Appendix 5
`Ultravision’s Claim Chart for U.S. Patent No. 9,916,782 v. Samsung VMR-O Series
`In these infringement contentions, Ultravision contends that at least the claims of U.S. Patent
`No. 9,916,782 (“the ’782 patent”) identified below are infringed by Samsung’s VMR-O Series
`LED displays,1,2,3 including:
`
` VM029R-O;4 and
`
` VM039R-O.5
`
`Ultravision does not concede that any claims of the ’782 patent that are not listed below are not
`infringed by the identified products. Moreover, the citations to certain documents and other
`information below are intended to be exemplary only and in no way foreclose Ultravision from
`citing or relying on additional documents, information, and/or testimony at a later time. These
`contentions are preliminary in nature, and an analysis of Samsung’s products, internal
`documentation, and/or testimony from relevant witnesses may more fully and accurately describe
`the infringing features of its accused products. Accordingly, Ultravision reserves the right to
`supplement, correct, modify, and/or amend these contentions once such additional information is
`made available to Ultravision. Furthermore, Ultravision reserves the right to supplement, correct,
`modify, and/or amend these contentions as discovery in this case progresses; in view of the
`Court’s claim construction order(s); in view of any positions taken by Samsung, including but
`not limited to positions on claim construction, invalidity, and/or noninfringement; and in
`connection with the preparation and exchange of expert reports.
`
`Claim
`1. A modular display panel
`comprising:
`
`Support
`The preamble of this claim does not limit the scope of the
`claimed invention.
`The Samsung VMR-O Series LED displays are modular
`display panels.
`
`1 https://displaysolutions.samsung.com/pdf/datasheet/3753/SMART-LED-Signage_VMR-
`O_Datasheet_190319_web.pdf.
`2 https://displaysolutions.samsung.com/pdf/manual/3802/VMR-
`O_P3.9_Product_Manual_20190326.pdf.
`3 https://displaysolutions.samsung.com/pdf/drawing/3809/VMR-I_VMR-O_drawing.pdf.
`4 https://displaysolutions.samsung.com/led-signage/detail/1416/VM029R-O.
`5 https://displaysolutions.samsung.com/led-signage/detail/1417/VM039R-O.
`
`Samsung Exhibit 1009
`Samsung Elecs. Co., Ltd. v. Ultravision Techns., LLC
`IPR2020-01354
`Page 00001
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`

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`Claim
`Support
`Claim
`Support
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` E<tn
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`uz=m
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`IPR2020-01354 Page 00002
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`IPR2020-01354 Page 00002
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`Claim
`Support
`Claim
`Support
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`IPR2020-01354 Page 00003
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`IPR2020-01354 Page 00003
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`Claim
`Support
`Claim
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`semlze
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`Cahlekess
`man
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` nunm a rear
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`IPR2020-01354 Page 00004
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`IPR2020-01354 Page 00004
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`Claim
`
`Support
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`
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`1[a] a shell comprising a first
`thermally conductive material,
`wherein sidewalls of the shell
`comprise plastic;
`
`
`The Samsung VMR-O Series LED displays comprise a first
`thermally conductive material, wherein sidewalls of the shell
`comprise plastic.
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`5
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`IPR2020-01354 Page 00005
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`

`

`Claim
`
`Support
`
`
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`plastic
`shells
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`plastic
`shells
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`plastic
`sidewall
`
`
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`plastic
`shells
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`1[b] a printed circuit board
`disposed in the shell;
`
`
`The Samsung VMR-O Series LED displays comprise a
`printed circuit board disposed in the shell. The Samsung
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`6
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`IPR2020-01354 Page 00006
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`

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`Claim
`
`Support
`VMR-O Series LED display includes LEDS, which are
`attached to a PCB in the shell.
`
`LEDs on
`PCB in
`shell
`
`
`
`
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`1[c] a plurality of LEDs
`attached to a first side of the
`printed circuit board;
`
`The Samsung VMR-O Series LED displays comprise a
`plurality of LEDs attached to a first side of the printed circuit
`board.
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`7
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`IPR2020-01354 Page 00007
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`

`

`Claim
`
`Support
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`LEDs on
`PCB in
`shell
`
`
`
`
`
`1[d] a driver circuit disposed
`in the shell and coupled to the
`plurality of LEDs from a
`second side of the printed
`circuit board;
`
`The Samsung VMR-O Series LED displays comprise a
`driver circuit disposed in the shell and coupled to the
`plurality of LEDs from a second side of the printed circuit
`board.
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`8
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`IPR2020-01354 Page 00008
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`

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`Claim
`
`Support
`
`1[e] a power supply unit for
`powering the LEDs, the
`printed circuit board being
`disposed between the power
`supply unit and the plurality of
`LEDs;
`
`The Samsung VMR-O Series LED displays comprise a
`power supply unit for powering the LEDs, the printed circuit
`board being disposed between the power supply unit and the
`plurality of LEDs.
`
`
`
`on information and
`belief, control box
`includes a power
`supply unit for power
`the LEDs
`
`
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`9
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`IPR2020-01354 Page 00009
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`

`

`Claim
`
`Support
`
`
`
`
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`1[f] a second thermally
`conductive material disposed
`between the power supply unit
`and an outer back side of the
`panel; and
`
`The Samsung VMR-O Series LED displays comprise a
`second thermally conductive material disposed between the
`power supply unit and an outer back side of the panel.
`
`10
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`IPR2020-01354 Page 00010
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`

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`Claim
`
`Support
`
`on information and
`belief, power supply
`unit (inside) is in a
`metal cage
`
`
`
`
`
`
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`1[g] a protective structure
`disposed over the first side of
`
`The Samsung VMR-O Series LED displays comprise a
`protective structure disposed over the first side of the printed
`
`11
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`IPR2020-01354 Page 00011
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`

`

`Claim
`the printed circuit board,
`wherein the modular display
`panel is sealed to be
`waterproof.
`
`Support
`circuit board, wherein the modular display panel is sealed to
`be waterproof.
`
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`12
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`IPR2020-01354 Page 00012
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`Claim
`
`Support
`
`on information and belief, a
`protective structure (e.g., potting
`material) is disposed over the PCB
`
`louvers
`
`
`
`
`
`3. The panel of claim 1,
`wherein the first thermally
`conductive material and the
`second thermally conductive
`material are different
`materials.
`
`The first thermally conductive material and the second
`thermally conductive material of the Samsung VMR-O
`Series LED displays are different materials. The first
`thermally conductive material is plastic. See claim element
`1[a]. The second thermally conductive material is metal. See
`claim element 1[f].
`
`4. The panel of claim 1,
`wherein the protective
`structure comprises a potting
`material overlying the printed
`circuit board.
`
`The protective structure of the Samsung VMR-O Series LED
`displays comprises a potting material overlying the printed
`circuit board. See claim element 1[g].
`
`5. The panel of claim 1,
`
`The protective structure of the Samsung VMR-O Series LED
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`13
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`IPR2020-01354 Page 00013
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`

`

`Claim
`wherein the protective
`structure comprises louvers for
`deflecting water from the
`printed circuit board.
`
`6. The panel of claim 1,
`wherein the modular display
`panel comprises an ingress
`protection (IP) rating of IP 65,
`IP 66, IP 67, or IP 68.
`
`9. The panel of claim 1,
`wherein the first thermally
`conductive material comprises
`plastic.
`
`10. The panel of claim 1,
`wherein the power supply unit
`comprises a power converter
`for converting ac power to dc
`power.
`
`Support
`displays comprises louvers for deflecting water from the
`printed circuit board. See claim element 1[g].
`
`The Samsung VMR-O Series LED displays comprise an
`ingress protection (IP) rating of IP 65, IP 66, IP 67, or IP 68.
`See claim element 1[g].
`
`The first thermally conductive material of the Samsung
`VMR-O Series LED displays comprises plastic. See claim
`element 1[a].
`
`The power supply unit of the Samsung VMR-O Series LED
`displays comprises a power converter for converting ac
`power to dc power.
`
`on information and
`belief, power supply
`unit (inside)
`comprises a power
`converter for
`converting AC power
`to DC power
`
`
`The power supply unit of the Samsung VMR-O Series LED
`displays comprises a down converter that down converts a dc
`voltage at a first level to a dc voltage at a second level that is
`lower than the first level.
`
`11. The panel of claim 1,
`wherein the power supply unit
`comprises a down converter
`that down converts a dc
`voltage at a first level to a dc
`voltage at a second level that is
`lower than the first level.
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`14
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`IPR2020-01354 Page 00014
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`

`

`Claim
`
`Support
`
`on information and
`belief, power supply
`unit (inside)
`comprises a down
`converter that down
`converts a DC voltage
`to a lower DC voltage
`
`12. The panel of claim 1,
`wherein the shell comprises
`attachment points for use in
`attachment as part of a multi-
`panel modular display.
`
`The shell of the Samsung VMR-O Series LED displays
`comprises attachment points for use in attachment as part of
`a multi-panel modular display.
`
`
`
`13. The panel of claim 1,
`wherein the power supply unit
`is disposed in a Faraday cage.
`
`
`The power supply unit of the Samsung VMR-O Series LED
`displays is disposed in a Faraday cage.
`
`15
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`IPR2020-01354 Page 00015
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`

`

`Claim
`
`Support
`
`on information and
`belief, power supply
`unit (inside) is in a
`metal Faraday cage
`
`
`
`
`
`16. The panel of claim 1,
`wherein the panel has a height
`
`
`The panel of the Samsung VMR-O Series LED displays has
`a height and a width, wherein a ratio of the height to the
`
`16
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`IPR2020-01354 Page 00016
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`

`

`Claim
`and a width, and wherein a
`ratio of the height to the width
`is 1:1 or 1:2.
`
`width is 1:1 or 1:2.
`.
`
`Support
`
`on information and
`belief, power supply
`unit (inside) is in a
`metal Faraday cage
`
`
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`
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`17
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`IPR2020-01354 Page 00017
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