IPR2021-01593, No. 1004-4 Exhibit - Exhibit 1004 (P.T.A.B. Oct. 1, 2021)

`
`
`
`
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`OPTICAL LICENSING, LLC,
`
`
`
`
`Case No. 6:21-cv-00186-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`Plaintiff
`
` v.
`
`ARROW ELECTRONICS,
`INC.,
`
`
`
`
`
`Defendants
`
`OPTICAL LICENSING, LLC’S DISCLOSURE OF
`PRELIMINARY INFRINGEMENT CONTENTIONS AND
`ACCOMPANYING DOCUMENT PRODUCTION
`
`Pursuant to the Court’s Scheduling Order, Plaintiff Optical Licensing, LLC
`
`(“Plaintiff”), hereby makes the following Disclosure of Asserted Claims, Infringement
`
`Contentions, and Accompanying Document Production to Defendant, Inc. (“Defendant”).
`
`These infringement contentions (“ICs”) are based on Plaintiff’s current
`
`interpretation of U.S. Patent No. 6,791,898 (the “’898 Patent”) (the “Patent-in-Suit”), and
`
`to the extent information describing Defendant’s sale and use of proprietary products,
`
`systems, and relationships is publicly available. Pursuant to the Scheduling Order,
`
`Plaintiff reserves the right to amend its ICs and asserted claims based on information
`
`Plaintiff obtains through discovery and otherwise as this case progresses. Plaintiff
`
`reserves the right to amend its infringement contentions responsive to claim construction
`
`proceedings and this Court’s claim construction rulings or rulings by other Courts’ in
`
`related cases. Plaintiff reserves the right to amend its infringement contentions and
`
`
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 1
`
`

`
`
`asserted claims based on any proceedings before the United States Patent and
`
`Trademark Office regarding Plaintiff’s patent.
`
`A.
`
`Identification of Infringed Claims
`
`The asserted claims of the Patent-in-Suit include those claims identified in the
`
`attached claim chart. Plaintiff identified these asserted claims based on its current and
`
`preliminary understanding and reserves the right to supplement its identification as
`
`discovery proceeds, including identifying additional claims. Plaintiff presently accuses
`
`Defendant of directly and indirectly infringing claim 7 of the ’898 Patent.
`
`B.
`
`Identification of Accused Products
`
`Based on the information currently available, Plaintiff identifies the following
`
`products, including all reasonably similar variants or improvements, as the accused
`
`products:
`
`• STMicroelectronics STM32L552ZET6 Microcontroller. The names and
`
`identification of specific devices and software to
`
`implement the
`
`STMicroelectronics STM32L552ZET6 Microcontroller are proprietary
`
`information of Defendant. Plaintiff will provide more
`
`identifying
`
`information once Defendant produces technical information regarding its
`
`systems and services.
`
`Plaintiff identifies these Accused Products based on its preliminary understanding
`
`of information currently available to Plaintiff (for more specificity, see attached claim
`
`chart). Plaintiff reserves the right to supplement its identification as discovery proceeds,
`
`including identifying additional Accused Products.
`
`PLAINTIFF’S DISCLOSURE OF PRELIMINARY INFRINGEMENT CONTENTIONS
`
`PAGE | 2
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 2
`
`

`
`
`C. Chart Identifying Accused Products
`
`Plaintiff provides the attached claim chart which identify where to find each
`
`element of each asserted claim based on the publicly available information to Plaintiff.
`
`These ICs serve a notice function and are not required to—and therefore do not—present
`
`every possible permutation or theory of Plaintiff’s case. These ICs focus on notice of the
`
`underlying direct infringement and are not provided to—and should not be read to—
`
`explain such issues as joint liability, mastermind, or indirect infringement.
`
`D. Literal Infringement and Infringement Under The Doctrine Of
`Equivalents
`
`Plaintiff presently contends that the Accused Products literally infringe the above-
`
`asserted claims of the ’898 Patent as more specifically explained in the attached claim
`
`chart. Further, Plaintiff asserts infringement under the doctrine of equivalents as
`
`identified in the attached claim chart, to the extent that the difference between any
`
`component of any product and any step of any service and any claim element is
`
`insubstantial.
`
`E. Patent Priority Dates
`
`Based upon the information currently available, Plaintiff discloses that the ’898
`
`Patent is entitled to a priority date of at least October 11, 2002.
`
`F.
`
`Document Production Accompanying Disclosure.
`
`Concurrently with service of its Preliminary Infringement Contentions, Plaintiff
`
`is producing documents evidencing conception and reduction to practice for each claimed
`
`invention and a copy of the file history for the ’898 Patent.
`
`
`
`PLAINTIFF’S DISCLOSURE OF PRELIMINARY INFRINGEMENT CONTENTIONS
`
`PAGE | 3
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 3
`
`

`
`
`Dated: June 30, 2021
`
`Respectfully Submitted
`
`
`
`/s/ Raymond W. Mort, III
`Raymond W. Mort, III
`Texas State Bar No. 00791308
`raymort@austinlaw.com
`
`THE MORT LAW FIRM, PLLC
`100 Congress Ave, Suite 2000
`Austin, Texas 78701
`Tel/Fax: (512) 865-7950
`
`ATTORNEYS FOR PLAINTIFF
`
`
`PLAINTIFF’S DISCLOSURE OF PRELIMINARY INFRINGEMENT CONTENTIONS
`
`PAGE | 4
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 4
`
`

`
`
`EXHIBIT A
`
`U.S. Patent No. 6,791,898
`
`Optical Licensing, LLC (“Plaintiff”) accuses Arrow Electronics, Inc. (“Defendant”) of directly infringing claims
`7 of U.S. Patent No. 6,791,898 (hereinafter the “’'898” Patent). Pursuant to the Court’s Scheduling Order, Plaintiff
`provides the following claim chart.
`
`Pursuant to the Court’s Scheduling Order, this claim chart provide Defendant notice of identified products that
`incorporates or reflects the recited claim elements. This claim chart is not intended to be an expert report on
`infringement or provide detailed analysis of the claim terms or infringement. Plaintiff will disclose and produce an
`expert report regarding infringement with appropriate analysis pursuant to the Court’s Scheduling Order. This chart
`includes select evidence of infringement by Defendant, including diagrams, web page screenshots, and other publicly
`available documentary evidence by way of example and not by way of limitation.
`
`Plaintiff reserves the right to revise these contentions, as appropriate, upon issuance of the Court’s Claim
`Construction Order, including the identification of whether any such differences between the accused
`instrumentalities and the claims are insubstantial and whether the accused instrumentality reads on the claim
`elements under the doctrine of equivalents.
`
`
`
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`
`
`1
`
`ARROW ELECTRONICS, INC.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 5
`
`

`
`
`Claim Language
`7. A memory device
`comprising:
`
`Accused Product
`The Accused Product is the STMicroelectronics STM32L552ZET6 microcontroller. Optical
`will identify additional products should it discover other versions of the STMicroelectronics
`STM32L552ZET6 microcontroller sold, used, imported, or offered for sale by Defendant.
`The Accused Product satisfies the claimed memory device.
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`2
`
`ARROW ELECTRONICS, INC.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 6
`
`

`
`
`Claim Language
`an array of memory cells
`for storing data;
`
`Accused Product
`The Accused Product includes memory banks.
`
`
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`
`The Accused Product’s memory banks satisfy as the claimed array of memory cells for
`storing data.
`The Accused Product includes a Flexible Static Memory Controller (“FSMC” or “FMC”).
`
`an
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`3
`
`ARROW ELECTRONICS, INC.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 7
`
`

`
`
`Claim Language
`asynchronous/synchron
`ous logic coupled to a
`plurality
`of
`control
`signals and said array of
`memory cells, wherein
`asynchronous
`transfer
`of data stored in said
`array of memory cells is
`provided based upon a
`first state of said control
`signals and wherein
`synchronous transfer of
`data stored in said array
`of memory
`cells
`is
`provided based upon a
`second state of said
`control signals; and
`
`Accused Product
`
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`The FMC interfaces with synchronous and asynchronous static memories.
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`4
`
`ARROW ELECTRONICS, INC.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 8
`
`

`
`
`Claim Language
`
`Accused Product
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`Multiple control signals are used to drive asynchronous and synchronous transfer of data.
`The Accused Product’s FMC satisfies the claimed asynchronous/synchronous logic coupled
`to a plurality of control signals and said array of memory cells, wherein asynchronous
`transfer of data stored in said array of memory cells is provided based upon a first state of
`said control signals and wherein synchronous transfer of data stored in said array of
`memory cells is provided based upon a second state of said control signals.
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`5
`
`ARROW ELECTRONICS, INC.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 9
`
`

`
`
`Claim Language
`
`Accused Product
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`The Accused Product includes configuration registers which can allow the controllers of
`the FMC to be configured.
`
`
`A configuration register
`coupled
`to
`said
`asynchronous/synchron
`ous logic, wherein said
`first state of said control
`signals or said second
`state of said control
`signals is latched for
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`6
`
`ARROW ELECTRONICS, INC.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 10
`
`

`
`
`Claim Language
`access
`by
`said
`asynchronous/synchron
`ous logic.
`
`Accused Product
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`7
`
`
`
`ARROW ELECTRONICS, INC.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 11
`
`

`
`
`Claim Language
`
`Accused Product
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`8
`
`ARROW ELECTRONICS, INC.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 12
`
`

`
`
`Claim Language
`
`Accused Product
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`The Accused Product’s configuration registers satisfy the claimed configuration register
`coupled to said asynchronous/synchronous logic, wherein said first state of said control
`signals or said second state of said control signals is latched for access by said
`asynchronous/synchronous logic.
`
`
`
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`9
`
`ARROW ELECTRONICS, INC.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 13
`
`

`
`
`
`
`
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`OPTICAL LICENSING, LLC,
`
`
`
`
`Case No. 6:21-cv-00188-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`Plaintiff
`
` v.
`
`FUTURE ELECTRONICS
`CORP.,
`
`
`
`
`
`Defendants
`
`OPTICAL LICENSING, LLC’S DISCLOSURE OF
`PRELIMINARY INFRINGEMENT CONTENTIONS AND
`ACCOMPANYING DOCUMENT PRODUCTION
`
`Pursuant to the Court’s Scheduling Order, Plaintiff Optical Licensing, LLC
`
`(“Plaintiff”), hereby makes the following Disclosure of Asserted Claims, Infringement
`
`Contentions, and Accompanying Document Production to Defendant, Inc. (“Defendant”).
`
`These infringement contentions (“ICs”) are based on Plaintiff’s current
`
`interpretation of U.S. Patent No. 6,791,898 (the “’898 Patent”) (the “Patent-in-Suit”), and
`
`to the extent information describing Defendant’s sale and use of proprietary products,
`
`systems, and relationships is publicly available. Pursuant to the Scheduling Order,
`
`Plaintiff reserves the right to amend its ICs and asserted claims based on information
`
`Plaintiff obtains through discovery and otherwise as this case progresses. Plaintiff
`
`reserves the right to amend its infringement contentions responsive to claim construction
`
`proceedings and this Court’s claim construction rulings or rulings by other Courts’ in
`
`related cases. Plaintiff reserves the right to amend its infringement contentions and
`
`
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 14
`
`

`
`
`asserted claims based on any proceedings before the United States Patent and
`
`Trademark Office regarding Plaintiff’s patent.
`
`A.
`
`Identification of Infringed Claims
`
`The asserted claims of the Patent-in-Suit include those claims identified in the
`
`attached claim chart. Plaintiff identified these asserted claims based on its current and
`
`preliminary understanding and reserves the right to supplement its identification as
`
`discovery proceeds, including identifying additional claims. Plaintiff presently accuses
`
`Defendant of directly and indirectly infringing claim 7 of the ’898 Patent.
`
`B.
`
`Identification of Accused Products
`
`Based on the information currently available, Plaintiff identifies the following
`
`products, including all reasonably similar variants or improvements, as the accused
`
`products:
`
` STMicroelectronics STM32L552VET6 Microcontroller. The names and
`
`identification of specific devices and software to
`
`implement the
`
`STMicroelectronics STM32L552VET6 Microcontroller are proprietary
`
`information of Defendant. Plaintiff will provide more
`
`identifying
`
`information once Defendant produces technical information regarding its
`
`systems and services.
`
`Plaintiff identifies these Accused Products based on its preliminary understanding
`
`of information currently available to Plaintiff (for more specificity, see attached claim
`
`chart). Plaintiff reserves the right to supplement its identification as discovery proceeds,
`
`including identifying additional Accused Products.
`
`PLAINTIFF’S DISCLOSURE OF PRELIMINARY INFRINGEMENT CONTENTIONS
`
`PAGE | 2
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 15
`
`

`
`
`EXHIBIT A
`
`U.S. Patent No. 6,791,898
`
`Optical Licensing, LLC (“Plaintiff”) accuses Future Electronics Corp. (“Defendant”) of directly infringing claim
`7 of U.S. Patent No. 6,791,898 (hereinafter the “’'898” Patent). Pursuant to the Court’s Scheduling Order, Plaintiff
`provides the following claim chart.
`
`Pursuant to the Court’s Scheduling Order, this claim chart provide Defendant notice of identified products that
`incorporates or reflects the recited claim elements. This claim chart is not intended to be an expert report on
`infringement or provide detailed analysis of the claim terms or infringement. Plaintiff will disclose and produce an
`expert report regarding infringement with appropriate analysis pursuant to the Court’s Scheduling Order. This chart
`includes select evidence of infringement by Defendant, including diagrams, web page screenshots, and other publicly
`available documentary evidence by way of example and not by way of limitation.
`
`Plaintiff reserves the right to revise these contentions, as appropriate, upon issuance of the Court’s Claim
`Construction Order, including the identification of whether any such differences between the accused
`instrumentalities and the claims are insubstantial and whether the accused instrumentality reads on the claim
`elements under the doctrine of equivalents.
`
`
`
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`
`
`1
`
`FUTURE ELECTRONICS CORP.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 18
`
`

`Claim Language
`7. A memory device
`comprising:
`
`Accused Product
`The Accused Product is the STMicroelectronics STM32L552VET6 microcontroller. Optical
`will identify additional products should it discover other versions of the STMicroelectronics
`STM32L552VET6 microcontroller sold, used, imported, or offered for sale by Defendant.
`The Accused Product satisfies the claimed memory device.
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`2
`
`FUTURE ELECTRONICS CORP.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 19
`
`

`Claim Language
`an array of memory cells
`for storing data;
`
`Accused Product
`The Accused Product includes memory banks.
`
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`
`
`The Accused Product’s memory banks satisfy as the claimed array of memory cells for
`storing data.
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`3
`
`FUTURE ELECTRONICS CORP.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 20
`
`

`Claim Language
`
`an
`asynchronous/synchron
`ous logic coupled to a
`plurality
`of
`control
`signals and said array of
`memory cells, wherein
`asynchronous
`transfer
`of data stored in said
`array of memory cells is
`provided based upon a
`first state of said control
`signals and wherein
`synchronous transfer of
`data stored in said array
`of memory
`cells
`is
`provided based upon a
`second state of said
`control signals; and
`
`Accused Product
`The Accused Product includes a Flexible Static Memory Controller (“FSMC” or “FMC”).
`
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`
`
`
`
`
`
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`4
`
`FUTURE ELECTRONICS CORP.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 21
`
`

`Claim Language
`
`Accused Product
`
`The FMC interfaces with synchronous and asynchronous static memories.
`
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`
`
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`5
`
`FUTURE ELECTRONICS CORP.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 22
`
`

`Claim Language
`
`Accused Product
`
`
`Multiple control signals are used to drive asynchronous and synchronous transfer of data.
`The Accused Product’s FMC satisfies the claimed asynchronous/synchronous logic coupled
`to a plurality of control signals and said array of memory cells, wherein asynchronous
`transfer of data stored in said array of memory cells is provided based upon a first state of
`said control signals and wherein synchronous transfer of data stored in said array of
`memory cells is provided based upon a second state of said control signals.
`
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`6
`
`FUTURE ELECTRONICS CORP.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 23
`
`

`Claim Language
`
`Accused Product
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`A configuration register
`coupled
`to
`said
`asynchronous/synchron
`ous logic, wherein said
`first state of said control
`signals or said second
`state of said control
`signals is latched for
`access
`by
`said
`asynchronous/synchron
`ous logic.
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`The Accused Product includes configuration registers which can allow the controllers of
`the FMC to be configured.
`
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`
`
`
`
`
`
`
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`7
`
`FUTURE ELECTRONICS CORP.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 24
`
`

`Claim Language
`
`Accused Product
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`
`
`
`
`
`
`
`
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`8
`
`FUTURE ELECTRONICS CORP.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 25
`
`

`Claim Language
`
`Accused Product
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`
`
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`9
`
`FUTURE ELECTRONICS CORP.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 26
`
`

`Claim Language
`
`Accused Product
`
`https://www.st.com/resource/en/reference_manual/dm00346336-stm32l552xx-and-stm32l562xx-
`
`advanced-arm-based-32-bit-mcus-stmicroelectronics.pdf
`
`
`
`
`
`
`
`
`
`
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`10
`
`FUTURE ELECTRONICS CORP.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 27
`
`

`Claim Language
`
`Accused Product
`The Accused Product’s configuration registers satisfy the claimed configuration register
`coupled to said asynchronous/synchronous logic, wherein said first state of said control
`signals or said second state of said control signals is latched for access by said
`asynchronous/synchronous logic.
`
`
`
`
`
`
`PRELIMINARY INFRINGEMENT CONTENTIONS
`U.S. PATENT NO. 6,791,898
`
`
`11
`
`FUTURE ELECTRONICS CORP.
`
`STMicroelectronics, Inc., Ex. 1004
`IPR2021-01593
`Page 28
`
`

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