U.S. Patent No. 10,341,811 (“’811 Patent”)
`
`Accused Instrumentalities
`Samsung products, including without limitation Galaxy SmartTag devices, including, but not limited to the SmartTag,
`SmartTag+, and all variations or iterations thereof; Galaxy Tab tablet devices, including, but not limited to the S9, S9+, S9 Ultra, S8,
`S8+, S8 Ultra, S6 Lite 2022, S7 FE, S6 Lite, S6 5G, S7+ 5G, S7+, S7 5G, S7,S5e, S6, S4, S3, and all variations or iterations thereof;
`Galaxy mobile phone devices, including, but not limited to the S8, S8+, S8 Active, S9, S9+, S10, S10+, S10 5G, S10 Lite, S10e, S20,
`S20+, S20+ BTS Edition, S20 Ultra, S20 FE, S20, S21, S21+, S21 Ultra, S21 FE, S22, S22+, S22 Ultra, S23, S23+, S23 Ultra, Z Fold
`5, Z Fold 4, Z Fold 3, Z Fold 2, Fold, Z Flip 5, Z Flip 4, Z Flip 3, Z Flip, A3, A5, A6, A6+, A7, A8, A8+, A8 Star, A9, A2 Core,
`A10e, A10, A10s, A20, A20s, A30, A30s, A40, A40s, A50, A50s, A60, A70, A70s, A80, A90, A01 Core, A01, A11, A21, A21s, A31,
`A41, A51, A71, A51 5G, A71 5G, A52s 5G, A73 5G, A23 5G, A02, A02s, A12, A22, A22 5G, A32, A32 5G, A42 5G, A52, A52 5G,
`A52s 5G, A72, A03 Core, A03, A03s, A13, A13 5G, A23, A23 5G, A33 5G, A53 5G, A73 5G, A04e, A04, A04s, A14, A14 5G,
`A24, A34 5G, A54 5G, Note 8, Note 9, Note 10, Note 10+, Note 10 Lite, Note 20, Note 20 Ultra, and all variations or iterations
`thereof (“Accused Products”), infringe at least Claims 1, 4, 5, 15, 18, 19, 24, 25, and 28 of the ’811 Patent.
`Each Accused Product infringes the claims in substantially the same way, and the evidence shown in this chart is similarly
`applicable to each Accused Product. Each claim limitation is literally infringed by each Accused Product. However, to the extent any
`claim limitation is not met literally, it is nonetheless met under the doctrine of equivalents because the differences between the claim
`limitation and each Accused Product would be insubstantial, and each Accused Product performs substantially the same function, in
`substantially the same way, to achieve the same result as the claimed invention. Notably, Samsung has not yet articulated which, if
`any, particular claim limitations it believes are not met by the Accused Products.
`
`Claim 1
`
`Claim 1
`
`[1pre] 1. A method of
`determining whether a portable
`RF communications device is
`present at a device-specific
`target location, the method
`comprising:
`
`Accused Products
`
`To the extent the preamble is limiting, each Accused Product performs a method of determining
`whether a portable RF communications device is present at a device-specific target location, the
`method comprising.
`
`For example, the Galaxy S22 contains both cellular and WiFi radios, and associated antennas,
`which are used to determine the geographic location of the phone as described below.
`
`See, e.g.:
`
`
`
`1
`
`Page 1 of 66
`
`SAMSUNG EX-1025
`
`

`

`Claim 1
`
`Accused Products
`
`https://www.gsmarena.com/samsung_galaxy_s22_5g-11253.php
`
`
`
`
`
`2
`
`Page 2 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`
`
`
`
`
`
`
`
`https://www.gsmarena.com/samsung_galaxy_s22_5g-11253.php
`
`
`
`3
`
`Page 3 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`https://findmymobile.samsung.com/
`
`https://www.samsung.com/us/support/owners/app/find-my-mobile
`
`
`
`4
`
`
`
`
`
`
`
`Page 4 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`
`
`5
`
`Page 5 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`
`
`6
`
`Page 6 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`[1a] with the portable RF
`communications device
`automatically:
`
`Each Accused Product performs a method with the portable RF communications device
`automatically performing the claimed steps.
`
`
`
`
`7
`
`Page 7 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`See claim elements below.
`
`[1b] (a) receiving a first
`plurality of communications
`signals, each received from
`one of a first plurality of
`antenna stations within range
`of the portable RF
`communications device,
`wherein the antenna stations
`are fixed-location service-area
`antenna stations and are
`substantially continuously
`operating;
`
`Each Accused Product performs receiving a first plurality of communications signals, each
`received from one of a first plurality of antenna stations within range of the portable RF
`communications device, wherein the antenna stations are fixed-location service-area antenna
`stations and are substantially continuously operating.
`
`For example, the Galaxy S22 receives communication signals from a plurality of Wi-Fi network
`stations and/or a plurality of mobile network stations, each of which is generally in a fixed
`location and operating continuously (Wi-Fi access point, cell phone tower, etc.).
`
`See, e.g.:
`
`https://findmymobile.samsung.com/
`
`
`
`
`
`8
`
`Page 8 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`https://www.samsung.com/us/support/owners/app/find-my-mobile
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`9
`
`
`
`
`
`
`
`Page 9 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`
`
`10
`
`Page 10 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`[1c] (b) causing a
`determination of whether the
`portable RF communications
`
`Each Accused Product performs causing a determination of whether the portable RF
`communications device is within proximity of the device-specific target location by electronically
`comparing at least one number based on signal strengths of each of the first plurality of
`
`
`
`11
`
`Page 11 of 66
`
`

`

`Claim 1
`
`device is within proximity of
`the device-specific target
`location by electronically
`comparing at least one number
`based on signal strengths of
`each of the first plurality of
`communications signals with
`at least one number based on
`corresponding signal strengths
`of each of a second plurality of
`communication signals from a
`second plurality of antenna
`stations that have been
`identified as being within
`range of the same location as
`the device-specific target
`location, which signal
`strengths have been
`determined for the same
`location as the device-specific
`target location; and
`
`Accused Products
`
`communications signals with at least one number based on corresponding signal strengths of each
`of a second plurality of communication signals from a second plurality of antenna stations that
`have been identified as being within range of the same location as the device-specific target
`location, which signal strengths have been determined for the same location as the device-specific
`target location.
`
`For example, using the Samsung Reminder app included with the Galaxy S22, a user can specify a
`device-specific target location by creating a location-based reminder. This functionality uses the
`Google Location Services functionality, as shown by the necessity of providing Location
`permissions to the Reminder app. The phone then uses signal strength and other network
`information from nearby Wi-Fi and/or mobile communications signals, based on antennas
`identified as being within range of the specified location, to determine whether or not the phone is
`in the same location as the device-specific target location. Similar reminders can also be created
`through Samsung’s Bixby service.
`
`For another example, Samsung SmartTag products use Bluetooth to communicate with mobile
`phones in its proximity, which will scan and find lost items attached with the SmartTag based on
`Bluetooth device ID and received signal strength. Even when the Samsung SmartTag is out of the
`proximity of its owner’s mobile phone, it can still broadcast Bluetooth beacons that will
`potentially be captured by anybody’s mobile phone that is nearby, which will relay the beacon to
`Samsung’s Find Network in order to be discovered by its owner. Samsung SmartTag+ product
`further uses UWB to communicate with mobile phones, such as Samsung Galaxy S22 Plus, in its
`proximity, which will use more precise ranging technology with UWB to get cm level accuracy
`and step-by-step guide to lead to the tag.
`
`For another example, Samsung’s SmartThings Find, Search Nearby, and/or Find My systems,
`when used on a Galaxy S22 or other Samsung Accused Product, enable locating, and navigating to
`the location of, a user’s SmartTag, SmartThings, and/or Android devices. On information and
`belief, these processes use the same or similar techniques as described in other Samsung and
`Google documentation, including comparing numbers based on signal strengths in order to
`determine if the Accused Product is within proximity of the target location.
`
`
`
`12
`
`
`
`Page 12 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`See, e.g.:
`
`
`Screenshot from Samsung Reminder app showing that the app uses Google Services based
`location determination.
`
`
`
`13
`
`Page 13 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`
`Screenshot from Samsung Reminder app showing selection of device-specific location for
`notification.
`
`
`
`14
`
`Page 14 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`https://www.samsung.com/global/galaxy/apps/bixby/reminder/
`
`
`
`
`
`15
`
`Page 15 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`
`
`16
`
`Page 16 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`In a press release this evening, Samsung announced that the SmartThings Find network has effectively doubled
`in size over the last year, with 200 million “find nodes” out in the wild. A “find node” is a Galaxy smartphone or
`
`
`
`17
`
`Page 17 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`tablet that is registered to use SmartThings Find and can relay the location of a Galaxy SmartTag to the tag’s
`owner.
`
`https://9to5google.com/2022/07/13/samsung-smartthings-find-users/
`
`
`The Samsung ecosystem runs more and more like a well-oiled machine with each update from the
`company. Now, the tech giant is announcing that it's expanded its SmartThings Find network by
`over 100 million nodes in since July 2022, adding up to over 300 million in total.
`
`Source: https://www.zdnet.com/article/samsung-expands-smartthings-find-network-to-over-300-
`million-nodes/, May 4, 2023
`
`
`
`18
`
`Page 18 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`
`
`
`
`
`
`19
`
`Page 19 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`
`
`https://manuals.plus/samsung/galaxy-smarttagsmarttag-manual#axzz7g8yWgeln
`
`
`
`Searching for the SmartTag location by signal strength
`
`
`You can find the SmartTag’s location by detecting its signal strength.
`
`1. Launch the SmartThings app on your mobile device.
`2. Tap SmartThings Find Search nearby. The signal screen of the SmartTag you are looking for will
`appear. The closer you are to the location of the SmartTag you are looking for, the stronger the
`signal strength indicated on the screen will be.
`
`https://manuals.plus/samsung/galaxy-smarttagsmarttag-manual#axzz7g8yWgeln
`
`
`
`
`
`20
`
`Page 20 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`Source: https://www.samsung.com/us/mobile-accessories/galaxy-smarttag-black-ei-t5300bbegus/
`
`
`
`
`
`
`
`21
`
`Page 21 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`Source: https://www.samsung.com/us/mobile-accessories/galaxy-smarttag-black-ei-t5300bbegus/
`
`
`
`
`
`
`
`22
`
`Page 22 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`Source: https://www.samsung.com/us/mobile-accessories/galaxy-smarttag-plus-black-1-pack-ei-
`t7300bbegus/
`
`
`
`
`
`Ultra-wideband (UWB) communication
`
`Ultra-wideband communication is a radio technology focused on precise ranging (measuring the
`location to an accuracy of 10 cm) between devices. This radio technology can use a low-energy
`density for short range measurements and perform high-bandwidth signaling over a large portion
`
`
`
`23
`
`Page 23 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`of the radio spectrum. UWB’s bandwidth is greater than 500 MHz (or exceeding 20% fractional
`bandwidth).
`
`UWB-enabled mobile devices
`
`As of April 2023, these devices support the Android UWB Jetpack library:
`
`Vendor Device Model
`
`Google Pixel 6 Pro, Pixel 7 Pro
`
`Samsung
`
`Galaxy Note 20, S21+, S22+, Z Fold 2, 3, 4
`
`https://developer.android.com/guide/topics/connectivity/uwb
`
`Source: https://www.gsmarena.com/samsung_galaxy_s22_ultra_5g-11251.php
`
`
`
`24
`
`
`
`
`
`Page 24 of 66
`
`

`

`Claim 1
`
`[1d] (c) as a result of the
`determination that the portable
`RF communications device is
`within proximity of the device-
`specific target location,
`initiating, on the portable RF
`communications device, a
`location-based action
`associated with the device-
`specific target location.
`
`Accused Products
`
`Each Accused Product performs as a result of the determination that the portable RF
`communications device is within proximity of the device-specific target location, initiating, on the
`portable RF communications device, a location-based action associated with the device-specific
`target location.
`
`For example, each Accused Product will take a predetermined action, such as displaying a
`notification, ending navigation, or performing a location-specific action, when it is determined
`that the device is within proximity of the target location.
`
`For another example, Any Android based mobile device can call a generic geofencing API to
`detect and notify any applications whenever the device enters the vicinity of a defined location.
`
`See, e.g.:
`
`
`
`25
`
`Page 25 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`
`Screenshot of notification (at top) from Samsung Reminder app upon arriving at the
`predetermined location
`
`See also, e.g., evidence and explanation above and below.
`
`
`
`26
`
`Page 26 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`Source: https://smartthingsfind.samsung.com/login
`
`
`
`
`
`Sometimes users want to use a particular app when they are in a specific type of location, such as
`an airport, or a supermarket. However, users have to navigate to that app and then take a specific
`action within it while they are near the area of interest.
`
`The geofencing API allows you to define perimeters, also referred to as geofences, which
`surround the areas of interest. Your app gets a notification when the device crosses a geofence,
`which allows you to provide a useful experience when users are in the vicinity.
`
`
`
`27
`
`Page 27 of 66
`
`

`

`Claim 1
`
`Accused Products
`
`Claim 4
`
`Claim 4
`
`4. The method of claim 1
`wherein the location-based
`action comprises launching a
`computer program application
`on the portable RF
`communications device.
`
`Source: https://developers.google.com/location-context/geofencing/
`
`
`
`Accused Products
`
`Each Accused Product performs the method of claim 1 wherein the location-based action
`comprises launching a computer program application on the portable RF communications device.
`
`For example, the Samsung Reminder app allows a user to specify a location while creating a
`location-based reminder. The phone then uses signal strength and other network information from
`nearby Wi-Fi and/or mobile communications signals, based on antennas identified as being within
`range of the specified location, to determine whether the phone is arriving or leaving the location
`chosen by the user. Based on this determination, the phone launches the Samsung Reminder app.
`
`For another example, any Android based mobile device can call a generic geofencing API to
`detect and notify applications, including launching applications as appropriate, when the device
`enters the vicinity of a defined location.
`
`
`
`28
`
`Page 28 of 66
`
`

`

`Claim 4
`
`Accused Products
`
`
`See, e.g.:
`
`
`
`
`Screenshot showing, at top, notification from Samsung Reminder app that the phone arriving at
`the location as specified by the user.
`
`Claim 5
`
`Claim 5
`
`5. The method of claim 1
`wherein part (b) is performed
`depending on the rate of
`change of the user's location.
`
`Accused Products
`
`Each Accused Product performs the method of claim 1 wherein part (b) is performed depending
`on the rate of change of the user's location.
`
`For example, each Accused Product’s location settings can be configured, by the user or an
`application, to update location based on the user’s speed (rate of change of location).
`
`
`
`29
`
`Page 29 of 66
`
`

`

`Claim 5
`
`Accused Products
`
`See, e.g.:
`
`If your app needs to request location or receive permission updates, the device needs to enable the
`appropriate system settings, such as GPS or Wi-Fi scanning. Rather than directly enabling services
`such as the device's GPS, your app specifies the required level of accuracy/power consumption
`and desired update interval, and the device automatically makes the appropriate changes to system
`settings. These settings are defined by the LocationRequest data object.
`
`Update interval
`
`setInterval() - This method sets the rate in milliseconds at which your app prefers to receive
`location updates. Note that the location updates may be somewhat faster or slower than this rate to
`optimize for battery usage, or there may be no updates at all (if the device has no connectivity, for
`example).
`
`Source: https://developer.android.com/training/location/change-location-settings
`
`Starting updates based on the user’s activity state. Example: Requesting updates only when the
`user is driving or riding a bike. Use the Activity Recognition API in conjunction with fused
`location provider updates. Request updates when the targeted activity is detected, and remove
`updates when the user stops performing that activity.
`
`Source: https://developer.android.com/guide/topics/location/battery
`
`Claim 14
`
`Claim 14
`
`14. The method of claim 1
`wherein the determination of
`whether the portable RF
`communications device is
`within proximity of the device-
`specific target location is
`
`
`
`Accused Products
`
`Each Accused Product performs the method of claim 1 wherein the determination of whether the
`portable RF communications device is within proximity of the device-specific target location is
`performed at a location remote from the portable RF communications device.
`
`For example, in one alternative implementation all or part of the geolocation determination is
`performed by a remote API. For a further example, the Galaxy Find Network can make
`
`30
`
`Page 30 of 66
`
`

`

`Claim 14
`
`performed at a location remote
`from the portable RF
`communications device.
`
`determinations while the device is offline, indicating that the determination is made at a remote
`location.
`
`Accused Products
`
`See, e.g.:
`
`The Geolocation API is a service that accepts an HTTPS request with the cell tower and WiFi
`access points that a mobile client can detect.
`
`Source: https://developers.google.com/maps/documentation/geolocation/overview
`
`
`
`Google Maps Platform web services are an interface for requesting Maps API data from external
`services and using the data within your Maps applications. These services are designed to be used
`in conjunction with a map, as per the License Restrictions in the Google Maps Platform Terms of
`Service. Geolocation requests are sent using POST to the following URL:
`
`https://www.googleapis.com/geolocation/v1/geolocate?key=YOUR_API_KEY
`
`Source: https://developers.google.com/maps/documentation/geolocation/web-service-best-
`practices
`
`
`
`31
`
`Page 31 of 66
`
`

`

`Claim 14
`
`Accused Products
`
`Source: https://www.samsung.com/us/mobile-accessories/galaxy-smarttag-black-ei-t5300bbegus/
`
`https://smartthingsfind.samsung.com/login
`
`
`
`
`
`32
`
`Page 32 of 66
`
`

`

`Claim 15
`
`Claim 15
`
`[15pre]. A portable RF
`communications device
`comprising an antenna, a user
`interface, and a storage device,
`wherein the storage device
`contains computer program
`code that, when executed by
`the portable device, controls
`the portable device to cause
`the portable device to perform
`a location-determining
`method, the method
`comprising automatically:
`
`Accused Products
`
`To the extent the preamble is limiting, each Accused Product includes a portable RF
`communications device comprising an antenna, a user interface, and a storage device, wherein the
`storage device contains computer program code that, when executed by the portable device,
`controls the portable device to cause the portable device to perform a location-determining
`method, the method comprising automatically.
`
`For example, the Galaxy S22 contains both cellular and WiFi radios, and associated antennas,
`which are used to determine the geographic location of the phone as described below.
`
`Furthermore, the Galaxy S22 contains a touchscreen user interface.
`
`Furthermore, the Galaxy S22 contains one or more storage device, including a NAND Flash
`memory chip, that contains the Android operating system, the Samsung One UI system, and
`additional software that performs the location determining method described below.
`
`See, e.g.:
`
`
`
`33
`
`Page 33 of 66
`
`

`

`Claim 15
`
`Accused Products
`
`https://www.gsmarena.com/samsung_galaxy_s22_5g-11253.php
`
`
`
`
`
`34
`
`Page 34 of 66
`
`

`

`Claim 15
`
`Accused Products
`
`
`
`
`
`
`
`
`
`https://www.gsmarena.com/samsung_galaxy_s22_5g-11253.php
`
`
`
`35
`
`Page 35 of 66
`
`

`

`Claim 15
`
`Accused Products
`
`https://findmymobile.samsung.com/
`
`https://www.samsung.com/us/support/owners/app/find-my-mobile
`
`
`
`36
`
`
`
`
`
`
`
`Page 36 of 66
`
`

`

`Claim 15
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`
`
`37
`
`Page 37 of 66
`
`

`

`Claim 15
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`
`
`38
`
`Page 38 of 66
`
`

`

`Claim 15
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`[15a] (a) receiving a first
`plurality of communications
`signals, each received from
`
`The computer program code in each Accused Product performs a method comprising
`automatically receiving a first plurality of communications signals, each received from one of a
`first plurality of antenna stations within range of the portable RF communications device, wherein
`
`
`
`39
`
`Page 39 of 66
`
`

`

`Claim 15
`
`one of a first plurality of
`antenna stations within range
`of the portable RF
`communications device,
`wherein the antenna stations
`are fixed-location service-area
`antenna stations and are
`substantially continuously
`operating;
`
`Accused Products
`
`the antenna stations are fixed-location service-area antenna stations and are substantially
`continuously operating.
`
`For example, the Galaxy S22 receives communication signals from a plurality of Wi-Fi network
`stations and/or a plurality of mobile network stations, each of which is generally in a fixed
`location and operating continuously (Wi-Fi access point, cell phone tower, etc.).
`
`See, e.g.:
`
`https://findmymobile.samsung.com/
`
`
`
`
`
`
`
`https://www.samsung.com/us/support/owners/app/find-my-mobile
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`
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`Claim 15
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`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
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`Claim 15
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`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
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`Claim 15
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`[15b] (b) causing a
`determination of whether the
`portable RF communications
`
`The computer program code in each Accused Product performs a method comprising
`automatically causing a determination of whether the portable RF communications device is
`within proximity of the device-specific target location by electronically comparing at least one
`
`
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`Claim 15
`
`device is within proximity of
`the device-specific target
`location by electronically
`comparing at least one number
`based on signal strengths of
`each of the first plurality of
`communications signals with
`at least one number based on
`corresponding signal strengths
`of each of a second plurality of
`communication signals from a
`second plurality of antenna
`stations that have been
`identified as being within
`range of the same location as
`the device-specific target
`location, which signal
`strengths have been
`determined for the same
`location as the device-specific
`target location; and
`
`Accused Products
`
`number based on signal strengths of each of the first plurality of communications signals with at
`least one number based on corresponding signal strengths of each of a second plurality of
`communication signals from a second plurality of antenna stations that have been identified as
`being within range of the same location as the device-specific target location, which signal
`strengths have been determined for the same location as the device-specific target location.
`
`For example, using the Samsung Reminder app included with the Galaxy S22, a user can specify a
`device-specific target location by creating a location-based reminder. This functionality uses the
`Google Location Services functionality, as shown by the necessity of providing Location
`permissions to the Reminder app. The phone then uses signal strength and other network
`information from nearby Wi-Fi and/or mobile communications signals, based on antennas
`identified as being within range of the specified location, to determine whether or not the phone is
`in the same location as the device-specific target location. Similar reminders can also be created
`through Samsung’s Bixby service.
`
`For another example, Samsung SmartTag products use Bluetooth to communicate with mobile
`phones in its proximity, which will scan and find lost items attached with the SmartTag based on
`Bluetooth device ID and received signal strength. Even when the Samsung SmartTag is out of the
`proximity of its owner’s mobile phone, it can still broadcast Bluetooth beacons that will
`potentially be captured by anybody’s mobile phone that is nearby, which will relay the beacon to
`Samsung’s Find Network in order to be discovered by its owner. Samsung SmartTag+ product
`further uses UWB to communicate with mobile phones, such as Samsung Galaxy S22 Plus, in its
`proximity, which will use more precise ranging technology with UWB to get cm level accuracy
`and step-by-step guide to lead to the tag.
`
`For another example, Samsung’s SmartThings Find, Search Nearby, and/or Find My systems,
`when used on a Galaxy S22 or other Samsung Accused Product, enable locating, and navigating to
`the location of, a user’s SmartTag, SmartThings, and/or Android devices. On information and
`belief, these processes use the same or similar techniques as described in other Samsung and
`Google documentation, including comparing numbers based on signal strengths in order to
`determine if the Accused Product is within proximity of the target location.
`
`
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`Claim 15
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`Accused Products
`
`See, e.g.:
`
`
`Screenshot from Samsung Reminder app showing that the app uses Google Services based
`location determination.
`
`
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`Claim 15
`
`Accused Products
`
`
`Screenshot from Samsung Reminder app showing selection of device-specific location for
`notification.
`
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`Claim 15
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`Accused Products
`
`https://www.samsung.com/global/galaxy/apps/bixby/reminder/
`
`
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`Claim 15
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`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
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`Claim 15
`
`Accused Products
`
`https://policies.google.com/technologies/location-data?hl=en-US
`
`
`
`In a press release this evening, Samsung announced that the SmartThings Find network has effectively doubled
`in size over the last year, with 200 million “find nodes” out in the wild. A “find node” is a Galaxy smartphone or
`
`
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`Accused Products
`
`tablet that is registered to use SmartThings Find and can relay the location of a Galaxy SmartTag to the tag’s
`owner.
`
`https://9to5google.com/2022/07/13/samsung-smartthings-find-users/
`
`
`The Samsung ecosystem runs more and more like a well-oiled machine with each update from the
`company. Now, the tech giant is announcing that it's expanded its SmartThings Find network by
`over 100 million nodes in since July 2022, adding up to over 300 million in total.
`
`Source: https://www.zdnet.com/article/samsung-expands-smartthings-find-network-to-over-300-
`million-nodes/, May 4, 2023
`
`
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`Accused Products
`
`
`
`
`
`
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`Claim 15
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`Accused Products
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`
`
`https://manuals.plus/samsung/galaxy-smarttagsmarttag-manual#axzz7g8yWgeln
`
`
`
`Searching for the SmartTag location by signal strength
`
`
`You can find the SmartTag’s location by detecting its signal strength.
`
`3. Launch the SmartThings app on your mobile device.
`4. Tap SmartThings Find Search nearby. The signal screen of the SmartTag you are looking for will
`appear. The closer you are to the location of the SmartTag you are looking for, the stronger the
`signal strength indicated on the screen will be.
`
`https://manuals.plus/samsung/galaxy-smarttagsmarttag-manual#axzz7g8yWgeln
`
`
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`Claim 15
`
`Accused Products
`
`Source: https://www.samsung.com/us/mobile-accessories/galaxy-smarttag-black-ei-t5300bbegus/
`
`
`
`
`
`
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`Claim 15
`
`Accused Products
`
`Source: https://www.samsung.com/us/mobile-accessories/galaxy-smarttag-black-ei-t5300bbegus/
`
`
`
`
`
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`Claim 15
`
`Accused Products
`
`Source: https://www.samsung.com/us/mobile-accessories/galaxy-smarttag-plus-black-1-pack-ei-
`t7300bbegus/
`
`
`
`
`
`Ultra-wideband (UWB) communication
`
`Ultra-wideband communication is a radio technology focused on precise ranging (measuring the
`location to an accuracy of 10 cm) between devices. This radio technology can use a low-energy
`density for short range measurements and perform high-bandwidth signaling over a large portion
`
`
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`Claim 15
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`Accused Products
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`of the radio spectrum. UWB’s bandwidth is greater than 500 MHz (or exceeding 20% fractional
`bandwidth).
`
`UWB-enabled mobile devices
`
`As of April 2023, these devices support the Android UWB Jetpack library:
`
`Vendor Device Model
`
`Google Pixel 6 Pro, Pixel 7 Pro
`
`Samsung
`
`Galaxy Note 20, S21+, S22+, Z Fold 2, 3, 4
`
`https://developer.android.com/guide/topics/connectivity/uwb
`
`Source: https://www.gsmarena.com/samsung_galaxy_s22_ultra_5g-11251.php
`
`
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`Claim 15
`
`[15c] (c) as a result of the
`determination that the portable
`RF communications device is
`within proximity of the device-
`specific target location,
`initiating, on the portable RF
`communications device, a
`location-based action
`associated with the device-
`specific target location.
`
`Accused Products
`
`The computer program code in each Accused Product performs a method comprising
`automatically, as a result of the determination that the portable RF communications device is
`within proximity of the device-specific target location, initiating, on the portable RF
`communications device, a location-based action associated with the device-specific target
`location.
`
`For example, each Accused Product will take a predetermined action, such as displaying a
`notification, ending navigation, or performing a location-specific action, when it is determined
`that the device is within proximity of the target location.
`
`For another example, Any Android based mobile device can call a generic geofencing API to
`detect and notify any applications whenever the device enters the vicinity of a defined location.
`
`See, e.g.:
`
`
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`Claim 15
`
`Accused Products
`
`
`Screenshot of notification (at top) from Samsung Reminder app upon arriving at the
`predetermined location
`
`See also, e.g., evidence and explanation above and below.
`
`
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`Claim 15
`
`Accused Products
`
`Source: https://smartthingsfind.samsung.com/login
`
`
`
`
`
`Sometimes users want to use a particular app when they are in a specific type of location, such as
`an airport, or a supermarket. However, users have to navigate to that app and then take a specific
`action within it while they are near the area of interest.
`
`The geofencing API allows you to define perimeters, also referred to as geofences, which
`surround the areas of interest. Your app gets a notification when the device crosses a geofence,
`which allows you to provide a useful experience when users are in the vicinity.
`
`
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`Claim 15
`
`Accused Products
`
`Source: https://developers.google.com/location-context/geofencing/
`
`
`
`Claim 18
`
`Claim 18
`
`18. The portable RF
`communications device of
`claim 15 wherein the location-
`based action comprises
`launching a computer program
`applica