Case 6:21-cv-00420-ADA Document 1-6 Filed 04/27/21 Page 1 of 11
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`Exhibit 6
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`Exhibit 6
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`Case 6:21-cv-00420-ADA Document 1-6 Filed 04/27/21 Page 2 of 11
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`HTC – Smartphones (see product list at end for relevant models)
`Infringement of the ‘105 patent
`Claim 1
`Evidence & Specification Support
`1. A method comprising:
`The HTC smartphone performs a method of mobile printing.
`For example, the HTC smartphone comes with mobile printing
`functionality built-in for operating systems Android 8 and later.
`
`[1]
`Mobile printing as supported by Mopria standards uses the set of
`Internet Printing Protocols (IPP).
`
`receiving, by a computing
`
`[6]
`The HTC smartphone receives, from a remote printer, data identifying
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`1
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`Case 6:21-cv-00420-ADA Document 1-6 Filed 04/27/21 Page 3 of 11
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`device from a remote printer,
`data identifying one or more
`characteristics of the remote
`printer, wherein the computing
`device comprises at least one
`processor and memory and is
`communicatively coupled to
`the remote printer via a
`network;
`
`one or more characteristics of the remote printer. The HTC
`smartphone is a computing device that includes a processor and
`memory and is communicatively coupled to the remote printer via a
`network.
`For example, the smartphone automatically discovers printers nearby
`that are certified for mobile printing by the Mopria Alliance. Most
`major brands of printers include Mopria certified printer models.
`
`[1]
`
`[1]
`The HTC Exodus 1s smartphone uses the Android 8.1 operating
`system, has a Qualcomm Snapdragon 435 central processor and 4096
`MB of RAM memory.
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`2
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`Case 6:21-cv-00420-ADA Document 1-6 Filed 04/27/21 Page 4 of 11
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`[8]
`
`[8]
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`[8]
`With IPP (Internet Printing Protocol), URI’s are used to identify a printer
`[2]. Other identifying data are the printer’s DNS hostname and
`network address. A printer server would receive these from a printer
`during the discovery process. (e.g. via mDNS, DNS-SD, Bonjour etc.).
`IPP also supports printer description attributes, including printer make
`and model, manufacturer, location etc. [3]. These attributes would be
`sent to a client from the printer when requested by the client.
`
`3
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`Case 6:21-cv-00420-ADA Document 1-6 Filed 04/27/21 Page 5 of 11
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`Specification Support
`Examples given in the patent of data identifying one or more
`characteristics of a printer are printer model, serial number and
`firmware version number. Such data is used to identify the printer for
`the purpose of registering it with a client (e.g. smartphone).
`According to the patent in the description concerning Figs. 7 and 8:
`“The data identifying the characteristics of the printer includes
`the serial number, the model number and the firmware number
`(revision, model) of the printer 30. The characteristics of the
`printer are compared to data in a database in order to verify
`registration (step 610, FIG. 8). If the characteristics of the
`printer 30 are found in the database, a specified number for the
`data items to be printed, and a specified number for the print
`data portions to be downloaded are sent to the
`printer 30 (step 630, FIG. 8). “
`The HTC smartphone verifies that the remote printer has been
`registered with the smartphone.
`
`For example, as part of the printer discovery process, and afterwards,
`the smartphone verifies that the printer is registered with it.
`Verification can be in terms of keeping the listing of already
`discovered printers updated, as well as part of the authentication
`procedure when secure printing (e.g. IPPS over HTTPS) is used.
`
`verifying, by the computing
`device, that the remote printer
`has been registered with the
`computing device; and
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`4
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`Case 6:21-cv-00420-ADA Document 1-6 Filed 04/27/21 Page 6 of 11
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`[1]
`As a convenience, printer URIs are kept by clients (e.g. smartphones)
`in a similar way that bookmarks are kept in web browsers. [2]
`Therefore, after a client has discovered a printer, the record of the
`printer’s URI in the client’s database (or cache) could be considered a
`registration of the printer.
`Furthermore, there are scenarios where the printer would send its URI
`to a client that already knows of the printer. For example, if the client
`is conducting continuous multicast DNS querying to determine all the
`reachable printers on a network, a printer will respond with its URI
`when the client already knows of the printer (despite known answer
`suppression) if the RR TTL (resource record time to live) for the printer
`(resource) is less than half of the original TTL. In that case, when the
`client receives such a response to the query, the client updates the
`record for the printer in its cache with the new TTL.
`According to the Internet Standard RFC6762 - Multicast DNS [5]
`“5.2. Continuous Multicast DNS Querying
`…
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`5
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`Case 6:21-cv-00420-ADA Document 1-6 Filed 04/27/21 Page 7 of 11
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`6
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`Imagine some hypothetical software that allows users to
`discover network printers. The user wishes to discover all
`printers on the local network, not only the printer that is
`quickest to respond. When the user is actively looking for a
`network printer to use, they open a network browsing window
`that displays the list of discovered printers. It would be
`convenient for the user if they could rely on this list of network
`printers to stay up to date as network printers come and go,
`rather than displaying out-of-date stale information, and
`requiring the user explicitly to click a "refresh" button any time
`they want to see accurate information (which, from the moment
`it is displayed, is itself already beginning to become out-of-date
`and stale). If we are to display a continuously updated live list
`like this, we need to be able to do it efficiently, without naive
`constant polling, which would be an unreasonable burden on
`the network.
`herefore, when retransmitting Multicast DNS queries to
`implement this kind of continuous monitoring, the interval
`between the first two queries MUST be at least one second, the
`intervals between successive queries MUST increase by at least
`a factor of two, and the querier MUST implement Known-Answer
`Suppression, as described below in Section 7.1. “ [RFC6762] [5]
`“7.1. Known-Answer Suppression
` Multicast DNS responder MUST NOT answer a Multicast DNS
`query if the answer it would give is already included in the
`Answer Section with an RR TTL at least half the correct value. If
`the RR TTL of the answer as given in the Answer Section is less
`than half of the true RR TTL as known by the Multicast DNS
`responder, the responder MUST send an answer so as to
`update the querier's cache before the record becomes in danger
`
`…A
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`…T
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`Case 6:21-cv-00420-ADA Document 1-6 Filed 04/27/21 Page 8 of 11
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`sending, from the computing
`device to the remote printer,
`an indication of a number of
`data items to be printed and an
`indication of a number of print
`data items to be downloaded,
`wherein the remote printer is
`configured to download the
`print data items.
`
`of expiration.” [RFC6762][5]
`The HTC smartphone sends, to the remote printer, an indication of a
`number of data items to be printed and an indication of a number of
`print data items to be downloaded. The remote printer is configured to
`download the print data items.
`For example, the smartphone sends information to the printer such as
`the number of copies of an item to be printed and/or the page range
`of pages to be printed. Each document or pages in a range are items
`that need to be retrieved, or downloaded, over a network by the
`printer. The number of these items to be printed depends on the
`number of copies that were specified.
`
`[1]
`In computer networks, download means to receive data from a remote
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`Case 6:21-cv-00420-ADA Document 1-6 Filed 04/27/21 Page 9 of 11
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`system, typically a server such as a web server, an FTP server, an
`email server, or other similar system. This contrasts with uploading,
`where data is sent to a remote server. A download is a file offered for
`downloading or that has been downloaded, or the process of receiving
`such a file. [7]
`Specification Support
`The patent does not differentiate between the client pushing a
`document to the printer (as in the Send-Document request) and the
`printer pulling the document from a server (as in the Send-URI
`request). Both could be considered as downloading because in both
`cases the printer receives the document over a network and saves it
`in its memory.
`
`Product List:
`Exodus 1s
`U11 life
`U12+
`
`8
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`Case 6:21-cv-00420-ADA Document 1-6 Filed 04/27/21 Page 10 of 11
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`References:
`[1] Print From Android 8 and Higher FAQ
`https://mopria.org/androidfaq
`[2] PWG 5100.19-2015 - IPP Implementor's Guide v2.0 (IG) (Updates RFC 3196)
`https://ftp.pwg.org/pub/pwg/candidates/cs-ippig20-20150821-5100.19.pdf
`[3] RFC8011 - Internet Printing Protocol/1.1: Model and Semantics (2017)
`https://tools.ietf.org/html/rfc8011
`[4] How to Use the Internet Printing Protocol
`https://www.pwg.org/ipp/ippguide.html
`[5] RFC6762 - Multicast DNS (2013)
`https://tools.ietf.org/html/rfc6762
`[6] IPP Everywhere Frequently Asked Questions
`https://www.pwg.org/ipp/evefaq.html#:~:text=All%20computers%20running%20CUPS%201.5,AirPrint
`%C2%AE%20or%20Mopria%C2%AE.
`[7] Download - Wikipedia
`https://searchnetworking.techtarget.com/definition/downloading#:~:text=Downloading%20is%20the
`%20transmission%20of,computer)%20and%20to%20receive%20it.
`[8] Exodus 1s
`https://phonedb.net/index.php?m=device&id=15883&c=htc_exodus_1s_global_dual_sim_td-
`lte&d=detailed_specs
`https://www.htcexodus.com/us/cryptophone/exodus1-binance/
`
`[9] U11 life
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`9
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`Case 6:21-cv-00420-ADA Document 1-6 Filed 04/27/21 Page 11 of 11
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`https://www.gsmarena.com/htc_u11_life-8885.php
`https://www.htc.com/us/smartphones/htc-u11-life/
`[10] U12+
`https://www.gsmarena.com/htc_u12+-9119.php
`https://www.htc.com/us/smartphones/htc-u12-plus/
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`10
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