Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 1 of 35
`
`      
`Exhibit  A  
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 2 of 35
`Case 1:16—cv-O4110-TWT Document 41-1 Filed 11/07/17 Page 2 of 35
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`APPENDIX A
`
`APPENDIX A
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 3 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Plaintiff Ironburg Inventions Ltd.’s Preliminary Infringement Contentions
`U.S. Patent No. 8,641,525
`Ironburg Inventions Ltd. v. Collective Minds, Case No. 1:16-cv-04110-TWT
`
`
`
`
`US Patent No. 8,641,525
`Asserted Claims
`1. A hand held controller for a game
`console comprising:
`
`Infringing Product
`
`The Collective Minds Strike Pack controller (hereafter “SP”), as shown in the illustration
`on Collective Minds packaging (image from sales on Amazon.com by Collective Minds)
`is a hand held controller for a game console.
`
`Source: Amazon.com.
`
`Instructional videos from Collective Minds show the SP controller (and a front view
`thereof) held in the hand of a user. A screen shot from one video shows the following:
`
`
`
`
`
`1
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 4 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`
`
`
`http://collectiveminds.ca/shop/xbox/strikepack/.
`
`Collective Minds provides the following:
`
`“PLAY LIKE A PRO
`
`The Strike Pack is a breakthrough patent pending product designed for BOTH the Casual
`and Tournament Gamer. A dedicated wired USB connection enables lag free
`performance of the Strike Pack requiring no permanent modification to your controller
`meaning no warranty is ever voided. By simply snapping into the battery compartment
`and connecting the included 10FT USB cable to your existing controller go beyond Elite
`level control. Welcome to the Next Generation in Paddle Technology.”
`
`http://collectiveminds.ca/shop/xbox/strikepack/.
`
`an outer case comprising a front, a back, a As illustrated in the following images, the SP controller includes an outer case
`
`
`
`2
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 5 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`top edge, and a bottom edge, wherein the
`back of the controller is opposite the front
`of the controller and the top edge is
`opposite the bottom edge; and
`
`comprising a front (shown in the cell above), a back, a top edge, and a bottom edge,
`wherein the back of the controller is opposite the front of the controller and the top edge
`is opposite the bottom edge. These elements are further discussed below.
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`
`
`
`
`
`
`3
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 6 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`a front control located on the front of the
`controller;
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`The SP controller has multiple front controls located on the front of the controller, as
`illustrated in the following image.
`
`
`wherein the controller is shaped to be held
`in the hand of a user such that the user's
`thumb is positioned to operate the front
`control; and
`
`
`http://collectiveminds.ca/shop/xbox/strikepack/.
`The SP controller is shaped to be held in the hand of a user such that the user's thumb is
`positioned to operate the front control, as illustrated in the following image.
`
`
`
`
`
`
`4
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 7 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`a first back control and a second back
`control, each back control being located
`on the back of the controller and each
`back control including an elongate
`member that extends substantially the full
`distance between the top edge and the
`bottom edge and
`
`
`
`
`http://collectiveminds.ca/shop/xbox/strikepack/.
`The SP controller has a first back control and a second back control, with each back
`control being located on the back of the controller and each back control including an
`elongate member that extends substantially the full distance between the top edge and the
`bottom edge, as illustrated in the following image with arrows added.
`
`
`
`
`
`5
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 8 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`is inherently resilient and flexible.
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`Each elongate member of the back controls of the SP controller is inherently resilient and
`flexible.
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`
`
`
`6
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 9 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`2. The controller of claim 1, further
`having a top edge control located on the
`top edge of the controller and
`
`wherein the controller is shaped such that
`the user's index finger is positioned to
`operate the top edge control.
`
`The SP controller has a top edge control located on the top edge of the controller, as
`illustrated in the following image with arrow added.
`
`
`
`3. The controller of claim 2, wherein at
`least one of the back controls replicates
`the function of one or more of the top
`edge control and the front control.
`
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`Each of the back controls of the SP controller replicates the function of one or more of
`the top edge control and the front control.
`
`Collective Minds provides the following:
`
`PADDLES
`
`Get the ELITE edge with raised or flat paddles to fit your playing style. Easy to replace
`with the provided tools, the paddles can be mapped not only to the face buttons, but the
`shoulder buttons, even the L3 and R3 stick buttons. Mapping control to the paddles
`removes the need to move off the thumbsticks and triggers to access face buttons. You
`
`
`
`7
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 10 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`maintain control and gain precious reaction time… You simply become a better gamer.
`
`ONE TOUCH ON THE FLY PADDLE MAPPING
`
`On the fly hardware based paddle mapping is the key to next generation paddle tech.
`With no App or PC required for this function you are never taken out of your game to
`access anything. Assign any button to the paddles, at any time, including face, shoulder,
`even the left and right analog stick buttons. In FPS Mod Mode, advanced MODS like
`drop shot with rapid fire, can also be mapped to the paddles. That mode’s revolutionary
`Turbo 2.0 system uses the paddles as activators allowing turbo functionality on any
`button, but only when you need it, allowing compatibility with more of your favorite
`games versus the standard turbo of old.
`
`FPS DOMINATOR MODE
`
`Hundreds of controller MOD combinations are built right into the dedicated FPS
`Dominator mode. Rapid Fire, Burst Fire, Drop Shot, Jitter Fire, Quick Scope, Auto Run,
`even Turbo 2.0 are easily accessible without the need for the advanced StrikeMax PC
`software. Many MODS like Rapid Fire, Burst Fire, Anti-Recoil, Quickscope, and even
`Turbo 2.0 have fully adjustable variants so the gamer can customize to their liking. The
`most popular game specific MODS including Autospot for the Battlefield TM series,
`Easy Double Jump for the CODTM series are also built in. Even deeper customization
`of your controller is possible with the Rumble Control MOD that can turn off rumble at
`request, and the Hair Trigger MOD that will let you fire at the mere touch of the triggers.
`Activate any MOD or combine MODS right from your controller without the need for
`the StrikeMax software giving you incredible power right in your hands.
`
`CUSTOM GAME PACKS
`
`Using the Windows based STRIKEMAX software you can unleash unprecedented
`control over your controller with no warranty ever being voided. Custom Game Packs
`
`
`
`8
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 11 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`provide literally millions of MOD combinations tailored for specific game experiences.
`Rapid Fire, Burst Fire, Drop Shot, Quick Scope, all of the shooter staples are there for the
`HaloTM, DestintyTM, and CODTMseries, but game packs are also available to
`maximize the fun in GTATM, Batman Arkham KnightTM, even Mortal Kombat XTM
`so you can unleash the gruesome fatalities. No genre of game is safe. Every stored mod is
`available any time with up to 8 Game Pack storage on the Strike Pack. This allows you to
`change Game Packs and MODS all on the fly without the need to go back to the
`STRIKEMAX PC software that installed them.
`
`http://collectiveminds.ca/shop/xbox/xbox-one/strikepack/
`
`See also:
`
`
`
`
`9
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 12 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`4. The controller of claim 2, wherein at
`least one of the back controls has
`functions in addition to the top edge
`control and the front control.
`
`http://collectiveminds.ca/product-tab-content/strikepack-original-instructions-tab/
`Each of the back controls of the SP controller have “functions in addition to the top edge
`control and the front control.”
`
`Collective Minds provides the following:
`
`PADDLES
`
`Get the ELITE edge with raised or flat paddles to fit your playing style. Easy to replace
`with the provided tools, the paddles can be mapped not only to the face buttons, but the
`shoulder buttons, even the L3 and R3 stick buttons. Mapping control to the paddles
`
`
`
`10
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 13 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`removes the need to move off the thumbsticks and triggers to access face buttons. You
`maintain control and gain precious reaction time… You simply become a better gamer.
`
`ONE TOUCH ON THE FLY PADDLE MAPPING
`
`On the fly hardware based paddle mapping is the key to next generation paddle tech.
`With no App or PC required for this function you are never taken out of your game to
`access anything. Assign any button to the paddles, at any time, including face, shoulder,
`even the left and right analog stick buttons. In FPS Mod Mode, advanced MODS like
`drop shot with rapid fire, can also be mapped to the paddles. That mode’s revolutionary
`Turbo 2.0 system uses the paddles as activators allowing turbo functionality on any
`button, but only when you need it, allowing compatibility with more of your favorite
`games versus the standard turbo of old.
`
`FPS DOMINATOR MODE
`
`Hundreds of controller MOD combinations are built right into the dedicated FPS
`Dominator mode. Rapid Fire, Burst Fire, Drop Shot, Jitter Fire, Quick Scope, Auto Run,
`even Turbo 2.0 are easily accessible without the need for the advanced StrikeMax PC
`software. Many MODS like Rapid Fire, Burst Fire, Anti-Recoil, Quickscope, and even
`Turbo 2.0 have fully adjustable variants so the gamer can customize to their liking. The
`most popular game specific MODS including Autospot for the Battlefield TM series,
`Easy Double Jump for the CODTM series are also built in. Even deeper customization
`of your controller is possible with the Rumble Control MOD that can turn off rumble at
`request, and the Hair Trigger MOD that will let you fire at the mere touch of the triggers.
`Activate any MOD or combine MODS right from your controller without the need for
`the StrikeMax software giving you incredible power right in your hands.
`
`CUSTOM GAME PACKS
`
`Using the Windows based STRIKEMAX software you can unleash unprecedented
`
`
`
`11
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 14 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`control over your controller with no warranty ever being voided. Custom Game Packs
`provide literally millions of MOD combinations tailored for specific game experiences.
`Rapid Fire, Burst Fire, Drop Shot, Quick Scope, all of the shooter staples are there for the
`HaloTM, DestintyTM, and CODTMseries, but game packs are also available to
`maximize the fun in GTATM, Batman Arkham KnightTM, even Mortal Kombat XTM
`so you can unleash the gruesome fatalities. No genre of game is safe. Every stored mod is
`available any time with up to 8 Game Pack storage on the Strike Pack. This allows you to
`change Game Packs and MODS all on the fly without the need to go back to the
`STRIKEMAX PC software that installed them.
`
`http://collectiveminds.ca/shop/xbox/xbox-one/strikepack/
`The top edge of the SP controller is substantially perpendicular to the front, as illustrated
`in the following image.
`
`
`US Patent No. 8,641,525
`Asserted Claims
`
`5. The controller of claim 2, wherein the
`top edge is substantially perpendicular to
`the front.
`
`6. The controller of claim 1, wherein each
`of the back controls is positioned to be
`
`
`http://collectiveminds.ca/shop/xbox/xbox-one/strikepack/
`The back controls of the SP controller are positioned to be operated by a middle finger of
`a user, as illustrated in the following image.
`
`
`
`
`
`12
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 15 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`operated by a middle finger of a user.
`
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`The following review discusses the features of the Strike Pack, including positioning for
`operation by a middle finger of a user:
`
`“4.0 out of 5 stars The paddles work perfectly out of the box with no special
`programming other than assigning them to an existing button on the con
`
`ByC Doon January 5, 2016
`
`Verified Purchase
`
` I
`
` ordered this product on blind faith since all the reviews at the time didn't go into much
`detail about how it works. Even the manufacturer took awhile to post up videos and the
`software download. So ill try to help get that all straightened out.
`
`The paddles work perfectly out of the box with no special programming other than
`assigning them to an existing button on the controller which is quick and easy. (no
`special software needed). They make a very audible click sound so its safe to assume its a
`basic momentary switch which should last a really long time. The flat paddle is easily
`
`
`
`13
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 16 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`within reach of my middle finger and didn't take long for me to use the left paddle as a
`replacement for the left analog stick click. The box comes with a screw driver, raised
`paddles and extra screws. PUT THEM IN A SAFE PLACE!! chances are there's no easy
`way to replace them so keep it safe and keep it secret. Also you do need to keep the unit
`powered with any micro usb cable so its good to invest in a USB extension cable so your
`nice an comfy and don't yank it out accidentally.
`
`Now the tricky part. The software provided installed and detected the pack with no
`problems. Figuring out how to get the different game profiles loaded was kind of
`annoying. Once you have a profile saved to the pack they do try to explain the different
`settings but there are so many and some are so similar that it can be a little rough. I really
`only use the rapid fire since its pretty straight forward. Nice to have other options but it
`will take some time to tweak to your liking. Just create a custom local game and if
`possible remove the time limit you'll need it. Now the other issue is tweaking while in
`game. You have to rely on a series of flashing lights on the pack to tell what setting your
`currently adjusting. I cant really complain about it since the pack is only $50 but a basic
`LCD numeric panel would have been nice. counting flashes gets old when you just want
`to make a slight change. In case your wondering what all that means I'll try to break it
`down even more. There are 2 sets of leds on the pack, when adjusting in game, one set
`tells you which class is selected(a class is basically what action you want ie rapid fire or
`auto run) and the other set is for Mods(a mod defines how the class acts). So with a series
`of controller button presses you can navigate the classes and mods in game by following
`the flashing LED patterns. The draw back is its damn hard to remember what number
`each class and or mod is so you gotta print a cheat sheet or use the website. And each
`class/mod setup might be different for each game profile you load.
`
`So while it can be a bit of a pain to get going even the basic functions like rapid fire have
`proven to be incredibly useful. Now people will always mention SCUF as an alternative
`and that’s fine but for $50 you got a pack that can be transferred to another controller
`should you break it or just decide you gotta have that dope new limited edition controller
`which they drop like once a year. I won’t compare to the Elite since it doesn’t have the
`
`
`
`14
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 17 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`option for mods but there is nothing stopping a person from removing the paddles from
`the Strike Pack and adding it to the Elite for god mode. No denying the build quality of
`an elite but analog stick modules do wear out in time. So having options is golden.”
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/product-
`reviews/B01720MZJO/ref=cm_cr_arp_d_viewopt_kywd?pageNumber=1&filterByKeyw
`ord=switch
`Each of the elongate members of the SP controller is mounted within a recess located in
`the case of the controller, as illustrated in the following image.
`
`
`7. The controller of claim 1, wherein each
`elongate member is mounted within a
`recess located in the case of the controller.
`
`8. The controller of claim 7, wherein each
`elongate member comprises an outermost
`surface which is disposed in close
`proximity to the outermost surface of the
`controller such that a user's finger may be
`received in said respective recess.
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`Each of the elongate members of the SP controller comprises an outermost surface which
`is disposed in close proximity to the outermost surface of the controller so that a user's
`finger may be received in said respective recess [in order to operate the paddle portions],
`as illustrated in the following image.
`
`
`
`
`
`
`15
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 18 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`9. The controller of claim 1, wherein each
`elongate member has a thickness between
`about 1 mm and 10 mm.
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`The SP controller has a first and second elongate members with a thickness between 1
`mm and 10 mm.
`
`
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`
`
`16
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 19 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`10. The controller of claim 1, wherein
`each elongate member has a thickness
`between about 1 mm and 5 mm.
`
`
`The SP controller has a first and second elongate members with a thickness between 1
`mm and 5 mm.
`
`
`11. The controller of claim 1, wherein
`each elongate member has a thickness
`between about 1 mm and 3 mm.
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`The SP controller has a first and second elongate members with a thickness between 1
`mm and 3 mm.
`
`
`
`
`17
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 20 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`The SP controller, as illustrated in the following photo, has elongate members that
`converge towards the front end of the controller with respect to one another.
`
`
`13. The controller of claim 1, wherein the
`elongate members converge towards the
`front end of the controller with respect to
`one another.
`
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`
`
`
`18
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 21 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`14. The controller of claim 1, wherein a
`portion of at least one of the first back
`control and the second back control is in
`registry with a switch mechanism
`disposed within the controller, such that
`displacement of the at least one back
`control activates the switch mechanism.
`
`
`The SP controller, as illustrated in the following image and photo, has a portion of at
`least one of the first back control and the second back control is in registry with a switch
`mechanism disposed within the controller, such that displacement of the at least one back
`control activates the switch mechanism.
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`
`
`19
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 22 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`15. The controller of claim 1, wherein a
`switch mechanism is disposed between
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/product-
`reviews/B01720MZJO/ref=cm_cr_arp_d_viewopt_kywd?pageNumber=1&filterByKeyw
`ord=switch
`The SP controller, as illustrated in the following image and photo, has a switch
`mechanism disposed between each of the elongate members and an outer surface of the
`
`
`
`20
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 23 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`each of the elongate members and an outer
`surface of the back of the controller.
`
`back of the controller.
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`See also the following:
`
`
`
`21
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 24 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`16. The controller of claim 1, wherein at
`least one of the back controls is a paddle
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/product-
`reviews/B01720MZJO/ref=cm_cr_arp_d_viewopt_kywd?pageNumber=1&filterByKeyw
`ord=switch
`The SP controller has at least one of the back controls that is a paddle lever.
`
`
`
`
`22
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 25 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`lever.
`
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`See also the following:
`
`
`
`
`
`23
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 26 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/product-
`reviews/B01720MZJO/ref=cm_cr_arp_d_viewopt_kywd?pageNumber=1&filterByKeyw
`ord=switch
`
`
`
`24
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 27 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`17. The controller of claim 1, wherein at
`least one of the back controls is
`substantially parallel to the front of the
`controller.
`
`
`http://collectiveminds.ca/product-tab-content/strikepack-original-instructions-tab/
`The SP controller, as illustrated in the following image, has at least one of the back
`controls that is substantially parallel to the front of the controller.
`
`
`
`25
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 28 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`18. The controller of claim 1, wherein at
`least one of the back controls is formed as
`an integral part of the outer case.
`
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`The controls of the SP controller, as illustrated in the image below, are formed as an
`integral part of the outer case.
`
`
`
`
`
`
`
`
`
`26
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 29 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`19. The controller of claim 1, wherein at
`least one of the back controls is formed
`separate from the outer case of the
`controller.
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`The controls of the SP controller, as illustrated are formed separate from the outer case of
`the controller.
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`
`
`
`
`
`27
`
`
`
`
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 30 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`20. A hand held controller for a game
`console comprising:
`
`The Collective Minds Strike Pack controller (hereafter “SP”), as shown in the illustration
`on Collective Minds packaging (image from sales on Amazon.com by Collective Minds)
`is a hand held controller for a game console.
`
`Source: Amazon.com.
`
`Instructional videos from Collective Minds show the SP controller (and a front view
`thereof) held in the hand of a user. A screen shot from one video shows the following:
`
`
`
`
`
`28
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 31 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`
`
`
`http://collectiveminds.ca/shop/xbox/strikepack/.
`
`Collective Minds provides the following:
`
`“PLAY LIKE A PRO
`
`The Strike Pack is a breakthrough patent pending product designed for BOTH the Casual
`and Tournament Gamer. A dedicated wired USB connection enables lag free
`performance of the Strike Pack requiring no permanent modification to your controller
`meaning no warranty is ever voided. By simply snapping into the battery compartment
`and connecting the included 10FT USB cable to your existing controller go beyond Elite
`level control. Welcome to the Next Generation in Paddle Technology.”
`
`http://collectiveminds.ca/shop/xbox/strikepack/.
`
`an outer case comprising a front, a back, a As illustrated in the following images, the SP controller includes an outer case
`
`
`
`29
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 32 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`top edge, and a bottom edge, wherein the
`back of the controller is opposite the front
`of the controller and the top edge is
`opposite the bottom edge; and
`
`comprising a front (shown in the cell above), a back, a top edge, and a bottom edge,
`wherein the back of the controller is opposite the front of the controller and the top edge
`is opposite the bottom edge. These elements are further discussed above and below.
`
`
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`
`
`
`
`
`
`30
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 33 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`a front control located on the front of the
`controller;
`
`https://www.amazon.com/Collective-Minds-XBOX-ONE-Strike-Pack/dp/B01720MZJO
`
`The SP controller has multiple front controls located on the front of the controller, as
`illustrated in the following image.
`
`
`wherein the controller is shaped to be held
`in the hand of a user such that the user's
`thumb is positioned to operate the front
`control; and
`
`
`http://collectiveminds.ca/shop/xbox/strikepack/.
`The SP controller is shaped to be held in the hand of a user such that the user's thumb is
`positioned to operate the front control, as illustrated in the following image.
`
`
`
`
`
`
`31
`
`

`

`Case 1:16-cv-04110-TWT Document 41-1 Filed 11/07/17 Page 34 of 35
`Confidential
`Ironburg Inventions Ltd. v. Collective Minds,
`
`
`
`
`Case No. 1:16-cv-04110-TWT
`
`
` For Use in Litigation Only
`
`
`Infringing Product
`
`US Patent No. 8,641,525
`Asserted Claims
`
`a first back control and a second back
`control, each back control being located
`on the back of the controller and each
`back control including an elongate
`member that extends substantially the full
`distance between the top edge and the
`bottom edge