throbber
Case 3:24-cv-00540-MHL Document 27-2 Filed 10/11/24 Page 1 of 6 PageID# 266
`Case 3:24-cv-00540-MHL Document 27-2 Filed 10/11/24 Page 1 of 6 PagelD# 266
`
`
`
`EXHIBIT B
`EXHIBIT B
`
`

`

`Case 3:24-cv-00540-MHL Document 27-2 Filed 10/11/24 Page 2 of 6 PageID# 267
`
`SoundClear
`’337 Patent
`Claim 4*
`
`
`4. [Pre] A voice-content
`control method,
`comprising:
`
`[a] calculating a
`distance between a user
`and a voice-content
`control device;
`
`[b] acquiring a voice
`spoken by a user;
`
`McRO
`’576 Patent,
`Claim 1
`
`Valid
`1. [Pre] A method for
`automatically animating
`lip synchronization and
`facial expression of three-
`dimensional characters
`comprising:
`[a] obtaining a first set of
`rules that define output
`morph weight set stream
`as a function of phoneme
`sequence and time of said
`phoneme sequence
`[b] obtaining a timed data
`file of phonemes having a
`plurality of sub-sequences
`
`EXHIBIT B
`
`Contour
`’954 Patent
`Claim 11†
`
`Valid
`11. [Pre] A portable, point
`of view digital video
`camera, comprising:
`
`CardioNet
`’207 Patent
`Claim 1
`
`Valid
`1. [Pre] A device,
`comprising:
`
`Cosmokey
`’903 Patent
`Claim 1†
`
`Valid
`1. [Pre] A method of
`authenticating a user to
`a transaction at a
`terminal, comprising the
`steps of:
`
`[h] receive the control
`signals from the personal
`portable computing
`device, and
`
`
`
`[a] a beat detector to
`identify a beat-to-beat
`timing of cardiac
`activity;
`
`[b] a ventricular beat
`detector to identify
`ventricular beats in
`the cardiac activity;
`
`[a] transmitting a user
`identification from the
`terminal to a transaction
`partner via a first
`communication channel,
`
`[a] a lens;
`
`[b] an image sensor
`configured to capture light
`propagating through the
`lens and representing a
`scene, and produce real
`time video image data of
`the scene;
`
`
`
`* Annotating initial terms in claim language corresponding to Google’s improper, over-generalized approach. See Section II.A of
`SoundClear’s Response Brief.
`
`† The limitations have been reordered to demonstrate similarity, in terms of the Alice Step One analysis, with ’337 patent claim 4.
`1
`
`
`
`

`

`Case 3:24-cv-00540-MHL Document 27-2 Filed 10/11/24 Page 3 of 6 PageID# 268
`
`EXHIBIT B
`
`Contour
`’954 Patent
`Claim 11†
`[d] a camera processor
`configured to:
`[e] receive the video
`image data directly or
`indirectly from the image
`sensor,
`
`
`SoundClear
`’337 Patent
`Claim 4*
`
`McRO
`’576 Patent,
`Claim 1
`
`
`
`
`
`[c] analyzing the
`acquired voice to
`classify the acquired
`voice as either one of a
`first voice and a second
`voice based on the
`distance between the
`user and the voice-
`content control device;
`
`[d] analyzing the
`acquired voice to
`execute processing
`intended by the user;
`
`
`
`[c] a wireless connection
`protocol device configured
`to send real time image
`content by wireless
`transmission directly to
`and receive control signals
`or data signals by wireless
`
`[d] relevance
`determination logic to
`identify a relevance of
`the variability in the
`beat-to-beat timing to
`at least one of atrial
`
`2
`
`CardioNet
`’207 Patent
`Claim 1
`
`Cosmokey
`’903 Patent
`Claim 1†
`
`[c] variability
`determination logic to
`determine a
`variability in the beat-
`to-beat timing of a
`collection of beats;
`
`[c] as a criterion for
`deciding whether the
`authentication to the
`transaction shall be
`granted or denied,
`having the
`authentication device
`check whether a
`predetermined time
`relation exists between
`the transmission of the
`user identification and a
`response from the
`second communication
`channel,
`
`
`

`

`Case 3:24-cv-00540-MHL Document 27-2 Filed 10/11/24 Page 4 of 6 PageID# 269
`
`SoundClear
`’337 Patent
`Claim 4*
`
`McRO
`’576 Patent,
`Claim 1
`
`
`
`
`
`[e] generating, based on
`content of the executed
`processing, output
`sentence that is text data
`for a voice to be output
`to the user; and
`
`[f] adjusting a sound
`volume of voice data
`obtained by converting
`the output sentence
`thereinto, wherein
`
`
`
`EXHIBIT B
`
`Contour
`’954 Patent
`Claim 11†
`transmission directly from
`a personal portable
`computing device
`executing an application;
`and
`
`
`[i] adjust one or more
`settings of the video
`camera based at least in
`part on at least a portion of
`the control signals
`received from the personal
`portable computing
`device.
`
`3
`
`CardioNet
`’207 Patent
`Claim 1
`fibrillation and atrial
`flutter; and
`
`[e] an event generator
`to generate an event
`when the variability
`in the beat-to-beat
`timing is identified as
`relevant to the at least
`one of atrial
`fibrillation and atrial
`flutter in light of the
`variability in the beat-
`to-beat timing caused
`by ventricular beats
`identified by the
`ventricular beat
`detector.
`
`
`Cosmokey
`’903 Patent
`Claim 1†
`
`[d] ensuring that the
`authentication function
`is normally inactive and
`is activated by the user
`only preliminarily for
`the transaction,
`
`[e] ensuring that said
`response from the
`second communication
`channel includes
`information that the
`authentication function
`is active, and
`
`

`

`Case 3:24-cv-00540-MHL Document 27-2 Filed 10/11/24 Page 5 of 6 PageID# 270
`
`EXHIBIT B
`
`McRO
`’576 Patent,
`Claim 1
`
`Contour
`’954 Patent
`Claim 11†
`
`CardioNet
`’207 Patent
`Claim 1
`
`Cosmokey
`’903 Patent
`Claim 1†
`
`
`
`
`[b] providing an
`authentication step in
`which an authentication
`device uses a second
`communication channel
`for checking an
`authentication function
`that is implemented in a
`mobile device of the
`user,
`[f] thereafter ensuring
`that the authentication
`function is
`
`SoundClear
`’337 Patent
`Claim 4*
`[g] at the generating,
`[h] a first output
`sentence is generated as
`the output sentence
`when the acquired voice
`has been classified as
`the first voice, and
`
`[i] a second output
`sentence is generated as
`the output sentence in
`which a part of
`information included in
`the first output sentence
`is omitted when the
`acquired voice has been
`classified as the second
`voice, wherein
`[j] at adjusting the
`sound volume of voice
`data, further adjusting
`the sound volume of
`
`
`[f] generate‡ from the
`video image data a first
`image data stream . . . .
`
`[f] [continued] . . . and a
`second image data stream,
`. . . .
`
`
`
`
`
`
`
`[c] generating an
`intermediate stream of
`output morph weight sets
`and a plurality of
`transition parameters
`between two adjacent
`morph weight sets by
`evaluating said plurality of
`sub-sequences against said
`first set of rules;
`[d] generating a final
`stream of output morph
`weight sets at a desired
`frame rate from said
`intermediate stream of
`output morph weight sets
`and said plurality of
`transition parameters; and
`
`[f] [continued again] . . .
`wherein the second image
`data stream is a higher
`
`
`
`
`
`4
`
`[e] applying said final
`stream of output morph
`weight sets to a sequence
`of animated characters to
`
`‡ Construed to mean “record in parallel from the video image data. Contour IP Holding LLC v. GoPro, Inc., __ F.4th __, 2024 U.S.
`App. LEXIS 22825, *7 (Fed. Cir. Sept. 9, 2024).
`
`

`

`Case 3:24-cv-00540-MHL Document 27-2 Filed 10/11/24 Page 6 of 6 PageID# 271
`
`CardioNet
`’207 Patent
`Claim 1
`
`Cosmokey
`’903 Patent
`Claim 1†
`automatically
`deactivated.
`
`McRO
`’576 Patent,
`Claim 1
`produce lip
`synchronization and facial
`expression control of said
`animated characters.
`
`SoundClear
`’337 Patent
`Claim 4*
`voice data such that the
`sound volume of voice
`data obtained by
`converting the first
`output sentence
`thereinto differs from
`the sound volume of
`voice data obtained by
`converting the second
`output sentence
`thereinto.
`
`
`
`
`
`EXHIBIT B
`
`Contour
`’954 Patent
`Claim 11†
`quality than the first image
`data stream,
`
`[g] cause the wireless
`connection protocol
`device to send the first
`image data stream directly
`to the personal portable
`computing device for
`display on a display of the
`personal portable
`computing device,
`wherein the personal
`portable computing device
`generates the control
`signals for the video
`camera, and wherein the
`control signals comprise at
`least one of a frame
`alignment, multi-camera
`synchronization, remote
`file access, and a
`resolution setting, and at
`least one of a lighting
`setting, a color setting, and
`an audio setting,
`
`5
`
`

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