IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`C.A. No. 6:24-cv-188-ADA
`
`JURY TRIAL DEMANDED
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`INTELLECTUAL VENTURES II LLC,
`
`Plaintiff,
`
`v.
`
`TESLA, INC.,
`
`Defendant.
`
`PLAINTIFF’S DISCLOSURE OF
`PRELIMINARY INFRINGEMENT CONTENTIONS
`
`Pursuant to the Joint Notice Regarding Preliminary Contentions (Dkt. 19) and P.R. 3-1 and
`
`3-2, Plaintiff Intellectual Ventures II LLC ( “Plaintiff” or “IV”), hereby provides its Initial
`
`Infringement Contentions to Defendant Tesla, Inc. (hereinafter, “Defendant” or “Tesla”) for U.S.
`
`Patent Nos. 7,336,805 (“the ’805 Patent”), 9,706,500 (“the ’500 Patent”), 10,292,138 (“the ’138
`
`Patent”), 10,952,153 (“the ’153 Patent”), 8,898,395 (“the ’395 Patent”), 10,136,416 (“the ’416
`
`Patent”), 7,916,180 (“the ’180 Patent”), 9,232,158 (“the ’158 Patent”), and 7,181,743 (“the ’743
`
`Patent”), 6,894,639 (“the ’639 Patent”), 11,206,670 (“the ’670 Patent”), 11,664,889 (“the ’889
`
`Patent”) (collectively, the “Asserted Patents” or “Patents-in-Suit”).
`
`IV makes this disclosure based on the information presently available to it. Discovery in this
`
`case has not started, and IV reserves its right to amend or supplement these disclosures as permitted
`
`by the Federal Rules of Civil Procedure, by the local rules of the Western District of Texas, and by
`
`order of the Court, including the Scheduling Conference Order.
`
`For each Asserted Patent, Plaintiff identifies the following Accused Instrumentalities of
`
`which it is currently aware. The identification of Accused Instrumentalities is based on Plaintiff’s
`
`research and analysis to date, without the benefit of discovery from the Defendant. Plaintiff
`
`reserves the right to add, delete, substitute or otherwise amend this list of Accused
`
`

`

`Instrumentalities based on discovery or other circumstances, in a manner consistent with the
`
`Federal Rules of Civil Procedures, local rules, and standing order.
`
`The Accused Instrumentalities include, without limitation, the following:
`
` The ’805 Patent. The Accused Instrumentalities include, without limitation, Tesla automotive
`vehicles that are equipped with Autopilot technology, and all past, current and future Tesla
`products that operate in the same or substantially similar manner as the specifically identified
`products and components, and all past, current and future Tesla products that have the same or
`substantially similar features as the specifically identified products and components. Exhibit
`1.
`
` The ’500 Patent. The Accused Instrumentalities include, without limitation, Tesla automotive
`vehicles that are equipped with Connectivity features, and all past, current and future Tesla
`products that operate in the same or substantially similar manner as the specifically identified
`products and components, and all past, current, and future Tesla products that have the same
`or substantially similar features as the specifically identified products and components. Exhibit
`2.
`
` The ’138 Patent. The Accused Instrumentalities include, without limitation, Tesla automotive
`vehicles that are equipped with Connectivity features and all past, current and future Tesla
`products that operate in the same or substantially similar manner as the specifically identified
`products and components, and all past, current and future Tesla products that have the same or
`substantially similar features as the specifically identified products and components. Exhibit
`3.
`
` The ’153 Patent. The Accused Instrumentalities include, without limitation, Tesla automotive
`vehicles that are equipped with Connectivity features, and all past, current, and future Tesla
`products that operate in the same or substantially similar manner as the specifically identified
`products and components, and all past, current and future Tesla products that have the same or
`substantially similar features as the specifically identified products and components. Exhibit
`4.
`
` The ’395 Patent. The Accused Instrumentalities include, without limitation, Tesla automotive
`vehicles that are equipped with a computer system that includes memory management features,
`and all past, current and future Tesla products that operate in the same or substantially similar
`manner as the specifically identified products and components, and all past, current and future
`Tesla products that have the same or substantially similar features as the specifically identified
`products and components. Exhibit 5.
`
` The ’416 Patent. The Accused Instrumentalities include, without limitation, Tesla automotive
`vehicles that are equipped with Connectivity features, and all past, current and future Tesla
`products that operate in the same or substantially similar manner as the specifically identified
`products and components, and all past, current and future Tesla products that have the same or
`substantially similar features as the specifically identified products and components. Exhibit
`6.
`
`2
`
`

`

` The ’180 Patent. The Accused Instrumentalities include, without limitation, Tesla automotive
`vehicles that are equipped with Autopilot technology, and all past, current and future Tesla
`products that operate in the same or substantially similar manner as the specifically identified
`products and components, and all past, current, and future Tesla products that have the same
`or substantially similar features as the specifically identified products and components. Exhibit
`7.
`
` The ’158 Patent. The Accused Instrumentalities include, without limitation, Tesla automotive
`vehicles that are equipped with Autopilot technology, and all past, current and future Tesla
`products that operate in the same or substantially similar manner as the specifically identified
`products and components, and all past, current and future Tesla products that have the same or
`substantially similar features as the specifically identified products and components. Exhibit
`8.
`
` The ’743 Patent. The Accused Instrumentalities include, without limitation, Tesla
`infrastructure for supporting Tesla automotive vehicles, and all past, current and future Tesla
`products that operate in the same or substantially similar manner as the specifically identified
`products and components, and all past, current and future Tesla products that have the same or
`substantially similar features as the specifically identified products and components. Exhibit
`9.
`
` The ’639 Patent. The Accused Instrumentalities include, without limitation, Tesla automotive
`vehicles that are equipped with Autopilot technology, and all past, current and future Tesla
`products that operate in the same or substantially similar manner as the specifically identified
`products and components, and all past, current, and future Tesla products that have the same
`or substantially similar features as the specifically identified products and components. Exhibit
`10.
`
` The ’670 Patent. The Accused Instrumentalities include, without limitation, Tesla automotive
`vehicles that are equipped with Connectivity features, and all past, current and future Tesla
`products that operate in the same or substantially similar manner as the specifically identified
`products and components, and all past, current, and future Tesla products that have the same
`or substantially similar features as the specifically identified products and components. Exhibit
`11.
`
` The ’889 Patent. The Accused Instrumentalities include, without limitation, Tesla automotive
`vehicles that are equipped with Connectivity features, and all past, current and future Tesla
`products that operate in the same or substantially similar manner as the specifically identified
`products and components, and all past, current and future Tesla products that have the same or
`substantially similar features as the specifically identified products and components. Exhibit
`12.
`
` All past, current and future Tesla products and services that operate in the same or substantially
`
`similar manner as the specifically identified products and services above and described in
`
`3
`
`

`

`Exhibits 1-12 (claim charts identifying specifically where each element of each asserted claim
`
`is found within each Accused Instrumentality).
`
` All past, current and future Tesla products and services that have the same or substantially
`
`similar features as the specifically identified products and services above and described in
`
`Exhibits 1-12, (claim charts identifying specifically where each element of each asserted claim
`
`is found within each Accused Instrumentality).
`
`Plaintiff’s infringement contentions apply to the Accused Instrumentalities as well as all
`
`other past, current and future hardware and software products and services developed, made, used,
`
`offered for sale, sold, imported, and provided by Tesla that contain or make use of the Patented
`
`Technology.1 This identification of Accused Instrumentalities is based upon Plaintiff’s diligent
`
`investigation to date, and without the benefit of any discovery from the Defendant and without the
`
`benefit of the Court’s claim construction. Plaintiff expressly reserves the right to add, delete,
`
`substitute or otherwise amend this list of Accused Instrumentalities based on discovery, the Court’s
`
`claim construction, or other circumstances, in a manner consistent with the Federal Rules of Civil
`
`Procedure and the Court’s rule, including the local Patent Rules.
`
`These preliminary infringement contentions are based upon publicly-available information
`
`and Plaintiff’s diligent investigation to date, and without the benefit of any substantial discovery
`
`from the Defendant and without the benefit of the Court’s claim construction. Plaintiff anticipates
`
`that discovery may provide additional evidence of Defendant’s infringement, may lead to the
`
`discovery of additional instances of infringement, and may also enable identification of additional
`
`claims that are infringed by Defendant.
`
`1 “Patented Technology” means all technologies described in the claims of the Patents-in-Suit.
`4
`
`

`

`Based upon currently available information, IV asserts that Tesla has infringed and/or
`
`continues to infringe the patents and claims identified in the attached claim charts (the “Asserted
`
`Claims” of the Patents-in-Suit). Infringement claim charts evidencing the correspondence between
`
`(i) the elements of the Asserted Claims, and (ii) the corresponding items of the accused products
`
`are attached hereto. Further, Exhibits 1-12, which are attached hereto and incorporated by reference,
`
`are exemplary infringement claim charts identifying specifically where each limitation of each
`
`Asserted Claim is found within each Accused Instrumentality or practiced by each Accused
`
`Instrumentality.
`
`Plaintiff asserts that Defendant has directly infringed and continues to directly infringe the
`
`Asserted Claims literally through the Accused Instrumentalities by making, using, offering for sale,
`
`selling, and/or importing into the United States the Accused Instrumentalities. To the extent that
`
`Defendant alleges that one or more limitations of the Asserted Claims are not literally found in the
`
`Accused Instrumentalities, Plaintiff alleges that such limitations are found in or practiced by the
`
`Accused Instrumentalities under the doctrine of equivalents. Any differences alleged to exist
`
`between any of the Asserted Claims and any of the Accused Instrumentalities are insubstantial and
`
`that each Accused Instrumentality also meets each limitation under the doctrine of equivalents as
`
`the identified features of the Accused Instrumentality performs substantially the same function in
`
`substantially the same way to achieve substantially the same result as the corresponding claim
`
`limitation. IV reserves the right to assert infringement solely under the doctrine of equivalents with
`
`respect to any particular claim element(s), if warranted by discovery, further analysis, and/or claim
`
`constructions in this case.
`
`These assertions are based upon Plaintiff’s diligent investigation to date, and without the
`
`benefit of any substantial discovery from the Defendant and without the benefit of the Court’s
`
`claim construction. Plaintiff reserves the right to add, delete, substitute or otherwise amend these
`5
`
`

`

`infringement allegations based on discovery, the Court’s claim construction, or other
`
`circumstances, in a manner consistent with the Federal Rules of Civil Procedure and the Court’s
`
`rules, including the local Patent Rules.
`
`Plaintiff further asserts that Defendant has indirectly infringed and continues to indirectly
`
`infringe by actively inducing infringement of one or more of the claims of the Asserted Patents
`
`through the Accused Instrumentalities. Plaintiff further asserts that Defendant has indirectly
`
`infringed and continues to indirectly infringe by contributory infringement by (at least) providing
`
`replacement parts to Tesla vehicles and repair facilities by least making components that suitable
`
`for direct infringement that do not have any substantial non-infringing use.
`
`Plaintiff also asserts that these third-parties directly infringe at least one or more of the
`
`claims of the Asserted Patents through the manufacture, use, sale, offer to sell, or importation of
`
`the Accused Instrumentalities.
`
`For example, Defendant has actively induced infringement by encouraging the use of the
`
`Accused Instrumentalities in ways that infringe each Asserted Claim. Defendant knew or should
`
`have known that such encouragement would induce infringement. Defendant has taken active steps
`
`with the specific intent to encourage and cause others to use each Accused Instrumentality in ways
`
`that infringes each Asserted Claim. Such active steps by Defendant with specific intent to induce
`
`infringement have included, among other things, advertising, promoting, marketing, making
`
`available for use, offering to sell, and/or selling the Accused Instrumentalities to others;
`
`encouraging and influencing others to import, offer to sell, and/or sell the Accused
`
`Instrumentalities; directing and instructing others to use the Accused Instrumentalities in
`
`infringing ways, including providing and promoting the described hardware and/or software
`
`components and features that when used in their normal and customary ways as intended and
`
`design infringe; and by providing the Accused Instrumentalities to others. Tesla has performed the
`6
`
`

`

`aforementioned active steps with the knowledge of the Asserted Patents through receipt of a letter
`
`dated April 11, 2024 and received by Defendant on the same date, and also as of the date when the
`
`complaint in this case was filed. Tesla has known or should have known that the acts it has induced
`
`constitute infringement because, for instance, it has been aware that end users and resellers will
`
`purchase the Accused Instrumentalities and use them, resulting in direct infringement.
`
`IV further reserves the right to supplement or revise its infringement contentions and/or
`
`charts. Such supplement may be based upon, for example, further discovery. Further, IV reserves
`
`the right to supplement or revise its infringement contentions and/or chart, including identification
`
`of additional asserted claims, based on, for example, new versions or variations of one or more of
`
`the accused products that are later discovered.
`
`Each of the Asserted Claims of the ’805 Patent is entitled to a priority date of no later than
`
`June 16, 2004. Each of the Asserted Claims of the ’500 Patent is entitled to a priority date of no
`
`later than August 12, 2004. Each of the Asserted Claims of the ’138 Patent is entitled to a priority
`
`date of no later than May 8, 2006. Each of the Asserted Claims of the ’153 Patent is entitled to a
`
`priority date of no later than Aug. 12, 2004. Each of the Asserted Claims of the ’395 Patent is
`
`entitled to a priority date of no later than Apr. 7, 2005. Each of the Asserted Claims of the ’416
`
`Patent is entitled to a priority date of no later than September 27, 2007. Each of the Asserted Claims
`
`of the ’180 Patent is entitled to a priority date of no later than August 25, 2005. Each of the Asserted
`
`Claims of the ’158 Patent is entitled to a priority date of no later than August 25, 2005. Each of
`
`the Asserted Claims of the ’743 Patent is entitled to a priority date of no later than May 24, 2001.
`
`Each of the Asserted Claims of the ’639 Patent is entitled to a priority date of no later than
`
`December 18, 1991. Each of the Asserted Claims of the ’670 Patent is entitled to a priority date of
`
`no later than January 20, 2012. Each of the Asserted Claims of the ’889 Patent is entitled to a
`
`priority date of no later than December 27, 2006. The subject matter described by the Asserted
`7
`
`

`

`Claims, however, may have been conceived and reduced to practice prior to these dates. Plaintiff’s
`
`research and analysis is ongoing and Plaintiff reserves the right to assert that the claims are entitled
`
`to a priority date that is earlier than the above dates.
`
`Dated: August 1, 2024
`
`Respectfully submitted,
`
`By: /s/ Jonathan K. Waldrop
`Jonathan K. Waldrop (CA Bar No. 297903)
`(Admitted in this District)
`jwaldrop@kasowitz.com
`Darcy L. Jones (CA Bar No. 309474)
`(Admitted in this District)
`djones@kasowitz.com
`Marcus A. Barber (CA Bar No. 307361)
`(Admitted in this District)
`mbarber@kasowitz.com
`John W. Downing (CA Bar No. 252850)
`(Admitted in this District)
`jdowning@kasowitz.com
`Heather S. Kim (CA Bar No. 277686)
`(Admitted in this District)
`hkim@kasowitz.com
`ThucMinh Nguyen (CA Bar No. 304382)
`(Admitted in this District)
`tnguyen@kasowitz.com
`KASOWITZ BENSON TORRES LLP
`333 Twin Dolphin Drive, Suite 200
`Redwood Shores, California 94065
`Telephone: (650) 453-5170
`Facsimile: (650) 453-5171
`
`Mark D. Siegmund (TX Bar No. 24117055)
`msiegmund@cjsjlaw.com
`CHERRY JOHNSON SIEGMUND
`JAMES PLLC
`The Roosevelt Tower
`400 Austin Avenue, 9th Floor
`Waco, Texas 76701
`Telephone: (254) 732-2242
`
`Attorneys for Plaintiff
`INTELLECTUAL VENTURES II LLC
`
`8
`
`

`

`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing instrument was served or
`
`delivered electronically, via email, to all counsel of record, on this 1st day of August 2024.
`
`/s/ Jonathan K. Waldrop
`Jonathan K. Waldrop
`
`
`
`

`

`Preliminary Infringement Contentions
`
`Intellectual Ventures II LLC’s
`
`Exhibit 4 to
`
`

`

`2See, for example, www.tesla.com/ownersmanual, www.tesla.com/support (last accessed on July 31, 2024).
`1See, for example, https://www.tesla.com/support/connectivity (last accessed on April 10, 2024).
`
`2
`
`Tesla sells and/or offers for sale the Tesla Count VI Automobiles in the United States through its sales centers.
`County, Nevada; Buffalo, New York; Brooklyn Park, Minnesota; Elgin, Illinois; and Austin, Texas manufacturing facilities. Further,
`makes Tesla Count VI Automobiles, including at least in its Fremont, California; Lathrop, California; Grand Rapids, Michigan; Storey
`Tesla makes, uses, sells, offers for sale, and /or imports the Tesla Count VI Automobiles. For example, on information and belief, Tesla
`
`use.
`and repair facilities by least making components that suitable for direct infringement that do not have any substantial non-infringing
`vehicles in an infringing manner. Tesla also infringes via contributory infringement by providing replacement parts to Tesla vehicles
`inducing customers to use the Tesla vehicles and providing product manuals2 that provide instructions regarding how to use Tesla
`of equivalents. IV also contends that Tesla has indirectly infringed and continues to indirectly infringe by contributing to and actively
`IV contends that Tesla, including Tesla’s employees, directly infringes each of the Asserted Claims, either literally or under the doctrine
`
`extent allowed by the Court, including but not limited to, incorporating additional information, claims, theories, and / or accused products.
`begin and this case is still in its initial stages. Accordingly, IV reserves the right to amend and/or supplement these contentions to the full
`rights to pursue other accused instrumentalities, patent claims, evidence, and infringement arguments in this case. Discovery has yet to
`Plaintiff Intellectual Ventures II LLC (“IV” or “Plaintiff”) does not intend this exemplary claim chart to be limiting, and IV reserves its
`
`(“Count VI Automotive Vehicles” or “Tesla Automotive Vehicles”).
`future Tesla products that have the same or substantially similar features as the specifically identified products and components
`operate in the same or substantially similar manner as the specifically identified products and components, and all past, current and
`Second Generation, and Cybertruck) that are equipped with Connectivity features,1 and all past, current, and future Tesla products that
`The Accused Instrumentalities include, without limitation, Tesla automotive vehicles (e.g., Tesla Model X, S, 3, Y, Semi, Roadster
`
`U.S. Patent No. 10,952,153 (the “’153 Patent”)
`
`Infringement Claim Chart of
`
`

`

`3
`
`Source: https://www.tesla.com/ (last accessed on April 10, 2024).
`
`On information and belief, the Tesla Automotive Vehicles include a user equipment (UE).
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`comprising:
`equipment (UE)
`1. A user
`
`Claim 1
`
`

`

`4
`
`GL component that supports 4G LTE.
`For example, on information and belief, at least certain versions of the Tesla 3 include a Quectel AG525R-
`
`Source: https://www.tesla.com/support/connectivity (last accessed on April 10, 2024).
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`5
`
`Source: https://fcc.report/FCC-ID/XMR2020AG525RGL/5011285 (last accessed on April 10, 2024).
`
`904C71FAC59F.html (last accessed on April 10, 2024).
`Source: https://www.tesla.com/ownersmanual/model3/en_tw/GUID-1F854D6E-67FA-4262-BB76-
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`6
`
`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`Source: https://fcc.report/FCC-ID/XMR2020AG525RGL/5011285 (last accessed on April 10, 2024).
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`7
`
`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`8
`
`GL component that supports 4G LTE.
`For example, on information and belief, at least certain versions of the Tesla 3 include a Quectel AG525R-
`
`Source: https://www.tesla.com/support/connectivity (last accessed on April 10, 2024).
`
`On information and belief, the Tesla Automotive Vehicles include a transmitter.
`
`1[a] a transmitter;
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`9
`
`904C71FAC59F.html (last accessed on April 10, 2024).
`Source: https://www.tesla.com/ownersmanual/model3/en_tw/GUID-1F854D6E-67FA-4262-BB76-
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`10
`
`Source: https://fcc.report/FCC-ID/XMR2020AG525RGL/5011285 (last accessed on April 10, 2024).
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`11
`
`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`See 3GPP TS 36.213 V8.8.0 at 9.
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`12
`
`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`13
`
`GL component that supports 4G LTE.
`For example, on information and belief, at least certain versions of the Tesla 3 include a Quectel AG525R-
`
`Source: https://www.tesla.com/support/connectivity (last accessed on April 10, 2024).
`
`1[b] a receiver; and On information and belief, the Tesla Automotive Vehicles include a receiver.
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`14
`
`904C71FAC59F.html (last accessed on April 10, 2024).
`Source: https://www.tesla.com/ownersmanual/model3/en_tw/GUID-1F854D6E-67FA-4262-BB76-
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`15
`
`Source: https://fcc.report/FCC-ID/XMR2020AG525RGL/5011285 (last accessed on April 10, 2024).
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`16
`
`See 3GPP TS 36.300 V8.12.0 at Fig. 4.3.2-1.
`
`See 3GPP TS 36.300 V8.12.0 at 67.
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`17
`
`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`18
`
`GL component that includes a processor and supports 4G LTE.
`For example, on information and belief, at least certain versions of the Tesla 3 include a Quectel AG525R-
`
`Source: https://www.tesla.com/support/connectivity (last accessed on April 10, 2024).
`
`coupled to the transmitter and the receiver.
`On information and belief, the Tesla Automotive Vehicles include a processor operatively
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`and the receiver,
`to the transmitter
`operatively coupled
`1[c] a processor
`Claim 1
`
`

`

`19
`
`904C71FAC59F.html (last accessed on April 10, 2024).
`Source: https://www.tesla.com/ownersmanual/model3/en_tw/GUID-1F854D6E-67FA-4262-BB76-
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`20
`
`Source: https://fcc.report/FCC-ID/XMR2020AG525RGL/5011285 (last accessed on April 10, 2024).
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`21
`
`Source: https://fcc.report/FCC-ID/XMR2020AG525RGL/5011285 (last accessed on April 10, 2024).
`
`Source: https://fcc.report/FCC-ID/XMR2020AG525RGL/5011285 (last accessed on April 10, 2024).
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`22
`
`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`See 3GPP TS 36.300 V8.12.0 at Fig. 4.3.2-1.
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`23
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`commands is enabled or not.
`UplinkPowerControl information element containing an indication of whether accumulation of TPC
`accumulation is enabled. On information and belief, the Tesla Automotive Vehicles receive an
`the receiver to receive, from a network device, an indication that transmit power control (TPC) command
`On information and belief, the Tesla Automotive Vehicles include the processor that is configured to cause
`
`Source: https://predictabledesigns.com/whats-inside-a-smartphone/ (last accessed on April 10, 2024).
`
`network device, an
`to receive, from a
`cause: the receiver
`configured to
`processor is
`1[d] wherein the
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`24
`
`See 3GPP TS 36.331 V8.21.0 at 137.
`
`See 3GPP TS 36.331 V8.21.0 at 136.
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`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`enabled,
`accumulation is
`command
`control (TPC)
`transmit power
`indication that
`Claim 1
`
`

`

`25
`
`See 3GPP TS 36.213 V8.8.0 at 12.
`
`etc.) by which a TPC command can step up or step down the power level in the UE.
`receive a multi-level TPC command on the PDCCH. There are multiple levels (e.g., 1 dB, 3dB, -1 dB,
`and belief, the Tesla Automotive Vehicles, along with the information regarding uplink resources, also
`information and power control information that includes a multi-level TPC command. On information
`cause the receiver to receive, from the network device, on a single physical channel, scheduling
`On information and belief, the Tesla Automotive Vehicles include the processor that is configured to
`
`See 3GPP TS 36.300 V8.12.0 at Fig. 4.3.2-1.
`
`command, and
`level TPC
`includes a multi-
`information that
`power control
`information and
`channel, scheduling
`a single physical
`network device, on
`receive, from the
`1[e] the receiver to
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`26
`
`See 3GPP TS 36.213 V8.8.0 at 9-10.
`
`See 3GPP TS 36.300 V8.12.0 at 15.
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`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
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`

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`27
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`allocated uplink transmission resources and multilevel TPC command.
`Automotive Vehicles transmit an uplink signal, e.g., PUSCH transmission to the eNB, based on the
`information and the multi-level TPC command. For example, on information and belief, the Tesla
`the transmitter to transmit, to the network device, an uplink signal based on the received scheduling
`On information and belief, the Tesla Automotive Vehicles include the processor that is configured to cause
`
`See 3GPP TS 36.321 V8.12.0 at 20.
`
`information and the
`scheduling
`on the received
`uplink signal based
`network device, an
`to transmit, to the
`1[f] the transmitter
`
`See 3GPP TS 36.212 V8.8.0 at 43-44.
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
`
`

`

`28
`
`See 3GPP TS 36.300 V8.12.0 at 67.
`
`See 3GPP TS 36.213 V8.8.0 at 12.
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`command.
`multi-level TPC
`
`Claim 1
`
`

`

`29
`
`See 3GPP TS 36.213 V8.8.0 at 9.
`
`See 3GPP TS 36.212 V8.8.0 at 43-44.
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`Claim 1
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`

`

`30
`
`See 3GPP TS 36.213 V8.8.0 at 12.
`
`values:
`As an example, the multi-level TPC command includes a value selected from a plurality of pre-defined
`
`See Claim 1.
`
`TPC command includes a value selected from a plurality of pre-defined values.
`On information and belief, the Tesla Automotive Vehicles include a UE of claim 1, wherein the multi-level
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
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`pre-defined values
`from a plurality of
`a value selected
`command includes
`multi-level TPC
`1, wherein the
`2. The UE of claim
`
`Claim 2
`
`

`

`31
`
`See 3GPP TS 36.212 V8.8.0 at 43-44.
`
`See 3GPP TS 36.213 V8.8.0 at 9-10.
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
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`Claim 2
`
`

`

`32
`
`See 3GPP TS 36.211 V8.8.0 at 13.
`
`See 3GPP TS 36.300 V8.12.0 at 23 and 25.
`
`-Carries the UL-SCH.
`
`is further configured to transmit the uplink signal on an uplink shared channel.
`On information and belief, the Tesla Automotive Vehicles include a UE of claim 1, wherein the transmitter
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`See Claim 1.
`
`Physical Layer for E-UTRA
`
`Physical uplink shared channel (PUSCH)
` ...
`
`
`
`
`
`
`
`
`The physical channels of E-UTRA are:
`...
`5
`
`channel.
`uplink shared
`uplink signal on an
`to transmit the
`further configured
`transmitter is
`1, wherein the
`3. The UE of claim
`
`Claim 3
`
`

`

`33
`
`device is one of a Node-B or a base station.
`On information and belief, the Tesla Automotive Vehicles include a UE of claim 1, wherein the network
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`See Claim 1.
`
`a base station.
`one of a Node-B or
`network device is
`1, wherein the
`4. The UE of claim
`
`Claim 4
`
`

`

`34
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
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`Claim 4
`
`

`

`35
`
`See 3GPP TS 36.213 V8.8.0 at 12
`
`two values up or at least two values down.
`The UE of claim 1, wherein the multi-level TPC command includes a set of values that includes at least
`
`Example Evidence of Tesla Automotive Vehicles – U.S. Patent No. 10,952,153
`
`See 3GPP TS 36.300 V8.12.0 at 15 and 18-19.
`
`down.
`least two values
`two values up or at
`includes at least
`a set of values that
`command inclu