`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 1 of 17 PageID #:23
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`EXHIBIT B
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`EXHIBIT B
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 2 of 17 PageID #:24
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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`U.S. Patent No. 9,191,629– Motorola Mobility LLC
`Claim 1
`Script Transform LLC (“Script Transform”) provides evidence of infringement of claim 1 of U.S. Patent No. 9,191,629 (hereinafter “the ‘629
`patent”) by Motorola Mobility LLC (“Motorola”). In support thereof, Script Transform provides the following claim charts.
`“Accused Instrumentalities” as used herein refers to at least the following products and services: Video Baby Monitor products models such
`as the MBP36XL and others available online at the Motorola store (See https://www.motorolastore.com/baby-monitors/video-monitoring). Product
`documentation reveals that the Video Baby Monitor products have been available at least since 2011. Therefore, the infringement has been occurring
`since at least that time. These claim charts demonstrate Motorola’s infringement, and provide notice of such infringement, by comparing each
`element of the asserted claims to corresponding components, aspects, and/or features of the Accused Instrumentalities. These claim charts are not
`intended to constitute an expert report on infringement. These claim charts include information provided by way of example, and not by way of
`limitation.
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`The analysis set forth below is based only upon information from publicly available resources regarding the Infringing Instrumentalities, as
`Motorola has not yet provided any non-public information. An analysis of Motorola’s (or other third parties’) technical documentation, and/or
`software source code, may assist in fully identify all infringing features and functionality. Accordingly, Script Transform reserves the right to
`supplement this infringement analysis once such information is made available to Script Transform. Furthermore, Script Transform reserves the right
`to revise this infringement analysis, as appropriate, upon issuance of a court order construing any terms recited in the asserted claim.
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`Unless otherwise noted, Script Transform contends that Motorola directly infringes the ‘629 patent in violation of 35 U.S.C. § 271(a) by
`selling, offering to sell, making, using, and/or importing the Infringing Instrumentalities. The following exemplary analysis demonstrates that
`infringement. Unless otherwise noted, Script Transform further contends that the evidence below supports a finding of indirect infringement under
`35 U.S.C. §§ 271(b) and/or (c), in conjunction with other evidence of liability under one or more of those subsections. Motorola makes, uses, sells,
`imports, or offers for sale in the United States, or has made, used, sold, imported, or offered for sale in the past, without authority, or induces others
`to make, use, sell, import, or offer for sale in the United States, or has induced others to make, use, sell, import, or offer for sale in the past, without
`authority products, equipment, or services that infringe claim 1 of the ‘629 patent, including without limitation, the Accused Instrumentalities.
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`Unless otherwise noted, Script Transform believes and contends that each element of each claim asserted herein is literally met through
`Motorola’s provision of the Infringing Instrumentalities. However, to the extent that Motorola attempts to allege that any asserted claim element is
`not literally met, Script Transform believes and contends that such elements are met under the doctrine of equivalents. More specifically, in its
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`Note: All internet sources last accessed and downloaded July 1, 2020.
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 3 of 17 PageID #:25
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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`investigation and analysis of the Infringing Instrumentalities, Script Transform did not identify any substantial differences between the elements of
`the patent claim and the corresponding features of the Infringing Instrumentalities, as set forth herein. In each instance, the identified feature of the
`Infringing Instrumentalities performs at least substantially the same function in substantially the same way to achieve substantially the same result as
`the corresponding claim element.
`To the extent the chart of an asserted claim relies on evidence about certain specifically identified Accused Instrumentalities, Script
`Transform asserts that, on information and belief, any similarly-functioning instrumentalities also infringes the charted claim. Script Transform
`reserves the right to amend this infringement analysis based on other products made, used, sold, imported, or offered for sale by Motorola. Script
`Transform also reserves the right to amend this infringement analysis by citing other claims of the ‘629 patent, not listed in the claim chart, that are
`infringed by the Accused Instrumentalities. Script Transform further reserves the right to amend this infringement analysis by adding, subtracting, or
`otherwise modifying content in the “Accused Instrumentalities” column of each chart.
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`Note: All internet sources last accessed and downloaded July 1, 2020.
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 4 of 17 PageID #:26
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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`Motorola Mobility LLC
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`Motorola Mobility LLC, marketed as simply Motorola, is an American consumer electronics and telecommunications subsidiary company owned by Chinese
`technology firm Lenovo.
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`Motorola Mobility was formed on January 4, 2011, after a split of Motorola into two separate companies, with Motorola Mobility assuming the company's
`consumer‐oriented product lines (including its mobile phone business, as well as its cable modems and pay television set‐top boxes), while Motorola Solutions
`assuming the company's enterprise‐oriented product lines.
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`Source: https://en.wikipedia.org/wiki/Motorola_Mobility#Brand_licensing
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`Note: All internet sources last accessed and downloaded July 1, 2020.
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 5 of 17 PageID #:27
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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` Source: https://www.motorola.com/us/ (Annotation added)
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 6 of 17 PageID #:28
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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`Source: https://www.motorolastore.com/baby‐monitors/video‐monitoring
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`Note: All internet sources last accessed and downloaded July 1, 2020.
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 7 of 17 PageID #:29
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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`Source: https://www.motorolastore.com/baby‐monitors/video‐monitoring
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`Note: All internet sources last accessed and downloaded July 1, 2020.
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 8 of 17 PageID #:30
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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`Source: https://www.motorolastore.com/baby‐monitors/video‐monitoring
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`Note: All internet sources last accessed and downloaded July 1, 2020.
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 9 of 17 PageID #:31
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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`Source: https://www.motorolastore.com/baby‐monitors/video‐monitoring
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`Note: All internet sources last accessed and downloaded July 1, 2020.
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`Claim US Patent
`9,191,629
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`1. A video‐enabled
`baby monitoring
`system which
`includes at least
`two separate units
`comprising:
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`Indep.
`Cl. 1
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`1‐p
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 10 of 17 PageID #:32
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
`
`Description of the Infringement
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`The Motorola MBP36XL “Video Baby Monitor” (A video‐enabled baby monitoring system) includes a “Portable, Rechargeable
`Camera” and an “Ergonomic Parent Unit with 5‐Inch Diagonal Color Screen” (at least two separate units).
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`Source: https://www.motorolastore.com/baby‐monitors/video‐monitoring/motorola‐mbp36xl.html (emphasis added).
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`Source: https://www.motorolastore.com/baby‐monitors/video‐monitoring/motorola‐mbp36xl.html (emphasis added).
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`Note: All internet sources last accessed and downloaded July 1, 2020.
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 11 of 17 PageID #:33
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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`Description of the Infringement
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`The Motorola MBP36XL “Baby Unit” (transmitter unit) includes a “Camera Lens” (camera feature which captures motion), a
`“Microphone” (sound sensor which captures sound) and “Infrared LEDs (x8, for night vision)” (an infrared light source capable of
`providing sufficient light for imaging when necessary).
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`Source: MBP36XL User’s Guide, p. 5 (emphasis and annotation added)
`https://assets.ctfassets.net/0dyo76hkwr49/1HQTKO5EJ20GOIsaUyOUuu/50fee8562ef0f9358197849199588d67/MBP36XL_IFU_
`US_EN_Version_2_170208.pdf
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`1‐a
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`Claim US Patent
`9,191,629
`a transmitter unit
`including a
`camera feature
`which captures
`motion,
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` a
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` sound sensor
`which captures
`sound, and
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`an infrared light
`source capable of
`providing
`sufficient light for
`imaging when
`necessary,
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`Note: All internet sources last accessed and downloaded July 1, 2020.
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 12 of 17 PageID #:34
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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`Description of the Infringement
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`The MBP36XL Baby Unit has a “Microprocessor” (transmitter unit also includes microprocessors) similar to the one shown in this
`picture of a MBP33SBU model.
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`Claim US Patent
`9,191,629
`wherein said
`transmitter unit
`also includes
`microprocessors
`which generate a
`series of video
`signal codes and
`audio signal codes
`which are
`transmitted at a
`specific radio
`frequency to a
`dedicated receiver
`unit; and
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`Source: Baby Unit internal of a MBP33SBU Baby Unit. (annotations added)
`https://www.ifixit.com/Guide/Motorola+MBP33SBU+Baby+Unit+Speaker+Replacement/99623
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`The microprocessor manages signals that allow the user to “clearly communicate with your partner or child using the two‐way
`communication feature. Take the portable, battery‐powered camera with you around the house to watch your little one”
`(generate a series of video signal codes and audio signal codes which are transmitted …. to a dedicated receiver unit).
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`Note: All internet sources last accessed and downloaded July 1, 2020.
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`Claim US Patent
`9,191,629
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 13 of 17 PageID #:35
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
`
`Description of the Infringement
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`The transmission occurs over the “2.4 GHz HFSS” frequency band (at a specific radio frequency).
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`Source: https://www.motorolastore.com/baby‐monitors/video‐monitoring/motorola‐mbp36xl.html (emphasis added).
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 14 of 17 PageID #:36
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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`Description of the Infringement
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`The Motorola MBP36XL “Parent Unit” (receiver unit) includes a “Display (LCD screen)” (display screen).
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`Source: MBP36XL User’s Guide, p. 3 (emphasis and annotation added)
`https://assets.ctfassets.net/0dyo76hkwr49/1HQTKO5EJ20GOIsaUyOUuu/50fee8562ef0f9358197849199588d67/MBP36XL_IFU_
`US_EN_Version_2_170208.pdf
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`1‐b
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`Claim US Patent
`9,191,629
`a receiver unit
`including a display
`screen,
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 15 of 17 PageID #:37
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
`
`Description of the Infringement
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`The Motorola MBP36XL “Parent Unit” (receiver unit) allows the user to “clearly communicate with your partner or child using
`the two‐way communication feature. Take the portable, battery‐powered camera with you around the house to watch your
`little one” (receives said signal codes from said transmitter and provides a displayed image, in combination with corresponding
`sound). The Motorola MBP36XL “Parent Unit” allows the user to “Press VIDEO ON/OFF button to turn the LCD screen on or off,
`whilst still leaving the audio monitor on” (or provides the sound alone).
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`Source: https://www.motorolastore.com/baby‐monitors/video‐monitoring/motorola‐mbp36xl.html (emphasis added).
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`Claim US Patent
`9,191,629
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`where said
`receiver unit
`receives said
`signal codes from
`said transmitter
`and
`provides a
`displayed image,
`in combination
`with
`corresponding
`sound, or provides
`the sound alone,
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 16 of 17 PageID #:38
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
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`Description of the Infringement
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`Source: MBP36XL User’s Guide, p. 14 (emphasis and annotation added)
`https://assets.ctfassets.net/0dyo76hkwr49/1HQTKO5EJ20GOIsaUyOUuu/50fee8562ef0f9358197849199588d67/MBP36XL_IFU_
`US_EN_Version_2_170208.pdf
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`Claim US Patent
`9,191,629
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`Case: 1:20-cv-03872 Document #: 1-2 Filed: 07/01/20 Page 17 of 17 PageID #:39
`CLAIM CHARTS BASED ON PRELIMINARY INFRINGEMENT ANALYSIS
`U.S. Patent No. 9,191,629
`
`Description of the Infringement
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`The Motorola MBP36XL “Parent Unit” (receiver unit) provides a “Power Savings mode” by “select auto video off after
`5 mins, 30 mins or 60 mins if operating on batteries only.” In this mode, “The audio will stay on and you can press any key to
`switch the video back on” (video‐off button which enables a user to simultaneously turn off said display screen and to turn off
`said camera feature and said infrared light source of said transmitter remotely).
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`Claim US Patent
`9,191,629
`wherein said
`receiver unit
`includes a video‐
`off button which
`enables a user to
`simultaneously
`turn off said
`display screen and
`to turn off said
`camera feature
`and said infrared
`light source of
`said transmitter
`remotely.
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`Source: MBP36XL User’s Guide, p. 19 (emphasis and annotation added)
`https://assets.ctfassets.net/0dyo76hkwr49/1HQTKO5EJ20GOIsaUyOUuu/50fee8562ef0f9358197849199588d67/MBP36XL_IFU_
`US_EN_Version_2_170208.pdf
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`Caveat: The notes and/or cited excerpts utilized herein are set forth for illustrative purposes only and are not meant to be limiting in any manner. For example,
`the notes and/or cited excerpts, may or may not be supplemented or substituted with different excerpt(s) of the relevant reference(s), as appropriate. Further,
`to the extent any error(s) and/or omission(s) exist herein, all rights are reserved to correct the same.
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`Note: All internet sources last accessed and downloaded July 1, 2020.
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