`
`Exhibit 2
`
`
`
`Case 6:20-cv-00867-ADA Document 1-2 Filed 09/24/20 Page 2 of 5
`
`Claim
`[1.1] A technical data monitoring device for use
`with a wireless data monitoring network, the
`technical data monitoring device comprising:
`a wireless communications circuit, the technical
`data monitoring device configured to establish a
`wireless communication link with a
`programmable interface of a programmable
`cellular telephone,
`
`[1.2] the technical data monitoring device
`configured to send and/or receive wireless
`packet switched data transmissions,
`
`[1.3] the technical data monitoring device
`having an associated status condition,
`
`Analysis
`True Protection sells a technical data monitoring device for use with a wireless data monitoring
`network. See, e.g., https://truehomeprotection.com/home-security/ (“Protecting your home
`is important. No one understands that more than us at True Protection, a leading home
`security company in Texas. Our large selection of home security products brings you peace of
`mind, letting you rest easy knowing that your home and family are safe from unwanted
`intruders.”). For example, True Protection’s home security technical data monitoring device
`such as 2GIG GC2 Control Panel, Thin Door/Window Contact and Key Fob uses wireless network
`(such as WiFi, Z-Wave Plus, dual band 802.11 a/b/g/n/ac, LTE, Bluetooth low Energy (BLE) 4.0
`and/or S-Line Encrypted 319.5 MHz) to monitor technical data and communicate with other
`wireless programmable devices. These devices have wireless communication circuits. See, e.g.,
`https://truehomeprotection.com/home-automation/ (“With home automation technology,
`you can control security systems, temperature settings, door locks, garage door openers,
`lighting and much more from a central hub in your house. True Protection’s home automation
`services redefine security measures for your household. With the swipe of a finger, turn on
`exterior lights and security cameras for a better view of your driveway or yard. Receive real-
`time alerts from burglary, unplanned guests, and even floods.”). The technical data monitoring
`device uses the wireless communication circuit to establish links to a programmable interface
`of a programmable cellular telephone, for example, a mobile app (“Alarm.com”) running on a
`smartphone. See, e.g., https://truehomeprotection.com/home-automation/ (“Use the app
`from our corporate partner, Alarm.com, to unlock doors, turn on lights and even turn on the
`air conditioner as you arrive home. Inside, you can operate your integrated systems and
`appliances from a central all-in-one control panel or Alarm.com smartphone app. We also offer
`additional wireless touch screens to save you steps.”).
`
`The technical data monitoring devices are configured to send and/or receive wireless packet
`switch data transmissions. Networks such as WiFi, Z-Wave Plus, dual band 802.11
`a/b/g/n/ac, LTE, Bluetooth low Energy (BLE) 4.0 and/or S-Line Encrypted 319.5 MHz) send
`and/or receive data in the form of packet switched data transmission. See
`https://truehomeprotection.com/home-automation/ .
`The technical data monitoring devices have many status conditions, including, for example:
`armed, not armed, alerts, event notification alarm and/or emergency features etc. See, e.g.,
`https://truehomeprotection.com/home-security/ (“Thin Door/Window Contact, This is a
`wireless, tamper protected door/window sensor. This sensor is most commonly used on the
`windows of your home. In the event that a window is opened while your system is armed, your
`alarm will sound immediately.”).
`
`1
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`
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`Case 6:20-cv-00867-ADA Document 1-2 Filed 09/24/20 Page 3 of 5
`
`The technical data monitoring devices are configured to generate data and to send data over
`the wireless communication link for processing by the programmable cellular telephone. The
`device is also configured to generate data (alarm and notifications) associated with sensors
`such as (Thin Door/Window Contact, Infrared Motion Detector, Glass Break Detector, Super
`Switch and/or Smoke/Heat detector) and send it over the wireless communication link for
`processing
`by
`the
`programmable
`cellular
`telephone,
`See
`https://truehomeprotection.com/home-security/. “Alarm.com” app which when installed on
`the programmable cellular telephone (such as smartphones) connects over wireless
`communication network with the panel to send and/or receive notifications and alerts, See
`https://truehomeprotection.com/home-automation/.
`
`The sent data is either displayed by the programmable cellular telephone and/or sent to an
`Internet website via GPRS or other wireless packet switched protocols. The data (alarm and/or
`notifications) associated with the True Protection products is sent to the programmable
`cellular telephone and displays the data on cellular telephone via “Alarm.com” app.
`See https://truehomeprotection.com/home-automation/.
`
`The technical data monitoring device is configured as part of the wireless data monitoring
`network
`along
`with
`the
`programmable
`cellular
`telephone.
`See
`https://truehomeprotection.com/home-automation/.
`
`The technical devices and system consist of many members of this group, including at least a
`home security monitoring system of one or more sensors (Thin Door/Window Contact, Infrared
`Motion Detector, Glass Break Detector, Super Switch and/or Smoke/Heat detector). See, e.g.,
`https://truehomeprotection.com/home-automation/ (“Use the app from our corporate
`partner, Alarm.com, to unlock doors, turn on lights and even turn on the air conditioner as you
`arrive home. Inside, you can operate your integrated systems and appliances from a central
`all-in-one control panel or Alarm.com smartphone app. We also offer additional wireless touch
`screens to save you steps.”).
`
`[1.4] the technical data monitoring device
`configured to generate data and send data over
`the wireless communication link for processing
`by
`the programmable cellular
`telephone
`periodically or
`in response to
`instructions
`received in a wireless packet switched message
`from the programmable cellular telephone,
`
`[1.5] wherein the data from the technical data
`monitoring device is (1) sent to be processed and
`displayed by
`the programmable
`cellular
`telephone and/or (2) sent to be processed and
`forwarded by
`the programmable cellular
`telephone to an Internet website via one or
`more General Packet Radio Service (GPRS), or
`other wireless packet switched data messages,
`[1.6] wherein the technical data monitoring
`device is configured to form part of the wireless
`data monitoring network in communication with
`the programmable cellular telephone;
`[1.7] and
`at least one technical device or system, the at
`least one technical device or system being at
`least one selected from the group consisting of a
`pressure sensor, a heat sensor, a mechanical
`displacement sensor, a speed sensor, a
`temperature sensor, a sound threshold sensor, a
`movement sensor, an electrical power sensor, an
`infra-red
`radiation detector, a proximity
`detection sensor, a heart rate sensor, a water
`sensor, a location processing module, a GPS
`Global Positioning Systems module, a sensor for
`detecting any physical characteristic of the
`human skin, and a health monitoring system of
`one or more sensors, a sports performance
`
`2
`
`
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`Case 6:20-cv-00867-ADA Document 1-2 Filed 09/24/20 Page 4 of 5
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`monitoring system of one or more sensors, a
`domestic appliance monitoring system of one or
`more sensors, and a home security monitoring
`system of one or more sensors,
`[1.8] wherein the data sent by the technical data
`monitoring device represents at least one of
`pressure
`data,
`heat
`data, mechanical
`displacement data, speed data, temperature
`data, sound threshold data, movement data,
`electrical power data, infra-red radiation data,
`proximity detection data, heart rate data, body
`temperature data, health data, water detection
`data,
`location data, GPS data,
`sports
`performance data, domestic appliance data, and
`home security data.
` [3] A technical data monitoring device according
`to claim 1, wherein the data from the technical
`data monitoring device
`is processed by a
`communications application running on the
`programmable cellular telephone.
`
`The data sent by the technical data monitoring device represents at least home security data
`associated with large range of sensors which integrates with at least one of the sensors (Thin
`Door/Window Contact, Infrared Motion Detector, Glass Break Detector, Super Switch and/or
`Smoke/Heat detector).
`See https://truehomeprotection.com/home-security/.
`
`True Protection uses a mobile app (“Alarm.com“) to process data on a programmable cellular
`telephone, such as Android or iPhones. See, e.g., https://truehomeprotection.com/home-
`automation/ (“Use the app from our corporate partner, Alarm.com, to unlock doors, turn on
`lights and even turn on the air conditioner as you arrive home. Inside, you can operate your
`integrated systems and appliances from a central all-in-one control panel or Alarm.com
`smartphone app. We also offer additional wireless touch screens to save you steps.”).
`
`[7] A technical data monitoring device according
`to claim 1, wherein
`the
`technical data
`monitoring device
`is further configured to
`transmit an alarm or data message to the
`programmable cellular telephone in response to
`a change in status of the said at least one
`technical data monitoring device.
`
`The technical data monitoring devices are configured to transmit an alarm or data message to
`the programmable cellular telephones via the mobile app in response to a change in the status
`of the device. See, e.g., https://truehomeprotection.com/home-automation/ (“Use the app
`from our corporate partner, Alarm.com, to unlock doors, turn on lights and even turn on the
`air conditioner as you arrive home. Inside, you can operate your integrated systems and
`appliances from a central all-in-one control panel or Alarm.com smartphone app. We also offer
`additional wireless touch screens to save you steps.”).
`
`technical data monitoring device
`[21] A
`according to claim 1, wherein the technical data
`monitoring device comprises a domestic
`appliance monitoring system, wherein the
`technical data monitoring device
`is further
`configured to transmit an alarm or data message
`to the programmable cellular telephone via the
`wireless
`communication
`link with
`the
`
`True Protection’s home security has a domestic appliance monitoring system that is configured
`to transmit an alarm or data message to the programmable cellular telephone via the link in
`response to a change in the status, wherein the data consists of at least home security data
`(among others). See https://truehomeprotection.com/home-security/.
`The home security monitoring device
`integrates with domestic appliance (such as
`door/window locks, key fob, 2GIG GC2 Control Panel and/or thermostats) and sends at least
`one of the corresponding data (such as mechanical displacement data, temperature data,
`movement data, proximity detection data, water detection data, location data, GPS data
`
`3
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`
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`Case 6:20-cv-00867-ADA Document 1-2 Filed 09/24/20 Page 5 of 5
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`in response to a
`interface,
`programmable
`change in status of the said at least one technical
`data monitoring device, wherein the data
`message includes data representing at least one
`of pressure data, heat data, mechanical
`displacement data, temperature data, sound
`threshold data, movement data, electrical power
`data,
`infra-red
`radiation data, proximity
`detection data, body
`temperature data,
`domestic appliance data, water pipe pressure
`data, home network data, door status data,
`window status data, and home security data.
`[23] A
`technical data monitoring device
`according to claim 1, wherein the technical data
`monitoring device is also configured to receive
`data communications from the programmable
`cellular telephone.
`
`domestic appliance data, and home security data) associated with the sensor (such as Thin
`Door/Window Contact, Infrared Motion Detector, Glass Break Detector, Super Switch and/or
`Smoke/Heat detector).
`Further, the alarm and/or data message is sent to the cellular telephone in response to a
`change in status of the at least one of the sensor data.
`
`The technical monitoring devices are also configured to receive data communications from the
`programmable cellular
`telephone. See, e.g., https://truehomeprotection.com/home-
`automation/ (“Use the app from our corporate partner, Alarm.com, to unlock doors, turn on
`lights and even turn on the air conditioner as you arrive home. Inside, you can operate your
`integrated systems and appliances from a central all-in-one control panel or Alarm.com
`smartphone app. We also offer additional wireless touch screens to save you steps.”).
`
`technical data monitoring device
`[24] A
`according to claim 1, wherein the technical data
`monitoring device is configured to be integrated
`with and/or embedded in a domestic appliance.
`
`The technical data monitoring devices are configured to be integrated with and/or embedded
`in domestic appliances, such as door/window locks, key fob and/or light controls. See
`https://truehomeprotection.com/home-security/.
`
`
`4
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