FEDEX’S INFRINGEMENT OF U.S. PATENT NO. 7,199,715
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`FedEx directly infringes U.S. Patent No. 7,199,715 (the “’715 patent”) in violation of 35 U.S.C. § 271(a) because FedEx has
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`used and continues to use the ’715 patented invention, within the United States, without authority. FedEx uses the ’715 patented
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`invention to infringe at least claim 1 at least as described in the chart below.
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`’715 Patent Claim
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`Claim 1
`1. A method of tracking tags
`at several successive points
`of a business process, said
`method comprising:
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`Elements In The Accused Instrumentalities
`(exemplified by GENCO’s Warehouse Management Services using RFID Technology)
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`FedEx tracks tags at several successive points of a business process.
`As one non-limiting example, defendant GENCO, a FedEx Corporation subsidiary, tracks tags at
`several successive points of a business process.
`GENCO specializes in high-volume serialized fulfillment of cell phones, computers, GPS devices,
`gaming systems, cable boxes, and other technology products.
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`(http://www.genco.com/Technology/tech-warehousing-distribution.php (highlighting added).)
`As part of its Warehousing capabilities and in order to keep track of its inventory, GENCO tracks tags,
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`Attachment C - page 1
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`FedEx Exhibit 1007
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`FedEx directly infringes U.S. Patent No. 7,199,715 (the “’715 patent”) in violation of 35 U.S.C. § 271(a) because FedEx has
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`used and continues to use the ’715 patented invention, within the United States, without authority. FedEx uses the ’715 patented
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`invention to infringe at least claim 1 at least as described in the chart below.
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`’715 Patent Claim
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`Claim 1
`1. A method of tracking tags
`at several successive points
`of a business process, said
`method comprising:
`
`Elements In The Accused Instrumentalities
`(exemplified by GENCO’s Warehouse Management Services using RFID Technology)
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`FedEx tracks tags at several successive points of a business process.
`As one non-limiting example, defendant GENCO, a FedEx Corporation subsidiary, tracks tags at
`several successive points of a business process.
`GENCO specializes in high-volume serialized fulfillment of cell phones, computers, GPS devices,
`gaming systems, cable boxes, and other technology products.
`
`(http://www.genco.com/Technology/tech-warehousing-distribution.php (highlighting added).)
`As part of its Warehousing capabilities and in order to keep track of its inventory, GENCO tracks tags,
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`Attachment C - page 1
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`FedEx Exhibit 1007
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`’715 Patent Claim
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`Elements In The Accused Instrumentalities
`(exemplified by GENCO’s Warehouse Management Services using RFID Technology)
`including at least RFID tags, at several successive points of a business process (e.g., warehousing,
`distribution, logistics, reverse logistics).
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`(http://www.genco.com/Technology/tech-warehousing-distribution.php (highlighting added).)
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`(http://www.genco.com/pdfs/Innovations_RFID.pdf at 1.)
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`Attachment C - page 2
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`’715 Patent Claim
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`Elements In The Accused Instrumentalities
`(exemplified by GENCO’s Warehouse Management Services using RFID Technology)
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`(http://www.genco.com/Distribution/wms.php (highlighting added).)
`GENCO uses 4 types of warehouse management systems:
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`Attachment C - page 3
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`’715 Patent Claim
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`Elements In The Accused Instrumentalities
`(exemplified by GENCO’s Warehouse Management Services using RFID Technology)
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`((http://www.genco.com/Distribution/wms.) All of those 4 systems use or have the capability of
`integrating RFID technology to track RFID tags at several successive points in time.
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`attempting to read each tag
`at each successive point;
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`FedEx attempts to read each tag at each successive point.
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`As one non-limiting example, GENCO attempts to read each tag (an RFID tag) at each successive
`point.
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`Attachment C - page 4
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`’715 Patent Claim
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`Elements In The Accused Instrumentalities
`(exemplified by GENCO’s Warehouse Management Services using RFID Technology)
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`(http://www.genco.com/Distribution/wms.php)
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`(http://www.genco.com/Logistics-Articles/article.php?aid=800742771 at 3.)
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`(http://www.genco.com/Coverage/docs/Distribution-Center-Management_140901.pdf at 3.)
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`Attachment C - page 5
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`’715 Patent Claim
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`Elements In The Accused Instrumentalities
`(exemplified by GENCO’s Warehouse Management Services using RFID Technology)
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`populating a database with
`information corresponding
`to the reading of each tag at
`each successive point and
`the time of each reading;
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`(http://www.genco.com/pdfs/Innovations_RFID.pdf at 1.)
`FedEx populates a database with information corresponding to the reading of each tag at each
`successive point and the time of each reading.
`As one non-limiting example, GENCO populates a database with information corresponding to the
`reading of each tag at each successive point (e.g., the identity of the tag/item) and the time of each
`reading (e.g., “arrival” time, load time, ).
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`(http://www.genco.com/Coverage/docs/Distribution-Center-Management_140901.pdf at 3 (highlighting
`added).)
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`Attachment C - page 6
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`’715 Patent Claim
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`Elements In The Accused Instrumentalities
`(exemplified by GENCO’s Warehouse Management Services using RFID Technology)
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`(http://www.genco.com/pdfs/Innovations_RFID.pdf (highlighting added).)
`GENCO tracks the products at various successive points along the supply chain:
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`Attachment C - page 7
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`’715 Patent Claim
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`Elements In The Accused Instrumentalities
`(exemplified by GENCO’s Warehouse Management Services using RFID Technology)
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`(http://www.genco.com/Logistics-Articles/article.php?aid=800379731).
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`modifying part of the
`information in the database
`as a function of the other
`information in the database;
`and
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`FedEx modifies part of the information in the database as a function of the other information in the
`database.
`As one non-limiting example, GENCO modifies part of the information in the database (e.g., contents
`of the pallet and location of specific products) as a function of the other information in the database
`(e.g., expected information concerning the contents of the pallet and specific products) through its
`validation process:
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`(http://www.genco.com/Logistics-Articles/article.php?aid=800742771 at 3 (highlighting added).)
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`Attachment C - page 8
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`’715 Patent Claim
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`Elements In The Accused Instrumentalities
`(exemplified by GENCO’s Warehouse Management Services using RFID Technology)
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`using the modified
`information to track the tags
`through the business
`process.
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`((http://www.genco.com/Coverage/docs/Distribution-Center-Management_140901.pdf at 3.)
`FedEx uses the modified information to track the tags through the business process.
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`As one non-limiting example, GENCO uses that verified data to track the RFID tags through the rest of
`the rest of the logistics process.
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`(http://www.genco.com/Coverage/docs/Distribution-Center-Management_140901.pdf at 3 (highlighting
`added).)
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`Attachment C - page 9
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`’715 Patent Claim
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`Elements In The Accused Instrumentalities
`(exemplified by GENCO’s Warehouse Management Services using RFID Technology)
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`(http://www.genco.com/Logistics-Articles/article.php?aid=800742771 at 2.)
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`Attachment C - page 10
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