`Case 2:22-cv-08050-CJC-JDE Document 23-5 Filed 04/18/23 Page 1of33 Page ID #:190
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`EXHIBIT 4
`EXHIBIT 4
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`
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`Case 2:22-cv-08050-CJC-JDE Document 23-5 Filed 04/18/23 Page 2 of 33 Page ID #:191
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`Exhibit 4
`Exemplary Infringement – ‘930 Patent, claim 6
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`Hikvision (A) directly infringed, (B) contributorily infringed, and (C) induced
`
`infringement claim 6 of the ‘930 Patent.
`
`(A) Direct infringement. Hikvision directly infringed claim 6 of the ‘930 Patent by practicing a
`
`method for remotely powering access equipment in a data network that satisfied all of the
`
`claimed elements of claim 6 as described below.
`
`In directly infringing claim 6 of the ‘930 Patent by practicing such a method, (a) the
`
`power sourcing equipment 1 (data nodes) and powered devices (access devices) used by
`
`Hikvision can both be Hikvision products, (b) neither can be Hikvision products (that is,
`
`Hikvision can use power sourcing equipment (data nodes) and powered devices (access
`
`devices) made by others), or (c) either the power sourcing equipment (data nodes) or the
`
`powered devices (access devices) can be Hikvision products, that satisfies all of the
`
`claimed elements as described below.
`
`1
`
`The IEEE 802.3 standards (including 802.3af and 802.3at) use their own terminology to
`describe what is referred to in the ‘930 Patent as the (a) “data signaling pair,” (b) “data node,”
`and (c) “access device:”
`
`•
`
`“1.4 Definitions …
`•
`1.4.x Twisted Pair Medium Dependent Interface (TP MDI): The mechanical and
`electrical interface between the transmission medium and the Medium Attachment Unit
`(MAU) or PHY, e.g., (10BASE-T, 100BASE-TX, or 1000BASE-T) [the “TP MDI”
`corresponds to the interface of the “data signaling pair” used in the claims of the ‘930
`Patent].
`1.4.x Power sourcing Equipment (PSE): A DTE or midspan that provides the power to a
`single link section. DTE powering is intended to provide a single 10BASE-T, 100BASE-
`T, or 1000BASE-T device with a unified interface for both the data it requires and the
`power to process these data [the “PSE” corresponds to the “data node” used in the claims
`of the ‘930 Patent].
`1.4.x Powered Device (PD): A device that is either drawing power or requesting power
`from a PSE [the “PD” corresponds to the “access device” used in the claims of the ‘930
`Patent].”
`
`•
`
`1
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`
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`
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`(B) Contributory infringement. Hikvision contributed to infringing claim 6 of the ‘930 Patent by
`
`making, importing, selling, and offering to sell:
`
`(1) power sourcing equipment (data nodes) that, when combined and connected to
`
`powered devices (access devices) that are either Hikvision powered devices (access
`
`devices) or are powered devices (access devices) made by others, are designed, sold,
`
`and imported with the knowledge that they are especially made or adapted for use as a
`
`material part of a combination that practices the method of claim 6 for remotely
`
`powering access equipment in a data network, that satisfies all of the claimed elements
`
`as described below; and
`
`(2) powered devices (access devices) that, when combined and connected to power
`
`sourcing equipment (data nodes) that are either Hikvision power sourcing equipment
`
`(data nodes) or are power sourcing equipment (data node) made by others, are
`
`designed, sold, and imported with the knowledge that they are especially made or
`
`adapted for use as a material part of combination that practices the method of claim 6
`
`for remotely powering access equipment in a data network, that satisfies all of the
`
`claimed elements as described below.
`
`
`
`(C) Induced infringement. Hikvision actively induced infringement of claim 6 of the ‘930
`
`Patent by instructing others to use power sourcing equipment (data nodes) (made by Hikvision
`
`or others), combined with and connected to powered devices (access devices) (made by
`
`Hikvision or others), as suggested by Hikvision’s manuals, advertising, place cards,
`
`instructions, and other literature, to practice the method of claim 6 for remotely powering
`
`access equipment in a data network, that satisfies all of the claimed elements as described
`
`below.
`
`
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`
`
`2
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`
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`Case 2:22-cv-08050-CJC-JDE Document 23-5 Filed 04/18/23 Page 4 of 33 Page ID #:193
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`
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`Hikvision’s products were designed and functioned consistent with the IEEE 802.3af 2 or
`
`802.3at 3 Standards. 4 Sample statements demonstrating that Hikvision’s products conform to
`
`the IEEE 802.3af or 802.3at Standards include:
`
`• “PoE Standard IEEE802.3af, IEEE802.3at”
`
`• “Compliant with IEEE802.3at/af”
`
`• “ports 1-4/8 support IEEE 802.3af PoE (15.4W) and IEEE 802.3at PoE+ (30W)”
`
`
`
`
`
`Claim language
`
`Claim 6
`
`Evidence and Analysis 5
`
`Pre: Method for
`
`Sample evidence (Hikvision statements, depictions, and other documentation),
`
`remotely powering
`
`includes: 6
`
`access equipment
`
`• See elements [a] – [d] below;
`
`in a data network,
`
`comprising
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`2
`The IEEE 802.3af Standard extends prior 802.3 Ethernet standards to support devices and
`interfaces for remotely powering access equipment in a data network. (IEEE 802.3af Standard).
`
` 3
`
`“Abstract: This amendment includes changes to IEEE Std 802.3-2008 to augment the
`
`capabilities of IEEE Std 802.3 with higher power levels and improved power management
`information.” (IEEE 802.3at Standard Abstract).
`
`All components of the 802.3af Standard are integrated into 802.3-2008 Standard.
`
`
`
` 4
`
` 5
`
`This infringement chart is exemplary and does not present all infringement theories,
`
`including any doctrine of equivalents theories.
`
` 6
`
`
`The “Sample evidence (Hikvision statements, depictions, and other documentation)” are
`illustrative examples of statements, depictions, and other documentation that help one understand
`and put into context the evidence for each claim element.
`
`3
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`
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`• “Use a network cable to connect the device to the RJ-45 port of a peer device such
`
`
`
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`as network camera, NVR, switch, etc.”
`
`4
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`
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`Case 2:22-cv-08050-CJC-JDE Document 23-5 Filed 04/18/23 Page 6 of 33 Page ID #:195
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`
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`• “Ports 1-16/24 support IEEE 802.3af and IEEE 802.3at PoE supply, and the PD
`
`can be wireless AP, IP phone or IP camera, etc. By default, PoE features of Ports
`
`1-16/24 are enabled.”
`
`
`
`802.3af, 802.3at, and 802.3-2008 Standards statements and depictions includes:
`
`• “Abstract: Support for optionally powering a 10BASE-T, 100BASE-TX or
`
`1000BASE-T DTE device via the Power Interface (PI) using physical layers
`
`defined in Clauses 14, 25, and 40. The Power Sourcing Equipment (PSE) is
`
`located at an endpoint or midspan, separate from and between the MDIs, and
`
`provides power to the Powered Device (PD) over the Link Section.” (IEEE
`
`802.3af Standard Abstract);
`
`• “DTE powering is intended to provide a single 10BASE-T, 100BASE-TX, or
`
`1000BASE-T device with a unified interface for both the data it requires and
`
`the power to process these data.” (IEEE 802.3af Standard Definition 1.4x
`
`(PSE));
`
`• “DTE powering is intended to provide a 10BASE-T, 100BASE-TX, or
`
`1000BASE-T device with a single interface to both the data it requires and the
`
`power to process this data.” (IEEE 802.3af Standard 33.1); (IEEE 802.3at
`
`Standard 33.1).
`
`The IEEE 802.3af and IEEE 802.3at Standards extend prior 802.3 Ethernet standards
`
`to support methods and interfaces for remotely powering access equipment (i.e.,
`
`powered devices) in a data network, e.g., 10BASE-T, 100BASE-TX, or 1000BASE-T
`
`networks.
`
`
`
`Identification: The preamble is a method for (a) “remotely powering access
`
`equipment,” (b) “in a data network.”
`
`•
`
`(a) remotely powering access equipment: Power sourcing equipment (data
`
`nodes, addressed below), made by Hikvision or others, combined with powered
`
`
`
`
`5
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`
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`
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`devices (access devices, addressed below), made by Hikvision or others, are
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`used to practice a method for remotely powering access equipment (the
`
`powered devices, access devices) as addressed in elements [a] through [d]
`
`below. The “access equipment” is the powered devices (access devices) that
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`access data and power through a network. Examples of such access equipment
`
`include (a) phones (e.g., IP phones), (b) wireless access points, and (c) cameras.
`
`•
`
`(b) in a data network: The “data network” refers to the Ethernet network that
`
`transmits data and power between power sourcing equipment (data nodes) and
`
`powered devices (access devices).
`
`
`
`[a-1] providing a
`
`Sample evidence (Hikvision statements, depictions, and other documentation) includes:
`
`data node adapted
`
`•
`
`
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`for data switching
`
`• “DS-3E0xxxP-E/M Series unmanaged PoE Ethernet Switches are the ideal
`
`field switches for powering your Hikvision cameras.”
`
`
`
`
`6
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`
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`• “DS-3E1XXXP series switches (hereinafter referred to as ‘the device’) are
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`layer 2 PoE switches, providing advanced PoE power supply technology on
`
`the basis of high-performance access.”
`
`
`
`802.3af, 802.3at, and 802.3-2008 Standards statements and depictions include:
`
`• “Power sourcing equipment. PSE, as the name implies, is the equipment
`
`that provides the power to a single link section. The PSE’s main functions
`
`are to search the link section for a PD, optionally classify the PD, supply
`
`power to the link section (only if a PD is detected), monitor the power on
`
`the link section, and scale power back to the detect level when power is no
`
`longer requested or required.” (IEEE 802.3af Standard 33.2); (IEEE 802.3-
`
`2008 Standard 33.2);
`
`
`
`
`7
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`
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`Case 2:22-cv-08050-CJC-JDE Document 23-5 Filed 04/18/23 Page 9 of 33 Page ID #:198
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`
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`
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`(IEEE 802.3af Standard Figure 33-4); (IEEE802.3-2008 Standard Figure 33-4);
`
`(IEEE 802.3at Standard Figure 33-4);
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`(IEEE 802.3at Standard Figure 33-5);
`
`
`
`
`
`
`
`
`
`
`8
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`
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`#:199
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`
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`(IEEE 802.3at Standard Figure 33-7);
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`• “The PSE is the portion of the end station or midspan equipment that
`
`provides the power to a single PD. The PSE’s main functions are as
`
`follows: — To search the link section for a PD — To supply power to the
`
`detected PD through the link section — To monitor the power on the link
`
`section — To remove power when no longer requested or required,
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`returning to the searching state.” (IEEE 802.3at Standard 33.2).
`
`Under the IEEE 802.3af and 802.3at standards, Hikvision’s switches are Endpoint
`
`PSEs (power sourcing equipment) which are data nodes adapted for switching.
`
`
`
`Identification: The “data node adapted for data switching” is each Hikvision Power
`
`over Ethernet switch or hub and each Power over Ethernet switch or hub made by
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`
`
`
`9
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`others used in connection with Hikvision’s powered devices (access devices).
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`Hikvision’s Power over Ethernet switches or hubs, and the switches or hubs made by
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`others, have multiple ports (e.g., 8-ports, 24-ports) and can switch data between ports,
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`providing switching functionality.
`
`
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`[a-2] an access
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`Sample evidence (Hikvision statements, depictions, and other documentation) includes:
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`device adapted for
`
`data transmission
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`• “The PoE interfaces enables the NVR system to pass electrical power
`
`safely, along with data, on Ethernet cabling to the connected network
`
`cameras. Up to 4 network cameras can be connected to /4P models, 8
`
`network cameras to /8P models, and 16 network cameras to /16P models.”
`
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`10
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`Case 2:22-cv-08050-CJC-JDE Document 23-5 Filed 04/18/23 Page 12 of 33 Page ID
`#:201
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`802.3af, 802.3at, and 802.3-2008 Standards statements and depictions include:
`
`
`
`(IEEE 802.3af Standard Figure 33-4);
`
`(IEEE802.3-2008 Standard Figure 33-4); (IEEE 802.3at Standard Figure 33-4);
`
`(IEEE 802.3at Standard Figure 33-5);
`
`• “A PD designed to the standard, and within its range of available power, can
`
`obtain both power and data for operation through the MDI and therefore need
`
`
`
`
`11
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`
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`#:202
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`no additional connections.” (IEEE 802.3af Standard 33.1.1); (IEEE 802.3-2008
`
`Standard 33.1.1); (IEEE 802.3at Standard 33.1.1.).
`
`The Hikvision power sourcing equipment (data nodes) are specifically designed for use
`
`with IEEE 802.3af and IEEE 802.3at compliant powered devices (access devices).
`
`The Hikvision powered devices (access devices) are 802.3af and 802.3at compliant
`
`powered devices (access devices). Under the 802.3af and 802.3at Standards, the
`
`Powered End Station—powered device (PD)—is an access device adapted for data
`
`transmission.
`
`
`
`Identification: The “access device adapted for data transmission” is each of the
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`powered devices (access devices) made by Hikvision or others, that are used in
`
`conjunction with the power sourcing equipment (data nodes, addressed above) made
`
`by Hikvision or others, that can receive and transmit data. Non-limiting examples of
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`such access devices include (a) phones (including IP phones), (b) wireless access
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`points, and (c) cameras (e.g., security cameras).
`
`
`
`[a-3] at least one
`
`Sample evidence (Hikvision statements, depictions, and other documentation) includes:
`
`data signaling pair
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`• “Use a network cable to connect the device to the RJ-45 port of a peer
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`connected between
`
`device such as network camera, NVR, switch, etc.).”
`
`the data node and
`
`•
`
` “Connect the switch to a remote device with Ethernet cable via RJ45 port.”
`
`the access device
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`• “Cat 5e or better Ethernet cable is recommended.”
`
`and arranged to
`
`• “The PoE interfaces enables the NVR system to pass electrical power
`
`transmit data
`
`therebetween
`
`safely, along with data, on Ethernet cabling to the connected network
`
`cameras. Up to 4 network cameras can be connected to /4P models, 8
`
`network cameras to /8P models, and 16 network cameras to /16P models.”
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`
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`12
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`Case 2:22-cv-08050-CJC-JDE Document 23-5 Filed 04/18/23 Page 14 of 33 Page ID
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`802.3af, 802.3at, and 802.3-2008 Standards statements and depictions include:
`
`
`
`(IEEE 802.3af Standard Table 33-1 and Figure 33-5); (IEEE 802.3-2008
`
`Standard Table 33-1 and Figure 33-5); (IEEE 802.3at Standard Table 33-2 and
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`Figure 33-8);
`
`(IEEE 802.3af Standard Figure 33-4);
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`
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`13
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`
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`Case 2:22-cv-08050-CJC-JDE Document 23-5 Filed 04/18/23 Page 15 of 33 Page ID
`#:204
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`(IEEE 802.3at Standard Figure 33-5);
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`• “PI pin assignments. A PSE device may provide power via one of two valid
`
`four-wire connections. In each four-wire connection, the two conductors
`
`associated with a pair each carry the same nominal current in both magnitude
`
`and polarity. For the purposes of data transfer, the type of PSE data port is
`
`relevant to the far-end PD and in some cases to the cabling system between
`
`them.” (IEEE 802.3af Standard 33.2.2); (IEEE 802.3-2008 Standard 33.2.2);
`
`(IEEE 802.3at Standard 33.2.3).
`
`Hikvision’s power sourcing equipment (data nodes) are designed to be connected to
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`IEEE 802.3af and IEEE 802.3at compliant access devices via a cable with at least one
`
`data signaling pair (e.g., a Category 5 cable). The data signaling pair is defined as the
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`twisted pair medium that connects the medium dependent interface (MDI) on the PSE
`
`to the MDI on the PD. As the 802.3af Standard was designed for 10Base-T, 100Base-
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`TX, and 1000Base-T, this is 2 pair or greater Category 3, 4, 5, 5e or better cable
`
`
`
`
`14
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`
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`designed and installed for data transmission. Under the 802.3af and 802.3at Standards,
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`the interface of the data signaling pair is referred to as the twisted pair medium
`
`dependent interface that connects to the line transformer data pairs as shown in Figure
`
`33-4 of the standards. Table 33-1 details the particular pins that may be used by the
`
`data pairs.
`
`
`
`Identification: The “at least one data signaling pair connected between the data node
`
`and the access device and arranged to transmit data therebetween” is a pair of wires in
`
`an Ethernet cable arranged to connect and transmit data and power between data nodes
`
`(addressed above) and access devices (addressed above). A non-limiting example of
`
`such a data signaling pair is a pair of twisted wires found in a Category 5 (CAT-5)
`
`Ethernet cable used to transmit data and power. In this example, a data signaling pair
`
`can be the pair of wires that connect pins 1 and 2 of the RJ-45 connector of the power
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`sourcing equipment (data node) to the corresponding pins of the powered device
`
`(access device).
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`
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`[a-4] a main power
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`Sample evidence (Hikvision statements, depictions, and other documentation) includes:
`
`source connected to
`
`supply power to the
`
`data node, and
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`
`
`
`
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`15
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`• “Use the power cord in the package to power on the device.”
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`• “Used for connecting the included power cord for power supply. Please use the
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`included power cord to connect the device to power supply.”
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`
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`
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`802.3af, 802.3at, and 802.3-2008 Standards statements and depictions include:
`
`• “PSE, as the name implies, is the equipment that provides the power to a single
`
`link section.” (IEEE 802.3af Standard 33.2); (IEEE 802.3-2008 Standard
`
`33.2);
`
`• “The PSE is the portion of the end station or midspan equipment that provides
`
`the power to a single PD.” (IEEE 802.3at Standard).
`
`Hikvision’s IEEE 802.3af and IEEE 802.3at compliant power sourcing equipment,
`
`which needs power to function, is powered by a main power source. The IEEE 802.3af
`
`and IEEE 802.3at Standards do not specify particular requirements for the main power
`
`source, but such a main power source is necessary for the power sourcing equipment
`
`(PSE) to function.
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`
`
`Identification:
`
`The Federal Circuit construed “main power source” broadly as any source of power,
`
`including “both AC and DC power sources.” Network-1 Techs. v. Hewlett-Packard
`
`Co., 976 F.3d 1301, 1310 (Fed. Cir. 2020). Hikvision’s power sourcing equipment
`
`(data nodes), and the power sourcing equipment (data nodes) made by others used in
`
`
`
`
`16
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`connection with Hikvision’s powered devices (access devices), have access to “a main
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`power source connected to supply power to the data node.” There are three
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`identifications under which the “main power source” is connected, via electrical
`
`connections, wiring, or cables, to supply certain power requirements to at least certain
`
`electrical components of the data nodes:
`
`•
`
`Identification 1: The “main power source” that supplies power to the power
`
`sourcing equipment (data nodes, addressed above) is a DC power supply 7
`
`that provides DC power to components of the data node. A non-limiting
`
`example of such a DC power supply is a power supply that provides 12V and
`
`48V outputs to power components of the data node.
`
`•
`
`Identification 2: The “main power source” is a combination of power
`
`supplies, arranged in series or parallel, that provide DC power to
`
`components of the data node. As a non-limiting example, the combination
`
`of power supplies can consist of (1) a power supply that provides a 12V
`
`output to power some components of the data node, and (2) a power supply
`
`that provides a 48V output to power other components of the data node. The
`
`“main power source” can be, or be connected to receive power from, a
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`power rack.
`
`•
`
`Identification 3: The “main power source” is an AC power source provided
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`via a power cord that is adapted to connect an AC outlet to the power
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`sourcing equipment (data nodes). The connection can be established by, for
`
`example, plugging one end of the power cord into a dedicated grounded AC
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`outlet or power strip and the other end into the AC power socket of the data
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`node. 8
`
`
`7
`A power supply is a collection of electronic circuitry or components used to convert
`voltages and currents.
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` 8
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`For example, switches and routers (data nodes) are often sold with a power cord adapted
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`for connection to an AC outlet, either directly or using an external power supply, connected to
`
`17
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`[a-5] a secondary
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`Sample evidence (Hikvision statements, depictions, and other documentation) includes:
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`power source
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`
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`arranged to supply
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`power from the
`
`data node via said
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`data signaling pair
`
`to the access
`
`device,
`
`802.3af, 802.3at, and 802.3-2008 Standards statements and depictions include:
`
`
`
`(IEEE 802.3af Standard Figure 33-4);
`
`(IEEE 802.3-2008 Standard Figure 33-4); (IEEE 802.3at Standard Figure 33-
`
`4);
`
`
`supply main power to the switches and routers (and to semiconductor logic circuits within the
`switch).
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`
`
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`18
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`(IEEE 802.3at Standard Figure 33-5);
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`• “DTE powering is intended to provide a 10BASE-T, 100BASE-TX, or
`
`1000BASE –T devices with a single interface to both the data it requires
`
`and the power to process this data. This clause specifies the following
`
`a) A power source to add power to the 100 Ω balanced cabling system.”
`
`(IEEE 802.3-2008 Standard 33.1); (IEEE 802.at Standard 33.1.1).
`
`• “33.2.8.4 Maximum output current in normal powering mode at PSE
`
`min output voltage. For VPort > 44V, the minimum value for IPort_max in
`
`Table 33–5 shall be 15.4W/VPort. The current IPort_max ensures 15.4W
`
`min output power.” (IEEE 802.3af Standard 33.2.8.4); (IEEE 802.3-
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`2008 Standard 33.2.8.4);
`
`• “33.2.8.1 Output voltage. The specification for VPort in Table 33–5
`
`shall include line and temperature variations. The voltage potential
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`shall be measured between any conductor of one power pair and any
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`conductor of the other power pair.” (IEEE 802.3af Standard 33.2.8.1);
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`(IEEE 802.3-2008 Standard 33.2.8.1);
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` (IEEE 802.3at Standard Table 33-11);
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`• “When the PSE provides power to the PI, it shall conform with Table
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`33-11.” (IEEE 802.3at at 33.2.7).
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`Hikvision’s IEEE 802.3af and IEEE 802.at compliant power sourcing equipment have
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`a source of secondary power which provides operating power from the Switch/Hub
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`(the Power Sourcing Equipment (PSE)) to the Powered End Station (Powered Device
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`(PD)).
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`
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`Identification: Hikvision’s power sourcing equipment (data nodes, addressed above),
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`and the power sourcing equipment (data nodes) made by others used in connection
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`with Hikvision’s powered devices (access devices), use “a secondary power source
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`arranged to supply power from the data node via said data signaling pair to the access
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`device.” When a properly configured powered device (access device, addressed
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`above) is detected, the secondary power source supplies power (for example (non-
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`limiting), 48 Volts DC for an access device that requires such a power load) from the
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`power sourcing equipment (data node, addressed above) through the data signaling
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`pairs (addressed above, e.g., Ethernet Category 5 cables) to the powered device (access
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`device) to supply operating power to the powered device (access device).
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`The power sourcing equipment (data nodes) incorporate a control valve or
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`switch (which may be part of an integrated circuit) that controls the application of
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`power to the access device derived from the main power source (addressed above).
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`The control valve or switch (for example (non-limiting), a MOSFET switch or other
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`transistor) is electrically located between the main power source and the access device,
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`and is a downstream or separate driving point from the main power source, for the
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`function of providing operating power to the powered device (access device).
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`[b] delivering a low
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`Sample evidence (Hikvision statements, depictions, and other documentation) includes:
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`level current from
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`•
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` “PoE Standard IEEE802.3af, IEEE802.3at”
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`said main power
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`• “Compliant with IEEE802.3at/af”
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`source to the access
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`
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`device over said
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`802.3af, 802.3at, and 802.3-2008 Standards statements and depictions include:
`
`data signaling pair,
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`• “The PSE probes the link section in order to detect a valid PD detection
`
`signature.” (IEEE 802.3af Standard 33.2.6); (IEEE 802.3-2008
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`Standard 33.2.6);
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`• “The PSE shall detect the PD by probing via the PSE PI.” (IEEE
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`802.3af Standard 33.2.5); (IEEE 802.3-2008 Standard 33.2.5);
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`• “The detection voltage Vdetect shall be within the VValid voltage range at
`
`the PSE PI as specified in Table 33–2 with a valid PD detection
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`signature connected.” (IEEE 802.3af Standard 33.2.5.1); (IEEE 802.3-
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`2008 Standard 33.2.5.1);
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`(IEEE 802.3af Standard Table 33-2);
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`(IEEE 802.3-2008 Standard Table 33-2);
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`(IEEE 802.3at Standard Table 33-4);
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`• “The PSE probes the link section in order to detect a valid PD detection
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`signature. The PSE PI is connected to a PD through a link segment.”
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`(IEEE 802.3at Standard 33.2.);
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`• “The detection voltage at the PSE PI shall be within the Vvalid voltage
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`range (as specified in Table 33-4) with a valid PD detection signature
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`connected (as specified in Table 33-14).” (IEEE 802.3at Standard
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`33.2.5.2);
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`• “The open circuit voltage and short circuit current shall meet the
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`specifications in Table 33–2.” (IEEE 802.3af Standard 33.2.5).
`
`Hikvision’s IEEE 802.3af and IEEE 802.3at compliant power sourcing equipment
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`contains circuitry that delivers a low level current (detection probe) to the access
`
`device over the data signaling pairs via a PD detection signature.
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`
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`Identification: The Federal Circuit construed “low level current” as “a non-data-signal
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`current that is sufficient to begin start up of the access device but that is not sufficient
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`to sustain the start up.” Network-1 Techs. v. Hewlett-Packard Co., 976 F.3d 1301,
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`1309 (Fed. Cir. 2020). The low level current delivered from the main power source
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`(addressed above) to the access device (powered device, addressed above) over the
`
`data signaling pair (addressed above) is the detection current (for example (non-
`
`limiting), in the range of 10 to 500 micro amps), that is used (as opposed to a data
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`signal) to determine whether the access device (powered device) can receive operating
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`power.
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`
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`[c] sensing a
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`Sample evidence (Hikvision statements, depictions, and other documentation) include:
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`voltage level on the
`
`• “PoE Standard IEEE802.3af, IEEE802.3at”
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`data signaling pair
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`• “Compliant with IEEE802.3at/af”
`
`in response to the
`
`
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`low level current
`
`802.3af, 802.3at, and 802.3-2008 Standards statements and depictions include:
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`24
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`(IEEE 802.3af Standard Table 33-2);
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`(IEEE 802.3-2008 Standard Table 33-2);
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`• “33.2.5.1 Detection probe requirements. The detection voltage Vdetect
`
`shall be within the Vvalid voltage range at the PSE PI as specified in
`
`Table 33-2 with a valid PD detection signature connected. The PSE
`
`shall make at least two measurements with Vdetect values that create at
`
`least a Vtest difference as specified in Table 33-2 between the two
`
`measurements with a valid PD detection signature connected.” (IEEE
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`802.3af Standard 33.5.1); (IEEE 802.3-2008 Standard 33.2.5.1);
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`(IEEE 802.3at Standard Table 33-5);
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`•
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` “The detection voltage at the PSE PI shall be within the Vvalid voltage
`
`range (as specified in Table 33-4) with a valid PD detection signature
`
`connected (as specified in Table 33-14). In evaluating the presence of a
`
`valid PD, the PSE shall make at least two measurements with VPSE
`
`values that create at least a ∆Vtest difference as specified in Table 33-4.
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`An effective resistance is calculated from two voltage/current
`
`measurements made during the detection process.” (IEEE 802.3at
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`Standard 33.2.5.2).
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`Hikvision’s IEEE 802.3af and 802.3at compliant power sourcing equipment contain
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`circuitry that senses a resulting voltage (detection signature) once a powered device
`
`(access devices) has been detected on the data signaling pair.
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`
`
`Identification: Hikvision’s power sourcing equipment (data nodes, addressed above),
`
`and the power sourcing equipment of others used in connection with Hikvision’s
`
`powered devices (access devices), includes an integrated circuit that contains circuitry
`
`that senses a voltage level or current level on the data signaling pair (addressed above),
`
`e.g., the signature of the powered device (access device), in response to the low level
`
`current (addressed above) delivered on (or applied to) the data signaling pair.
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`
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`[d] controlling
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`Sample evidence (Hikvision statements, depictions, and other documentation) include:
`
`power supplied by
`
`•
`
` “PoE Standard IEEE802.3af, IEEE802.3at”
`
`said secondary
`
`• “Compliant with IEEE802.3at/af”
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`power source to
`
`
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`said access device
`
`802.3af, 802.3at, and 802.3-2008 Standards statements and depictions include:
`
`in response to a
`
`• “In an operation mode, the PSE shall not apply operating power to the
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`preselected
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`PI until the PSE has successfully detected a PD requesting power”
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`condition of said
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`(IEEE 802.3-2008 Standard 33.2.4);
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`voltage level.
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`• “33.2.5.1 Detection probe requirements. The detection voltage Vdetect
`
`shall be within the Vvalid voltage range at the PSE PI as specified in
`
`Table 33-2 with a valid PD detection signature connected. The PSE
`
`shall make at least two measurements with Vdetect values that create at
`
`least a Vtest difference as specified in Table 33-2 between the two
`
`measurements with a valid PD detection signature connected.” (IEEE
`
`802.3af Standard 33.5.1); (IEEE 802.3-2008 Standard 33.2.5.1);
`
`(IEEE 802.3af Standard Table 33-2);
`
`(IEEE 802.3-2008 Standard Table 33-2);
`
`• “The detection voltage at the PSE PI shall be within the Vvalid voltage
`
`range (as specified in Table 33-4) with a valid PD detection signature
`
`connected (as specified in Table 33-14). In evaluating the presence of a
`
`valid PD, the PSE shall make at least two measurements with VPSE
`
`values that create at least a ∆Vtest difference as specified in Table 33-4.
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`An effective resistance is calculated from two voltage/current
`
`measurements made during the detection process.” (IEEE 802.3at
`
`Standard 33.2.5.2);
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`• “A PSE shall accept as a valid signature a link section with both of the
`
`following characteristics between the powering pairs with an offset
`
`voltage up to Vos max and an offset current up to Ios max, as specified in
`
`Table 33-5: a) Signature resistant Rgood, and b) Parallel signature
`
`capacitance Cgood.” (IEEE 802.3at Standard, 33.2.5.2);
`
`• “A PSE shall accept as a valid signature a link section with both of the
`
`following characteristics between the powering pairs with an offset
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`voltage up to Vos max and an offset current up to I max, as specified in
`
`Table 33–2: a) Signature resistance Rgood, and b) Parallel signature
`
`capacitance Cgood.