Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 1 of 24
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`Exhibit 5
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 2 of 24
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`BELL NORTHERN RESEARCH LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
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`
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`U.S. Patent No. 6,696,941 – HMD America, Inc. and HMD Global Oy
`Claims 1, 3, 6, 10, 12, 15
`Bell Northern Research, LLC (“BNR”) provides evidence of infringement of at least claims 1, 3, 6, 10, 12, and 15 of U.S. Patent No.
`6,696,941 (hereinafter “the ’941 patent”) by HMD America, Inc. and HMD Global Oy (“Defendant”). In support thereof, BNR provides the
`following claim charts.
`“Accused Instrumentalities” as used herein refers to at least the Nokia 8.3 5G, Nokia XR20, Nokia G10, Nokia G20, Nokia G50, and the Nokia
`9 PureView. These claim charts demonstrate Defendant’s infringement by comparing each element of the asserted claims to corresponding components,
`aspects, and/or features of the Accused Instrumentalities. These claim charts are not intended to constitute an expert report on infringement. These
`claim charts include information provided by way of example, and not by way of limitation.
`The analysis set forth below is based only upon information from publicly available resources regarding the Accused Instrumentalities, as
`Defendant has not yet provided any non-public information. An analysis of Defendant’s (or other third parties’) technical documentation and/or
`software source code may assist in fully identifying all infringing features and functionalities. Accordingly, BNR reserves the right to supplement this
`infringement analysis once such information is made available to BNR. Furthermore, BNR reserves the right to revise this infringement analysis, as
`appropriate, upon issuance of a court order construing any terms recited in the asserted claims.
`BNR provides this evidence of infringement and related analysis without the benefit of claim construction or expert reports or discovery. BNR
`reserves the right to supplement, amend or otherwise modify this analysis and/or evidence based on any such claim construction or expert reports or
`discovery.
`
`Unless otherwise noted, BNR contends that Defendant directly infringes the ’941 patent in violation of 35 U.S.C. § 271(a) by selling, offering
`to sell, making, using, and/or importing the Accused Instrumentalities. The following exemplary analysis demonstrates that infringement. Unless
`otherwise noted, BNR further contends that the evidence below supports a finding of indirect infringement under 35 U.S.C. §§ 271(b) and/or (c), in
`conjunction with other evidence of liability under one or more of those subsections. Defendant makes, uses, sells, imports, or offers for sale in the
`United States, or has made, used, sold, imported, or offered for sale in the past, without authority, or induces others to make, use, sell, import, or offer
`for sale in the United States, or has induced others to make, use, sell, import, or offer for sale in the past, without authority products, equipment, or
`services that infringe claims 1, 3, 6, 10, 12, and 15 of the ’941 patent, including without limitation, the Accused Instrumentalities.
`
`Unless otherwise noted, BNR believes and contends that each element of each claim asserted herein is literally met through Defendant’s
`provision of the Accused Instrumentalities. However, to the extent that Defendant attempts to allege that any asserted claim element is not literally
`met, BNR believes and contends that such elements are met under the doctrine of equivalents. More specifically, in its investigation and analysis of
`the Accused Instrumentalities, BNR did not identify any substantial differences between the elements of the patent claims and the corresponding
`features of the Accused Instrumentalities, as set forth herein. In each instance, the identified feature of the Accused Instrumentalities performs at
`least substantially the same function in substantially the same way to achieve substantially the same result as the corresponding claim element.
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`

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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 3 of 24
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`BELL NORTHERN RESEARCH LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`To the extent the chart of an asserted claim relies on evidence about certain specifically identified Accused Instrumentalities, BNR asserts that,
`on information and belief, any similarly functioning instrumentalities also infringe the charted claim. BNR reserves the right to amend this infringement
`analysis based on other products made, used, sold, imported, or offered for sale by Defendant. BNR also reserves the right to amend this infringement
`analysis by citing other claims of the ’941 patent, not listed in the claim chart, that are infringed by the Accused Instrumentalities. BNR further reserves
`the right to amend this infringement analysis by adding, subtracting, or otherwise modifying content in the “Accused Instrumentalities” column of each
`chart.
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 4 of 24
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`BELL NORTHERN RESEARCH LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
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`Claim 1
`
`1. A method of
`remotely
`triggering an alarm
`within a mobile
`wireless device,
`said method
`comprising:
`
`Accused Instrumentalities
`The preamble is not limiting. To the extent that the preamble is considered limiting, the Accused
`Instrumentalities include a method of remotely triggering an alarm within a mobile wireless device.
`
`For example, the Nokia 8.3 5G is a mobile wireless device and includes a method of remotely triggering an
`alarm.
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 5 of 24
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`BELL NORTHERN RESEARCH LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
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`Source: https://www.nokia.com/phones/en_int/nokia-8-3-5g/specs?sku=HQ5020JB37000 (last visited Feb 3,
`2023).
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 6 of 24
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`BELL NORTHERN RESEARCH LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`The Accused Instrumentalities include receiving an alarm trigger signal from a service provider to said mobile
`wireless device based on user authorization.
`
`For example, the Nokia 8.3 5G includes receiving an alarm trigger signal from a service provider to said
`mobile wireless device based on user authorization, as shown below.
`
`[i] receiving an
`alarm trigger
`signal from a
`service provider to
`said mobile
`wireless device
`based on user
`authorization; and
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 7 of 24
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`BELL NORTHERN RESEARCH LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
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`Further, the user authorization for receiving an alarm trigger signal from a service provider to said mobile
`wireless device is shown below.
`
`Select
`Security
`
`Select Find
`My Device
`
`Authorize
`Find My
`Device
`
`
`
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`
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`
`
`Authorized
`device for
`receiving
`alarm
`triggers
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 8 of 24
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`BELL NORTHERN RESEARCH LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`The Accused Instrumentalities include triggering a sensory output from said mobile wireless device based on
`receipt of said alarm trigger signal from said service provider.
`
`For example, the Nokia 8.3 5G includes triggering a sensory output from said mobile wireless device based
`on receipt of said alarm trigger signal from said service provider, as shown below.
`
`
`[ii] triggering a
`sensory output
`from said mobile
`wireless device
`based on receipt of
`said alarm trigger
`signal from said
`service provider;
`and
`
`Unlocked
`phone
`
`
`Receipt of
`Attempt to
`Triggers
`
`alarm trigger
`open phone
`sensory
`
`locks phone
`output
`
`
`The Accused Instrumentalities include preventing a current holder of said mobile wireless device from
`
`
`stopping said sensory output unless an alarm PIN is manually entered by said holder into said mobile wireless
`device.
`
`For example, the Nokia 8.3 5G includes preventing a current holder of said mobile wireless device from
`stopping said sensory output unless an alarm PIN is manually entered by said holder into said mobile wireless
`device, as shown below.
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`[iii] preventing a
`current holder of
`said mobile
`wireless device
`from stopping said
`sensory output
`unless an alarm
`PIN is manually
`entered by said
`
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`February 7, 2023
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 9 of 24
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`BELL NORTHERN RESEARCH LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
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`holder into said
`mobile wireless
`device.
`
`
`
`
`
`Sensory
`output
`
`
`User enters
`
`PIN
`
`Phone
`unlocks
`
`
`
`Claim 3
`3. The method of
`remotely
`triggering an alarm
`within a mobile
`wireless device
`according to claim
`1, wherein:
`
`said sensory
`output is a visible
`alarm on a display.
`
`Accused Instrumentalities
`
`See claim 1.
`
`The Accused Instrumentalities include the method of remotely triggering an alarm within a mobile wireless
`device according to claim 1.
`
`For example, the Nokia 8.3 5G is a mobile wireless device that includes the remotely triggering means for an
`alarm within a mobile wireless device according to claim 1.
`
`See claim 1[ii].
`
`The Accused Instrumentalities include said sensory output is a visible alarm on a display.
`
`For example, the Nokia 8.3 5G includes said sensory output is a visible alarm on a display, as shown below.
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 10 of
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`BELL NORTHERN RESEARCH LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
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`
`
`Sensory
`output
`
`
`
`
`Sensory
`output
`
`
`
`Accused Instrumentalities
`
`See claim 1.
`
`The Accused Instrumentalities include the method of remotely triggering an alarm within a mobile wireless
`device according to claim 1.
`
`For example, the Nokia 8.3 5G is a mobile wireless device and includes the method of remotely triggering an
`alarm within a mobile wireless device according to claim 1.
`
`See claim 1.
`
`The Accused Instrumentalities include said mobile device is a wireless phone.
`For example, the Nokia 8.3 5G is a wireless phone, as shown below.
`
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`Claim 6
`6. The method of
`remotely
`triggering an alarm
`within a mobile
`wireless device
`according to claim
`1, wherein:
`
`said mobile
`wireless device is
`a wireless phone.
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`February 7, 2023
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 11 of
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`BELL NORTHERN RESEARCH LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
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`Source: https://www.nokia.com/phones/en_int/nokia-8-3-5g/specs?sku=HQ5020JB37000 (last visited Feb 3,
`2023).
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 12 of
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`BELL NORTHERN RESEARCH LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
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`
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`Source: https://www.nokia.com/phones/en_int/nokia-8-3-5g/specs?sku=HQ5020JB37000 (last visited Feb 3,
`2023).
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 13 of
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`
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`Claim 10
`10. A remotely
`triggering means
`for an alarm within
`a mobile wireless
`device comprising:
`
`Accused Instrumentalities
`The preamble is not limiting. To the extent that the preamble is considered limiting, the Accused
`Instrumentalities include a remotely triggering means for an alarm within a mobile wireless device.
`
`For example, the Nokia 8.3 5G includes a remotely triggering means for an alarm within a mobile wireless
`device.
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 15 of
`24
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`Source: https://www.nokia.com/phones/en_int/nokia-8-3-5g/specs?sku=HQ5020JB37000 (last visited Feb 3,
`2023).
`
`The Accused Instrumentalities include a means for receiving an alarm trigger signal from a service provider
`to said mobile wireless device based on user authorization.
`
`For example, the Nokia 8.3 5G includes a means for receiving an alarm trigger signal from a service provider
`to said mobile wireless device based on user authorization, as shown below.
`
`[i] means for
`receiving an alarm
`trigger signal from
`a service provider
`to said mobile
`wireless device
`based on user
`authorization; and
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 17 of
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`Further, the user authorization for receiving an alarm trigger signal from a service provider to said mobile
`wireless device is shown below.
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 18 of
`24
`
`
`Authorize
`Find My
`Device
`
`
`
`
`Authorized
`
`device for
`
`receiving
`
`alarm
`
`triggers
`
`The Accused Instrumentalities include a means for triggering a sensory output based on receipt of said alarm
`trigger signal from said service provider.
`
`For example, the Nokia 8.3 5G includes a means for triggering a sensory output based on receipt of said alarm
`trigger signal from said service provider, as shown below.
`
`
`Select
`Security
`
`Select Find
`My Device
`
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`[ii] means for
`triggering a
`sensory output
`based on receipt of
`said alarm trigger
`signal from said
`service provider;
`and
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`February 7, 2023
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 19 of
`24
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`
`
`
`
`
`Unlocked
`phone
`
`Receipt of
`Attempt to
`Triggers
`alarm trigger
`open phone
`sensory
`locks phone
`
`output
`
`
`
`
`The Accused Instrumentalities include a means for preventing a current holder of said mobile wireless device
`from stopping said sensory output unless an alarm PIN is manually entered by said holder into said mobile
`wireless device.
`
`For example, the Nokia 8.3 5G includes a means for preventing a current holder of said mobile wireless
`device from stopping said sensory output unless an alarm PIN is manually entered by said holder into said
`mobile wireless device.
`
`
`
`[iii] means for
`preventing a
`current holder of
`said mobile
`wireless device
`from stopping said
`sensory output
`unless an alarm
`PIN is manually
`entered by said
`holder into said
`
`
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 20 of
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`mobile wireless
`device.
`
`Sensory
`output
`
`
`User enters
`
`PIN
`
`
`Phone
`unlocks
`
`
`
`
`
`Accused Instrumentalities
`
`See claim 10.
`
`The Accused Instrumentalities include the remotely triggering means for an alarm within a mobile wireless
`device according to claim 10.
`
`For example, the Nokia 8.3 5G is a mobile wireless device that includes the remotely triggering means for an
`alarm within a mobile wireless device according to claim 10.
`
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`Claim 12
`12. The remotely
`triggering means
`for an alarm within
`a mobile wireless
`device according
`to claim 10,
`wherein:
`
`
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`February 7, 2023
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 21 of
`24
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`
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`said sensory
`output is a visible
`alarm on a display.
`
`See claim 10[ii].
`
`The Accused Instrumentalities include said sensory output is a visible alarm on a display.
`
`For example, the Nokia 8.3 5G includes said sensory output is a visible alarm on a display, as shown below.
`
`
`
`
`See claim 10.
`
`
`
`
`Claim 15
`15. The remotely
`triggering means
`for an alarm within
`
`
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`February 7, 2023
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`Sensory
`output
`
`Sensory
`output
`
`
`
`
`
`
`
`Accused Instrumentalities
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`a mobile wireless
`device according
`to claim 10,
`wherein:
`
`said mobile
`wireless device is
`a wireless phone.
`
`The Accused Instrumentalities include the remotely triggering means for an alarm within a mobile wireless
`device according to claim 10.
`
`For example, the Nokia 8.3 5G is a mobile wireless device and includes the remotely triggering means for an
`alarm within a mobile wireless device according to claim 10.
`
`
`The Accused Instrumentalities include said mobile wireless device is a wireless phone.
`
`For example, the Nokia 8.3 5G is a wireless phone, as shown below.
`
`
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 23 of
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`Source: https://www.nokia.com/phones/en_int/nokia-8-3-5g/specs?sku=HQ5020JB37000 (last visited Feb 3,
`2023).
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`Case 1:22-cv-22706-RNS Document 154-5 Entered on FLSD Docket 03/14/2023 Page 24 of
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`Source: https://www.nokia.com/phones/en_int/nokia-8-3-5g/specs?sku=HQ5020JB37000 (last visited Feb 3,
`2023).
`
`
`
`
`Caveat: The notes and/or cited excerpts utilized herein are set forth for illustrative purposes only and are not meant to be limiting in
`any manner. For example, the notes and/or cited excerpts, may or may not be supplemented or substituted with different excerpt(s) of
`the relevant reference(s), as appropriate. Further, to the extent any error(s) and/or omission(s) exist herein, all rights are reserved to
`correct the same.
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