accept entries that act as identifiers. For
`example, to set up the remote control to control a Samsung TV, a “Replay” button entry is
`accepted as a brand-identifier. In another example, to set up the remote control to control a
`Zenith TV, a 5-digit code entry is accepted as a code-set-identifier.
`
`See evidence for claim element 1b.
`
`The UEI Accused Products comprise means for scanning though remote control code-sets in a
`database stored in a memory of the remote control.
`
`For example, the remote control contains a processor and software that perform scanning
`through remote control code-sets in a database stored in a memory of the remote control.
`
`See evidence for claim element 1c.
`
`In case that the identifier-entry is a brand-identifier that identifies a brand, the UEI Accused
`Products comprise means for scanning that are adapted for (i) iterating through the remote
`control code-sets corresponding to the brand and (ii) testing said remote control code-sets by
`sending to a consumer electronic device for a given iteration, one of more specific control
`code functions of a corresponding remote control code-set.
`
`See evidence for claim element 1d.
`
`
`
`U.S. Patent No. 8,378,875
`
`14b means for accepting an
`identifier-entry; and
`
`14c means for scanning though
`remote control code-sets in
`a database stored in a
`memory of the Remote
`Control wherein the means
`for scanning are adapted
`for:
`
`14d
`
`in case that the identifier-
`entry is a brand-identifier
`that identifies a brand, (i)
`iterating through the
`remote control code-sets
`corresponding to the brand
`and (ii) testing said remote
`control code-sets by
`sending to a Consumer
`Electronic device for a
`given iteration, one of
`more specific control code
`functions of a
`
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`Case 8:21-cv-00658 Document 1-3 Filed 04/08/21 Page 34 of 35 Page ID #:67
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`
`
`14e
`
`U.S. Patent No. 8,378,875
`corresponding remote
`control code-set
`
`in case that the identifier-
`entry is a code-set-
`identifier that identifies a
`single remote control
`code-set which is not
`pointed to by a brand-
`identifier, testing the
`single remote control
`code-set corresponding to
`the code-set-identifier by
`sending to the Consumer
`Electronic device one or
`more specific control code
`functions of the
`corresponding single
`remote control code-set.
`
`
`
`
`
`UEI Accused Products
`
`In case that the identifier-entry is a code-set-identifier that identifies a single remote control
`code-set which is not pointed to by a brand-identifier, the Accused Products comprise means
`for scanning that are adapted for testing the single remote control code-set corresponding to
`the code-set-identifier by sending to the consumer electronic device one or more specific
`control code functions of the corresponding single remote control code-set.
`
`See evidence for claim element 1e.
`
`References:
`
`[1] “OFA Streamer URC 7935”, OneForAll,
`https://www.oneforall.us/sites/default/files/2019-
`05/711949%20QSG%20ENG%20URC7935%20Walmart%20%20RDN1060319.pdf
`(“Streamer Remote URC 7935 User Manual”).
`
`[2] URC 7935 Teardown Images.
`
`[3] “16-Bit Microcontroller with Infrared Module”, Maxim Integrated Products, 2011,
`https://datasheets.maximintegrated.com/en/ds/MAXQ610.pdf
`(“MAXQ610 Datasheet”).
`
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