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`Exhibit D
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`Claim Chart re Asserted Claims of ’635 Patent and
`Exemplary Bell+Howell Accused Products
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`Case 1:20-cv-07573-VSB Document 1-4 Filed 09/15/20 Page 2 of 7
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`Preliminary Comparison of the Bell+Howell B35HDZ with U.S. Patent No. 6,914,635
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`Claim language
`1. A digital camera system comprising:
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`Information Relating to the Bell+Howell B35HDz
`The Bell+Howell B35HDZ is a digital camera system.
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`http://bellhowellcameras.com/product.php?id=137
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`The Bell+Howell B35HDZ includes a lens assembly mounted for receiving an image and projecting
`said image on an image plane.
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`a lens assembly mounted for receiving
`an image and projecting said image on
`an image plane;
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`1
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`Case 1:20-cv-07573-VSB Document 1-4 Filed 09/15/20 Page 3 of 7
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`Preliminary Comparison of the Bell+Howell B35HDZ with U.S. Patent No. 6,914,635
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`Bell+Howell B35HDZ User Manual at 9.
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`2
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`Case 1:20-cv-07573-VSB Document 1-4 Filed 09/15/20 Page 4 of 7
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`Preliminary Comparison of the Bell+Howell B35HDZ with U.S. Patent No. 6,914,635
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`Bell+Howell B35HDZ User Manual at 9.
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`Bell+Howell B35HDZ User Manual at 86.
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`Bell+Howell B35HDZ User Manual at 86.
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`3
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`Case 1:20-cv-07573-VSB Document 1-4 Filed 09/15/20 Page 5 of 7
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`Preliminary Comparison of the Bell+Howell B35HDZ with U.S. Patent No. 6,914,635
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`http://bellhowellcameras.com/product.php?id=137
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`http://bellhowellcameras.com/product.php?id=137
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`4
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`Case 1:20-cv-07573-VSB Document 1-4 Filed 09/15/20 Page 6 of 7
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`Preliminary Comparison of the Bell+Howell B35HDZ with U.S. Patent No. 6,914,635
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`Upon information and belief, the Bell+Howell B35HDZ includes a micro-electromechanical (MEMS)
`system support mechanism for providing at least two positions of movement to a supported
`element.
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`a micro-electromechanical (MEMS)
`system support mechanism for
`providing at least two positions of
`movement to a supported element, said
`MEMS support mechanism being
`fabricated integrally with said supported
`element; and
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`http://bellhowellcameras.com/product.php?id=137
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`5
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`Case 1:20-cv-07573-VSB Document 1-4 Filed 09/15/20 Page 7 of 7
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`Preliminary Comparison of the Bell+Howell B35HDZ with U.S. Patent No. 6,914,635
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`http://bellhowellcameras.com/product.php?id=137
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`a semi-conductor image sensor
`mounted at said image plane for
`movement on said MEMS system
`support mechanism and being
`operatively associated with said lens
`assembly to generate a digital image.
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`Bell+Howell B35HDZ User Manual at 56.
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`Upon information and belief, the Bell+Howell B35HDZ includes a semi-conductor image sensor.
`Upon information and belief, said semi-conductor image sensor is mounted at said image plane for
`movement on said MEMS system support mechanism and being operatively associated with said lens
`assembly to generate a digital image.
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`Bell+Howell B35HDZ User Manual at 86.
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`6
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