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Case 3:24-cv-00540-MHL Document 27-3 Filed 10/11/24 Page 1 of 5 PageID# 272
`Case 3:24-cv-00540-MHL Document 27-3 Filed 10/11/24 Page 1 of 5 PagelD# 272
`
`
`
`EXHIBIT C
`EXHIBIT C
`
`

`

`Case 3:24-cv-00540-MHL Document 27-3 Filed 10/11/24 Page 2 of 5 PageID# 273
`
`SoundClear
`’675 Patent
`Claim 6*
`
`McRO
`’576 Patent,
`Claim 1†
`
`
`1. [Pre] An output-
`content control method
`comprising:
`
`[a] acquiring a voice
`spoken by a user;
`
`Valid
`1. [Pre] A method for
`automatically animating
`lip synchronization and
`facial expression of
`three-dimensional
`characters comprising:
`[b] obtaining a timed
`data file of phonemes
`having a plurality of
`sub-sequences
`
`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:
`
`[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,
`
`EXHIBIT C
`
`Contour
`’954 Patent
`Claim 11†
`
`Valid
`11. [Pre] A portable,
`point of view digital
`video camera,
`comprising:
`
`[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;
`
`[d] a camera processor
`configured to:
`
`[e] receive the video
`image data directly or
`
`
`* 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 ’675 patent claim 6.
`1
`
`
`
`

`

`Case 3:24-cv-00540-MHL Document 27-3 Filed 10/11/24 Page 3 of 5 PageID# 274
`
`EXHIBIT C
`
`Contour
`’954 Patent
`Claim 11†
`indirectly from the
`image sensor,
`[h] receive the control
`signals from the
`personal portable
`computing device, 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.
`
`
`SoundClear
`’675 Patent
`Claim 6*
`
`McRO
`’576 Patent,
`Claim 1†
`
`[b] calculating a
`distance between the
`user and an output-
`content control device
`by a proximity sensor to
`classify the voice into
`either a first voice or a
`second voice based on
`the calculated distance;
`
`[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
`
`
`
`[c] analyzing the
`acquired voice to detect
`intention information
`indicating what kind of
`information is wished to
`be acquired by the user;
`
`
`
`2
`
`CardioNet
`’207 Patent
`Claim 1†
`
`Cosmokey
`’903 Patent
`Claim 1†
`
`[a] a beat detector to
`identify a beat-to-beat
`timing of cardiac
`activity;
`
`[e] ensuring that said
`response from the second
`communication channel
`includes information that
`the authentication function
`is active, and
`
`[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 27-3 Filed 10/11/24 Page 4 of 5 PageID# 275
`
`SoundClear
`’675 Patent
`Claim 6*
`[d] acquiring
`notification information
`which includes content
`information as a content
`of information to be
`notified to the user
`based on the intention
`information; and
`
`McRO
`’576 Patent,
`Claim 1†
`[e] applying said final
`stream of output morph
`weight sets to a
`sequence of animated
`characters to produce lip
`synchronization and
`facial expression control
`of said animated
`characters.
`
`[e] generating, when the
`voice is determined to
`be the first voice, a first
`output sentence in
`which at least one word
`selected among words
`included in the content
`information of the
`notification information
`is replaced with another
`word; and
`
`[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;
`
`EXHIBIT C
`
`Contour
`’954 Patent
`Claim 11†
`[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 transmission
`directly from a personal
`portable computing
`device executing an
`application; and
`[f] generate‡ from the
`video image data a 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
`
`CardioNet
`’207 Patent
`Claim 1†
`[d] relevance
`determination logic to
`identify a relevance of
`the variability in the
`beat-to-beat timing to at
`least one of atrial
`fibrillation and atrial
`flutter; and
`
`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] 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
`
`
`‡ 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).
`
`
`
`3
`
`

`

`Case 3:24-cv-00540-MHL Document 27-3 Filed 10/11/24 Page 5 of 5 PageID# 276
`
`SoundClear
`’675 Patent
`Claim 6*
`
`McRO
`’576 Patent,
`Claim 1†
`
`[f] generating, when the
`voice is not determined
`to be the second voice, a
`second output sentence
`which includes all of the
`intention information
`and the content
`information.
`
`[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
`
`EXHIBIT C
`
`Contour
`’954 Patent
`Claim 11†
`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,
`[f] [continued] . . . and a
`second image data
`stream, wherein the
`second image data
`stream is a higher
`quality than the first
`image data stream,
`
`CardioNet
`’207 Patent
`Claim 1†
`ventricular beat
`detector.
`
`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 automatically
`deactivated.
`
`
`
`
`
`4
`
`

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