Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 1 of 14
`Case 6:21-cv-00165—ADA Document 1-6 Filed 02/23/21 Page 1 of 14
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`EXHIBIT F
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`EXHIBIT F
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`Case 6:21-cv-00165—ADA Document 1-6 Filed 02/23/21 Page 1 of 14
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`EXHIBIT F
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`EXHIBIT F
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 2 of 14
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`Claim Chart for U.S. Patent No. 9,269,208 (“the ’208 Patent”)
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`The Accused Instrumentalities include, but are not necessarily limited to, Apple iPhone type cellular phones and Apple iPad type
`tablets, including the Apple iPhone X and any Apple product or device that is substantially or reasonably similar to the functionality set
`forth below. The Accused Instrumentalities infringe the claims of the ’208 Patent, as described below, either directly under 35 U.S.C.
`§ 271(a), or indirectly under 35 U.S.C. §§ 271(b)–(c). The Accused Instrumentalities infringe the claims of the ’208 Patent literally and,
`to the extent not literally, under the doctrine of equivalents.
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`The products accused of infringing the ’208 Patent include the Secure Access Accused Products equipped with Apple Card
`loaded into the iPhone Wallet (“the Secure Pay Accused Products”).
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`To the extent that the preamble is deemed to be a limitation, the Apple iPhone X is configured to use a
`system in accordance with this claim.
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`Apple iPhone X
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`Claim 10
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`10. A method for
`providing secure access to
`a controlled item in a
`system comprising a
`database of biometric
`signatures, a transmitter
`sub-system comprising a
`biometric sensor for
`receiving a biometric
`signal, and means for
`emitting a secure access
`signal capable of granting
`more than two types of
`access to the controlled
`item, and a receiver sub-
`system comprising means
`for receiving the
`transmitted secure access
`signal, and means for
`providing conditional
`access to the controlled
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`1
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 3 of 14
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`Claim 10
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`item dependent upon
`information in said secure
`access signal, the method
`comprising the steps of:
`the
`10a.
`
`populating
`database
`of
`biometric
`signatures by: receiving a
`series of entries of
`the
`biometric signal;
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`Apple iPhone X
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`The Apple iPhone populates the database of biometric signatures by receiving a series of entries
`of the biometric signal.
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`More specifically, the Apple iPhone X has a secure enclave (SEP) in the A11 chip that populate the
`database of an encrypted mathematical representation of face images used for Face ID based on a
`series of face image received by TrueDepth camera system.
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`https://www.apple.com/business-docs/FaceID_Security_Guide.pdf
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`https://support.apple.com/en-us/HT208108
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`2
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 4 of 14
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`Claim 10
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`Apple iPhone X
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`https://www.ifixit.com/Teardown/iPhone+X+Teardown/98975
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`https://www.phonearena.com/news/TrueDepth-camera-iPhone-X-Face-ID-Animoji_id108355
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`3
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 5 of 14
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`Claim 10
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`Apple iPhone X
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`https://www.apple.com/business-docs/FaceID_Security_Guide.pdf
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`4
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 6 of 14
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`Claim 10
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`Apple iPhone X
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`https://www.ifixit.com/Teardown/iPhone+X+Teardown/98975
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`5
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 7 of 14
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`Claim 10
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`Apple iPhone X
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`https://appletoolbox.com/multiple-face-id-users-ios-12/
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`6
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 8 of 14
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`Claim 10
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`Apple iPhone X
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`https://support.apple.com/guide/iphone/set-up-face-id-iph6d162927a/ios
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`The Apple iPhone X populates the database of biometric signatures by determining at least one
`of the number of said entries and a duration of each said entry.
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`More specifically, the Apple iPhone X receives a series of face images through its image sensor on the
`TrueDepth camera system by having users move or tilt their head to set up a Face ID.
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`7
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`10a1. determining at least
`one of the number of said
`entries and a duration of
`each said entry;
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 9 of 14
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`Claim 10
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`Apple iPhone X
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`10a2. mapping said series
`into an instruction; and
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`https://support.apple.com/en-us/HT208109
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`The Apple iPhone X populates the database of biometric signatures by mapping said series into
`an instruction.
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`More specifically, the Apple iPhone X includes a secure enclave processor (SEP) that can map
`biometric signals into an instruction.
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`8
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 10 of 14
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`Claim 10
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`Apple iPhone X
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`https://www.apple.com/business-docs/FaceID_Security_Guide.pdf
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`
`the
` populating
`10a3.
`database according to the
`instruction;
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`https://support.apple.com/en-us/HT208108
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`The Apple iPhone X populates the database of biometric signatures according to the instruction.
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`More specifically, the Apple iPhone X includes a secure enclave processor (SEP) that can generate an
`authentication score based on its program instructions to determine whether the device can be
`unlocked.
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`https://www.apple.com/business-docs/FaceID_Security_Guide.pdf
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`https://support.apple.com/en-us/HT208108
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`9
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 11 of 14
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`Claim 10
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`10b. receiving a biometric
`signal;
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`Apple iPhone X
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`The Apple iPhone X provide secure access to a device by receiving a face image.
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`More specifically, the iPhone X includes a secure enclave processor (SEP) that receives translated
`face images through an image sensor located on the camera to populate the database of face images.
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`https://www.apple.com/business-docs/FaceID_Security_Guide.pdf
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`the
` matching
`10c.
`biometric signal against
`members of the database of
`biometric
`signatures
`to
`thereby
`output
`an
`accessibility attribute;
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`
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`https://support.apple.com/en-us/HT208108
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`The Apple iPhone X provide secure access to a device by matching the biometric signal against
`members of the database of biometric signatures to thereby output an accessibility attribute.
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`More specifically, the Apple iPhone X includes a secure enclave processor (SEP) that matches a face
`image against the enrolled facial image data and generate a matching score. The matching score
`generated by SEP is then transmitted to a processor. When the matching score is above the unlock
`threshold, the device can be unlocked.
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`10
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 12 of 14
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`Claim 10
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`Apple iPhone X
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`https://www.apple.com/business-docs/FaceID_Security_Guide.pdf
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`
` emitting a secure
`10d.
`access signal conveying
`information
`dependent
`upon
`said
`accessibility
`attribute; and
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`
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`https://www.apple.com/business-docs/FaceID_Security_Guide.pdf
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`The Apple iPhone X provide secure access to a device by emitting a secure access signal
`conveying information dependent upon said accessibility attribute
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`More specifically, the iPhone X includes a secure enclave processor (SEP) configured to deliver
`secure access signal to application processors.
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`“SEP is involved in a facial recognition authentication process involving images captured by camera
`and processed by ISP. SEP may be a secure circuit configured to authenticate an active user (e.g., the
`user that is currently using device) as authorized to use device. A “secure circuit” may be a circuit that
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`11
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 13 of 14
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`Claim 10
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`Apple iPhone X
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`protects an isolated, internal resource from being directly accessed by an external circuit.” the ‘835
`Publication, ¶ ¶048
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`
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`https://support.apple.com/guide/security/secure-enclave-overview-sec59b0b31ff/web
`The Apple iPhone X provides conditional access to the controlled item dependent upon said
`information, wherein the controlled item is one of: a locking mechanism of a physical access
`structure or an electronic lock on an electronic computing device.
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`More specifically, the iPhone X includes a processor that controls the unlocking of the phone based
`on the matching score received from a secure enclave processor (SEP).
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`10e. providing conditional
`access
`to
`the controlled
`item dependent upon said
`information, wherein
`the
`controlled item is one of: a
`locking mechanism of a
`physical access structure or
`an electronic lock on an
`electronic
`computing
`device.
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`12
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`Case 6:21-cv-00165-ADA Document 1-6 Filed 02/23/21 Page 14 of 14
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`Claim 10
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`Apple iPhone X
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`https://www.apple.com/business-docs/FaceID_Security_Guide.pdf
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`https://support.apple.com/en-us/HT208108
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`13
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