Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 1 of 57
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`EXHIBIT C
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 2 of 57
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`TCL A1 (“The accused product”)
`The accused product practices a method, performed in a character entry system (e.g., predictive text system
`of the accused product) so that incomplete input character strings input by a user interacting with the
`character entry system, that are part of a series of input character strings which establish a context for the
`incomplete input character string (e.g., previous appearance of charter strings in adjacent fashion), can be
`completed by a selection of a presented character string (e.g., selection of suggested selectable words) using
`an input device (e.g., Touchscreen of the accused product) connected to the character entry system.
`
`
`
`US7991784
`1. A method, performed
`in a character entry
`system
`so
`that
`incomplete
`input
`character strings input
`by a user interacting
`with the character entry
`system, that are part of a
`series of input character
`strings which establish a
`context
`for
`the
`incomplete
`input
`character string, can be
`completed
`by
`a
`selection of a presented
`character string using an
`input device connected
`to the character entry
`system,
`the method
`comprising
`
`https://shop.tracfone.com/shop/en/tracfonestore/tf-alcatel-tcl-a1-a501dl
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 3 of 57
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`contextual
`computing
`between
`associations
`character
`multiple
`based
`upon
`strings
`occurrence of character
`strings relative to each
`other
`in
`documents
`present in the character
`entry system, wherein
`the
`computing
`contextual associations
`comprises:
`
`
`https://files.bbystatic.com/zNtiTLuJOBf9%2F7gMzsOKAw%3D%3D/B6A1A272-A51A-4B11-B1F2-
`87BB0077BD49.pdf
`
`The accused product practices computing contextual associations between multiple character strings based
`upon occurrence of character strings relative to each other (e.g., number of adjacent co-occurrence of pairs
`of various character strings) in documents (e.g., Notes, message mail, etc.) present in the character entry
`system.
`
`As shown below, various character strings are associated with each other based on their mutual co-
`occurrence with adjacency. For instance, when a couple of paragraphs, hereinafter referred to as “The
`Combined Essay” with phrase “James Maxwell”, “James Maxima”, and "James Michener" are typed, and
`therefore input to the predictive text system of the accused product, the predictive text system of the accused
`product, based on the frequency of mutual co-occurrence of the string “James” with “Maxwell”, “Maxima”,
`and “Michener”, in the given order, start providing selectable character strings when “James m” is typed.
`The two selectable character strings, among others, are: Maxwell, and Maxima. For the reliability of the
`demonstration, The combined Essay is typed five times. The frequency of occurrence of “James Maxwell”,
`“James “Maxima”, and “James Michener” is 105, 50, and 20 respectively calculated over the Combined
`Essay repeated for five times.
`
`As shown below, since pairs of strings, for example, “James” and “Maxwell” has adjacently appeared for
`the greatest number of times, 105 to be precise, in comparison to the other pairs of strings with “James” as
`one of the strings, Maxwell appears as a selectable option followed by “Maxima”, since the number of
`adjunct appearances of “James” with “Maxima” is 50.
`Shown below is a Matrix depicting association of character string “James” with character strings
`“Maxwell”, “Maxima”, and “Michener”.
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`

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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 4 of 57
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`Character
`String-1
`
`James
`James
`James
`
`Character String Matrix Vis a Vis the paragraphs
`Character
`Number of co-occurrence of the Character String-1 and Character
`String-2
`String-2, with both being adjacent to each other in that order
` (Per 5 entry of “The Combined Essay”)
`50 (10 James Maxima)
`105 (21 James Maxwell)
`4 (20 James Michener)
`
`Maxima
`Maxwell
`Michener
`
`
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 5 of 57
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`The Combined Essay, Part-1
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 6 of 57
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`The Combined Essay, Part-2
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 7 of 57
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`The Combined Essay, Part-3
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 8 of 57
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`The Combined Essay, Part-4
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 9 of 57
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`The Combined Essay, Part-5
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 10 of 57
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`The Combined Essay, Part-6
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 11 of 57
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`The Combined Essay, Part-7
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 12 of 57
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`The Combined Essay, Part-8
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 13 of 57
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`
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`The Combined Essay, Part-9
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`The accused product practices identifying pertinent documents (e.g., stored notes or notes being composed)
`present in the character entry system (e.g., predictive text system of the accused product).
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`i) identifying pertinent
`documents present
`in
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`

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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 14 of 57
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`character
`the
`system,
`
`entry
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`The Combined Essay, Part-1
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 15 of 57
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`The Combined Essay, Part-2
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 16 of 57
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`The Combined Essay, Part-3
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 17 of 57
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`The Combined Essay, Part-4
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 18 of 57
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`The Combined Essay, Part-5
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 19 of 57
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`The Combined Essay, Part-6
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 20 of 57
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`The Combined Essay, Part-7
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 21 of 57
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`The Combined Essay, Part-8
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 22 of 57
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`ii) creating a list of
`character
`strings
`contained
`within
`
`
`
`The Combined Essay, Part-9
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`The accused product practices creating a list of character strings contained within documents in the
`character entry system (e.g., predictive text system of the accused product) and creating an interrelationship
`between distinct character strings (e.g., frequency of adjacent appearance of pairs of character strings) in
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 23 of 57
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`an
`
`the
`in
`documents
`character entry system;
`and
`creating
`iii)
`interrelationship
`between
`distinct
`character strings in the
`list
`using
`their
`in
`occurrence
`the
`of
`documents
`the
`character entry system;
`
`the list using their occurrence in the documents of the character entry system (e.g., predictive text system
`of the accused product).
`
`As shown below, various character strings are associated with each other based on their mutual co-
`occurrence with adjacency. For instance, when a couple of paragraphs, hereinafter referred to as “The
`Combined Essay” with phrase “James Maxwell”, “James Maxima”, and "James Michener" are typed, and
`therefore input to the predictive text system of the accused product, the predictive text system of the accused
`product, based on the frequency of mutual co-occurrence of the string “James” with “Maxwell”, “Maxima”,
`and “Michener”, in the given order, start providing selectable character strings when “James m” is typed.
`The two selectable character strings, among others, are: Maxwell, and Maxima. For the reliability of the
`demonstration, The combined Essay is typed five times. The frequency of occurrence of “James Maxwell”,
`“James “Maxima”, and “James Michener” is 105, 50, and 20 respectively calculated over the Combined
`Essay repeated for five times.
`
`
`For calculating mutual co-occurrences of pairs of character strings the accused product must create a list of
`character strings contained in the documents (i.e., previously stored notes or notes being composed).
`
`
`
`Character String Matrix Vis a Vis the paragraphs
`Character
`Number of co-occurrence of the Character String-1 and Character
`String-2
`String-2, with both being adjacent to each other in that order
` (Per 5 entry of “The Combined Essay”)
`50 (10 James Maxima)
`105 (21 James Maxwell)
`4 (20 James Michener)
`
`Maxima
`Maxwell
`Michener
`
`Character
`String-1
`
`James
`James
`James
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`
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`

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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 24 of 57
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`The Combined Essay, Part-1
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 25 of 57
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`The Combined Essay, Part-2
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 26 of 57
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`The Combined Essay, Part-3
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 27 of 57
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`The Combined Essay, Part-4
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 28 of 57
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`The Combined Essay, Part-5
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 29 of 57
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`The Combined Essay, Part-6
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 30 of 57
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`The Combined Essay, Part-7
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 31 of 57
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`The Combined Essay, Part-8
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 32 of 57
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`in response to the user
`inputting a specified
`threshold of individual
`
`
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`The Combined Essay, Part-9
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`The accused product practices in response to the user inputting a specified threshold (e.g., inputting a
`starting character of a word followed by the corresponding preceding word) of individual characters using
`the input device (e.g., Touchscreen of the accused product), identifying at least one selectable character
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`

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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 33 of 57
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`the
`characters using
`input device, identifying
`at least one selectable
`character string from
`among
`the character
`strings used in creating
`the computed contextual
`associations
`that can
`complete the incomplete
`input character string in
`context;
`
`string (e.g., predicting selectable words for user selection) from among the character strings used in creating
`the computed contextual associations that can complete the incomplete input character string in context.
`
`As shown below, since pairs of strings, for example, “James” and “Maxwell” has adjacently appeared for
`the most number of times, 105 to be precise, in comparison to the other pairs of strings with “James” as
`one of the strings, Maxwell appears as a selectable option followed by “Maxima”, since the number of
`adjacent appearances of “James” with “Maxima” is 50 and which is greater than the adjacent appearance
`of “James” with “Michener” which stands at 20.
`
`
`Shown below is a Matrix depicting association of character string “James” with character strings
`“Maxwell”, “Maxima”, and “Michener”.
`
`
`Character String Matrix Vis a Vis the paragraphs
`Character
`Number of co-occurrence of the Character String-1 and Character
`String-2
`String-2, with both being adjacent to each other in that order
` (Per 5 entry of “The Combined Essay”)
`50 (10 James Maxima)
`105 (21 James Maxwell)
`4 (20 James Michener)
`
`Maxima
`Maxwell
`Michener
`
`Character
`String-1
`
`James
`James
`James
`
`
`
`
`
`

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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 34 of 57
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`The Combined Essay, Part-1
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 35 of 57
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`The Combined Essay, Part-2
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 36 of 57
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`The Combined Essay, Part-3
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 37 of 57
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`The Combined Essay, Part-4
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 38 of 57
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`The Combined Essay, Part-5
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 39 of 57
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`The Combined Essay, Part-6
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 40 of 57
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`The Combined Essay, Part-7
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 41 of 57
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`The Combined Essay, Part-8
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 42 of 57
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`The Combined Essay, Part-9
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 43 of 57
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 44 of 57
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`providing the identified
`at least one selectable
`character string to a user
`in a manner suitable for
`selection by the user
`using the input device;
`and
`
`The accused product practices providing the identified at least one selectable character string (e.g.,
`suggesting words for user selection) to a user in a manner suitable for selection by the user using the input
`device (e.g., Touchscreen of the accused product).
`
`As shown below, since pairs of strings, for example, “James” and “Maxwell” has adjacently appeared for
`the most number of times, 105 to be precise, in comparison to the other pairs of strings with “James” as
`one of the strings, Maxwell appears as a selectable option followed by “Maxima”, since the number of
`adjacent appearances of “James” with “Maxima” is 50 and which is greater than the adjacent appearance
`of “James” with “Michener” which stands at 20.
`
`Shown below is a Matrix depicting association of character string “James” with character strings
`“Maxwell”, “Maxima”, and “Michener”.
`
`
`
`Character String Matrix Vis a Vis the paragraphs
`Character
`Number of co-occurrence of the Character String-1 and Character
`String-2
`String-2, with both being adjacent to each other in that order
` (Per 5 entry of “The Combined Essay”)
`50 (10 James Maxima)
`105 (21 James Maxwell)
`4 (20 James Michner)
`
`Maxima
`Maxwell
`Michener
`
`Character
`String-1
`
`James
`James
`James
`
`
`
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`

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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 45 of 57
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`The Combined Essay, Part-1
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 46 of 57
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`The Combined Essay, Part-2
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 47 of 57
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`The Combined Essay, Part-3
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 48 of 57
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`The Combined Essay, Part-4
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 49 of 57
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`The Combined Essay, Part-5
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 50 of 57
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`The Combined Essay, Part-6
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 51 of 57
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`The Combined Essay, Part-7
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 52 of 57
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`The Combined Essay, Part-8
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 53 of 57
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`The Combined Essay, Part-9
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 54 of 57
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 55 of 57
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`receiving, in the system,
`the user's selection and
`completing
`the
`incomplete
`input
`character string based
`upon the selection.
`
`The accused product practices receiving, in the system, the user's selection (e.g., selecting a suggested word
`by user) and completing the incomplete input character string based upon the selection.
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`Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 56 of 57
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