`
`
`This is a preliminary comparison, based on the information currently available to Continental of the claims of U.S. Patent No. 6,998,973
`and Schrader tire pressure monitoring sensor No. 20161 (“Schrader 20161”). Continental reserves the right to amend or supplement this
`disclosure as additional information becomes available through discovery, and/or the claims of the ‘973 Patent are construed by the Court. This
`chart should not be interpreted as providing Continental’s claim construction positions, which will be set forth in separate documents at the
`appropriate times according to the schedule provided by the Court.
`
`
`Claim 1
`A data transmission method for a
`tireͲpressure monitoring system
`(10) of a vehicle, said data being
`transmitted by wheel units (12) to
`a central computer (13) located in
`the vehicle, said method
`comprising:
`a data transmission phase in
`parking mode, over a first
`period; and
`
`a data transmission phase in
`running mode, over a second
`period shorter than the first
`period; said method being
`characterized in that:
`
`a natural time lag between
`various internal clocks with
`which each wheel unit (12) is
`equipped is used to prevent
`collisions between
`transmissions from the various
`wheel units of one and the
`same vehicle.
`
`A/74859929.1
`
`Schrader 20161
`The Schrader 20161 is a tire pressure monitoring sensor designed for installation in the wheel of
`a vehicle, and designed to, among other things, detect and air pressure drop in a tire . It
`transmits data wirelessly to a tire pressure monitoring receiver located in a vehicle. See
`generally Exhibit A, Figure A.
`
`The Schrader 20161 transmits data periodically when stationary (i.e., when the sensor is in a
`“parking mode”). Wireless data was collected from a stationary Schrader 20161 over the course
`of approximately 4 hours. Each transmission consisted of 4 data bursts of 8 data frames each,
`and occurred approximately every hour.
`The Schrader 20161 transmits data periodically when in motion (i.e., when the sensor is in a
`“running mode”). Wireless data was collected from a rotating Schrader 20161 operating over
`the course of approximately 2 minutes. Each transmission consisted of 4 data bursts of 4 data
`frames each, and occurred approximately every 30.9 seconds Ͳ 31.0 seconds. The period for this
`data transmission phase (30.9 seconds Ͳ 31.0 seconds) is shorter than the period for the data
`transmission phase in parking mode (approximately every hour).
`Testing of the Schrader 20161 showed that the sensor transmits asynchronously whether the
`sensor is stationary or rotating. Wireless data was collected from a stationary Schrader 20161
`operating over approximately 4 hours. The data shows that the time between the start of each
`transmission varied from 1 hour, 6.6 seconds to 1 hour, 6.8 seconds. Wireless data was
`collected from a rotating Schrader 20161 operating over approximately 2 minutes. The data
`shows that the time between the start of each transmission varied from 30.9 seconds Ͳ 31.0
`seconds. These variations in time enable the prevention of data collisions between
`transmissions from tire pressure monitoring system sensors installed in different wheels of a
`
`1
`
`Page 1002-1
`
`
`
`vehicle.
`
` U
`
`pon information and belief, the Schrader 20161 accomplishes these asynchronous transmission
`periods, at least in part, through the use of an internal clock with a natural time lag.
`
`
`
`Upon information and belief, the Schrader 20161 uses an RC oscillator to generate clock signals,
`and therefore that the internal time lag is determined by the precision of an RC oscillator,
`because only an RC oscillator would allow the Schrader 20161 to function properly while still
`meeting the service life requirements imposed by original equipment manufacturers.
`
`
`
`
`The Schrader 20161 transmits several frames during each transmission whether the sensor is
`stationary or rotating. Wireless data was collected from a stationary Schrader 20161 operating
`over approximately 4 hours. Each transmission consisted of 4 data bursts of 8 data frames each.
`Wireless data was collected from a rotating Schrader 20161 operating over approximately 2
`minutes. Each transmission consisted of 4 data bursts of 4 data frames each.
`
`
`
`The Schrader 20161 transmits at least three frames during each transmission whether the sensor
`is stationary or rotating. Wireless data was collected from a stationary Schrader 20161
`operating over approximately 4 hours. Each transmission consisted of 4 data bursts of 8 data
`frames each. Wireless data was collected from a rotating Schrader 20161 operating over
`approximately 2 minutes. Each transmission consisted of 4 data bursts of 4 data frames each. In
`each case, the Schrader 20161 transmitted 3 frames of data.
`
`
`
`
`2
`
`
`
`Claim 2
`The method as claimed in claim 1,
`characterized in that the
`internal time lag between the
`various clocks of each wheel
`unit is preferably determined
`by the precision of an RCͲtype
`oscillator mounted in each
`wheel unit.
`
`
`
`Claim 4
`The method as claimed in claim 1,
`characterized in that each
`wheel unit transmits several
`frames for each data item to
`be transmitted.
`
`
`
`Claim 5
`The method as claimed in claim 4,
`characterized in that three
`frames are transmitted for
`each data item to be
`transmitted.
`
`
`
`Claim 9
`The method as claimed in claim 2,
`
`A/74859929.1
`
`Page 1002-2
`
`
`
`characterized in that each
`wheel unit transmits several
`frames for each data item to
`be transmitted.
`
`The Schrader 20161 transmits several frames during each transmission whether the sensor is
`stationary or rotating. Wireless data was collected from a stationary Schrader 20161 operating
`over approximately 4 hours. Each transmission consisted of 4 data bursts of 8 data frames each.
`Wireless data was collected from a rotating Schrader 20161 operating over approximately 2
`minutes. Each transmission consisted of 4 data bursts of 4 data frames each.
`
`
`
`3
`
`A/74859929.1
`
`Page 1002-3
`
`
`
`
`
`EXHIBIT A
`
`
`
`EXHIBIT AEXHIBIT A
`
`Page 1002-4
`
`
`
`
`
`
`
`
`
`
`
`Figure A
`
`
`
`
`
`Figure AFigure A
`
`Page 1002-5
`
`
`
`For Outside Counsel Eyes Only
`
`APPENDIX 1 ‐ PLAINTIFF'S AMENDED INFRINGEMENT CONTENTIONS CLAIM CHART (GEN 3 SENSORS)
`
`
`This is a preliminary comparison, based on the information currently available to Continental of the asserted claims of U.S. Patent No.
`6,998,973 (the “ ‘973 Patent”) and Schrader tire pressure monitoring system (“TPMS”) sensors with Gen Alpha or Gen 3 internal oscillator ASICs
`(collectively “Gen 3 Sensors”). Continental reserves the right to amend or supplement this disclosure as additional information becomes
`available through discovery and/or when the claim terms of the ‘973 Patent are construed by the Court. This chart should not be interpreted as
`providing Continental’s claim construction positions, which will be set forth in separate documents at the appropriate times according to the
`schedule provided by the Court.
`
`
`Claim 1
`A data transmission method for a
`tire‐pressure monitoring system
`(10) of a vehicle, said data being
`transmitted by wheel units (12) to
`a central computer (13) located in
`the vehicle, said method
`comprising:
`a data transmission phase in
`parking mode, over a first
`period; and
`a data transmission phase in
`running mode, over a second
`period shorter than the first
`period; said method being
`characterized in that:
`a natural time lag between
`various internal clocks with
`which each wheel unit (12) is
`equipped is used to prevent
`collisions between
`transmissions from the various
`wheel units of one and the
`
`Schrader Gen 3 Sensors
`Gen 3 Sensors are designed for installation in the wheel of a vehicle and are designed to, among
`other things, monitor and report air pressure in a tire. They transmit data wirelessly to a tire
`pressure monitoring receiver located in a vehicle. See, e.g., SCH0001109 ‐ SCH0001133;
`SCH0002510 ‐ SCH0002528; SCH0002972 ‐ SCH0003019; SCH0004358 ‐ SCH0004413;
`SCH0004431 ‐ SCH0004443.
`
`Gen 3 Sensors transmit data when stationary over a first period. See, e.g., SCH0001109 ‐
`SCH0001133; SCH0002510 ‐ SCH0002528; SCH0002972 ‐ SCH0003019; SCH0004358 ‐
`SCH0004413.
`Gen 3 Sensors transmit data when in motion over a period that is shorter than the transmission
`period when the vehicle is stationary. See, e.g., id.
`
`Gen 3 Sensors use an internal oscillator (as opposed to a crystal oscillator) to control the timing
`of RF transmissions. See, e.g., SCH0001109 ‐ SCH0001133; SCH0002510 ‐ SCH0002528;
`SCH0002972 ‐ SCH0003019; SCH0004358 ‐ SCH0004413; SCH0004431 ‐ SCH0004443. The
`imprecision of the internal oscillator results in a natural time lag that prevents collisions
`between transmissions from the various wheel units of one and the same vehicle. See, e.g., id.
`
`For the avoidance of doubt, Continental does not contend that Schrader TPMS sensors having a
`
`1
`A/74941081.1
`
`Page 1002-6
`
`
`
`same vehicle.
`
`
`
`Claim 2
`The method as claimed in claim 1,
`characterized in that the
`internal time lag between the
`various clocks of each wheel
`unit is preferably determined
`by the precision of an RC‐type
`oscillator mounted in each
`wheel unit.
`
`
`
`Claim 4
`The method as claimed in claim 1,
`characterized in that each
`wheel unit transmits several
`frames for each data item to
`be transmitted.
`
`
`
`Claim 5
`The method as claimed in claim 4,
`characterized in that three
`frames are transmitted for
`each data item to be
`transmitted.
`
`
`
`Claim 7
`The method as claimed in claim 4,
`characterized in that the
`frames transmitting the same
`
`For Outside Counsel Eyes Only
`
`Gen 3 ASIC that uses a crystal oscillator as the sole timing reference to initiate RF transmissions
`infringe the ‘973 patent. An example of such an ASIC is described at SCH0002803 ‐ SCH0002809.
`
`
`
`Gen 3 Sensors contain an RC‐type oscillator; the internal time lags between the various clocks of
`each of the four Gen 3 Sensors on a vehicle are determined by the precision of the RC‐type
`oscillator in each Gen 3 Sensor. See, e.g., id.
`
`
`
`
`Gen 3 Sensors transmit several frames during each block transmission whether the sensor is
`stationary or rotating. See, e.g., SCH0001109 ‐ SCH0001133; SCH0002510 ‐ SCH0002528;
`SCH0002972 ‐ SCH0003019; SCH0004358 ‐ SCH0004413.
`
`
`
`
`Gen 3 Sensors transmit three frames during each block transmission whether the sensor is
`stationary or rotating. See, e.g., id.
`
`
`
`
`Gen 3 Sensors transmit frames for the same data item during a single wheel revolution. See,
`e.g., id.
`
`2
`A/74941081.1
`
`Page 1002-7
`
`
`
`Chart Contains References to Highly Confidential and Source Code Subject to the Protection Order
`For Outside Counsel Eyes Only
`
`
`data item are transmitted
`during a single wheel
`revolution.
`
`
`Claim 9
`The method as claimed in claim 2,
`characterized in that each
`wheel unit transmits several
`frames for each data item to
`be transmitted.
`
`
`Claim 11
`The method as claimed in claim 5,
`characterized in that the
`frames transmitting the same
`data item are transmitted
`during a single wheel
`revolution.
`
`
`
`
`Gen 3 Sensors transmit several frames during each block transmission whether the sensor is
`stationary or rotating. See, e.g., id.
`
`
`
`
`Gen 3 Sensors transmit three frames for the same data item during a single wheel revolution.
`See, e.g., id.
`
`
`
`3
`A/74941081.1
`
`Page 1002-8
`
`
`
`For Outside Counsel Eyes Only
`
`APPENDIX 2 ‐ PLAINTIFF'S AMENDED INFRINGEMENT CONTENTIONS CLAIM CHART (GEN 4 SENSORS)
`
`
`This is a preliminary comparison, based on the information currently available to Continental of the asserted claims of U.S. Patent No.
`6,998,973 (the “ ‘973 Patent”) and Schrader tire pressure monitoring system (“TPMS”) sensors with Gen 4 internal oscillator ASICs (“Gen 4
`Sensors”). Continental reserves the right to amend or supplement this disclosure as additional information becomes available through discovery
`and/or when claim terms of the ‘973 Patent are construed by the Court. This chart should not be interpreted as providing Continental’s claim
`construction positions, which will be set forth in separate documents at the appropriate times according to the schedule provided by the Court.
`
`
`Claim 1
`A data transmission method for a
`tire‐pressure monitoring system
`(10) of a vehicle, said data being
`transmitted by wheel units (12) to
`a central computer (13) located in
`the vehicle, said method
`comprising:
`a data transmission phase in
`parking mode, over a first
`period; and
`
`a data transmission phase in
`running mode, over a second
`period shorter than the first
`period; said method being
`characterized in that:
`a natural time lag between
`various internal clocks with
`which each wheel unit (12) is
`equipped is used to prevent
`collisions between
`transmissions from the various
`wheel units of one and the
`
`A/74941101.1
`
`Schrader Gen 4 Sensors
`Gen 4 Sensors are designed for installation in the wheel of a vehicle and are designed to, among
`other things, monitor air pressure in a tire. They transmit data wirelessly to a tire pressure
`monitoring receiver located in a vehicle. See, e.g., SCH0001398 ‐ SCH0001425; SCH0001428 ‐
`SCH0001457; SCH0002460 ‐ SCH0002491; SCH0002529 ‐ SCH0002564; SCH0002810 ‐
`SCH0002853; SCH0003060 ‐ SCH0003098; SCH0003099 ‐ SCH0003135; SCH0004431 ‐
`SCH0004443.
`
`Gen 4 Sensors transmit data when stationary over a first period. See, e.g., SCH0001398 ‐
`SCH0001425; SCH0001428 ‐ SCH0001457; SCH0002460 ‐ SCH0002491; SCH0002529 ‐
`SCH0002564; SCH0002810 ‐ SCH0002853; SCH0003060 ‐ SCH0003098; SCH0003099 ‐
`SCH0003135.
`Gen 4 Sensors transmit data when in motion over a period that is shorter than the transmission
`period when the vehicle is stationary. See, e.g., id.
`
`Gen 4 Sensors use an internal oscillator (as opposed to a crystal oscillator) to control the timing
`of RF transmissions. See, e.g., SCH0001398 ‐ SCH0001425; SCH0001428 ‐ SCH0001457;
`SCH0002460 ‐ SCH0002491; SCH0002529 ‐ SCH0002564; SCH0002810 ‐ SCH0002853;
`SCH0003060 ‐ SCH0003098; SCH0003099 ‐ SCH0003135; SCH0004431 ‐ SCH0004443. The
`imprecision of the internal oscillator results in a natural time lag that prevents collisions
`between transmissions from the various wheel units of one and the same vehicle. See, e.g., id.
`
`1
`
`Page 1002-9
`
`
`
`same vehicle.
`
`
`
`Claim 2
`The method as claimed in claim 1,
`characterized in that the
`internal time lag between the
`various clocks of each wheel
`unit is preferably determined
`by the precision of an RC‐type
`oscillator mounted in each
`wheel unit.
`
`
`
`Claim 4
`The method as claimed in claim 1,
`characterized in that each
`wheel unit transmits several
`frames for each data item to
`be transmitted.
`
`
`
`Claim 5
`The method as claimed in claim 4,
`characterized in that three
`frames are transmitted for
`each data item to be
`transmitted.
`
`
`Claim 7
`The method as claimed in claim 4,
`characterized in that the
`frames transmitting the same
`data item are transmitted
`
`A/74941101.1
`
`For Outside Counsel Eyes Only
`
`
`
`
`
`Gen 4 Sensors contain an RC‐type oscillator; the internal time lags between the various clocks of
`each of the four Gen 4 Sensors on a vehicle are determined by the precision of the RC‐type
`oscillator in each Gen 4 Sensor. See, e.g., id.
`
`
`
`
`Gen 4 Sensors transmit several frames during each block transmission whether the sensor is
`stationary or rotating. See, e.g., SCH0001398 ‐ SCH0001425; SCH0001428 ‐ SCH0001457;
`SCH0002460 ‐ SCH0002491; SCH0002529 ‐ SCH0002564; SCH0002810 ‐ SCH0002853;
`SCH0003060 ‐ SCH0003098; SCH0003099 ‐ SCH0003135.
`
`
`
`Gen 4 Sensors transmits three frames during each block transmission whether the sensor is
`stationary or rotating. See, e.g., id.
`
`
`
`
`Gen 4 Sensors transmit frames for the same data item during a single wheel revolution. See,
`e.g., id.
`
`2
`
`Page 1002-10
`
`
`
`Chart Contains References to Highly Confidential and Source Code Subject to the Protection Order
`For Outside Counsel Eyes Only
`
`
`during a single wheel
`revolution.
`
`
`
`Claim 9
`The method as claimed in claim 2,
`characterized in that each
`wheel unit transmits several
`frames for each data item to
`be transmitted.
`
`
`Claim 11
`The method as claimed in claim 5,
`characterized in that the
`frames transmitting the same
`data item are transmitted
`during a single wheel
`revolution.
`
`
`
`
`Gen 4 Sensors transmit several frames during each block transmission whether the sensor is
`stationary or rotating. See, e.g., id.
`
`
`
`
`Gen 4 Sensors transmit three frames for the same data item during a single wheel revolution.
`See, e.g., id.
`
`
`
`3
`
`A/74941101.1
`
`Page 1002-11
`
`
`
`For Outside Counsel Eyes Only
`
`APPENDIX 3 ‐ PLAINTIFF'S AMENDED INFRINGEMENT CONTENTIONS CLAIM CHART (GEN 5 SENSORS)
`
`
`This is a preliminary comparison, based on the information currently available to Continental of the asserted claims of U.S. Patent No.
`6,998,973 (the “ ‘973 Patent”) and Schrader tire pressure monitoring system (“TPMS”) sensors with Gen 5 internal oscillator ASICs and the
`Schrader EZ Sensor (Schrader Part Nos. 33000 and 33100) (collectively “Gen 5 Sensors”). Continental reserves the right to amend or supplement
`this disclosure as additional information becomes available through discovery and/or when claim terms of the ‘973 Patent are construed by the
`Court. This chart should not be interpreted as providing Continental’s claim construction positions, which will be set forth in separate documents
`at the appropriate times according to the schedule provided by the Court.
`
`
`Claim 1
`A data transmission method for a
`tire‐pressure monitoring system
`(10) of a vehicle, said data being
`transmitted by wheel units (12) to
`a central computer (13) located in
`the vehicle, said method
`comprising:
`a data transmission phase in
`parking mode, over a first
`period; and
`a data transmission phase in
`running mode, over a second
`period shorter than the first
`period; said method being
`characterized in that:
`a natural time lag between
`various internal clocks with
`which each wheel unit (12) is
`equipped is used to prevent
`collisions between
`transmissions from the various
`wheel units of one and the
`
`A/74941103.1
`
`Schrader Gen 5 Sensors
`Gen 5 Sensors are designed for installation in the wheel of a vehicle and are designed to, among
`other things, monitor air pressure in a tire. They transmit data wirelessly to a tire pressure
`monitoring receiver located in a vehicle. See, e.g., SCH0002934 ‐ SCH0002971; SCH0004510 ‐
`SCH0004596.
`
`Gen 5 Sensors transmit data when stationary over a first period. See, e.g., id.
`
`Gen 5 Sensors transmit data when in motion over a period that is shorter than the transmission
`period when the vehicle is stationary. See, e.g., id.
`
`Gen 5 Sensors use an internal oscillator (as opposed to a crystal oscillator) to control the timing
`of RF transmissions. See, e.g., id. The imprecision of the internal oscillator results in a natural
`time lag that prevents collisions between transmissions from the various wheel units of one and
`the same vehicle. See, e.g., id.
`
`1
`
`Page 1002-12
`
`
`
`same vehicle.
`
`
`
`Claim 2
`The method as claimed in claim 1,
`characterized in that the
`internal time lag between the
`various clocks of each wheel
`unit is preferably determined
`by the precision of an RC‐type
`oscillator mounted in each
`wheel unit.
`
`
`
`Claim 4
`The method as claimed in claim 1,
`characterized in that each
`wheel unit transmits several
`frames for each data item to
`be transmitted.
`
`
`
`Claim 5
`The method as claimed in claim 4,
`characterized in that three
`frames are transmitted for
`each data item to be
`transmitted.
`
`
`Claim 7
`The method as claimed in claim 4,
`characterized in that the
`frames transmitting the same
`data item are transmitted
`
`A/74941103.1
`
`For Outside Counsel Eyes Only
`
`
`
`
`
`Gen 5 Sensors contain an RC‐type oscillator; the internal time lags between the various clocks of
`each of the four Gen 5 Sensors on a vehicle are determined by the precision of the RC‐type
`oscillator in each Gen 5 Sensor. See, e.g., id.
`
`
`
`
`Gen 5 Sensors transmit several frames during each block transmission whether the sensor is
`stationary or rotating. See, e.g., id.
`
`
`
`
`Gen 5 Sensors transmit three frames during each block transmission whether the sensor is
`stationary or rotating. See, e.g., id.
`
`
`
`
`Gen 5 Sensors transmit frames for the same data item during a single wheel revolution. See,
`e.g., SCH0004510 ‐ SCH0004596.
`
`2
`
`Page 1002-13
`
`
`
`Chart Contains References to Highly Confidential and Source Code Subject to the Protection Order
`For Outside Counsel Eyes Only
`
`
`during a single wheel
`revolution.
`
`
`
`Claim 9
`The method as claimed in claim 2,
`characterized in that each
`wheel unit transmits several
`frames for each data item to
`be transmitted.
`
`
`Claim 11
`The method as claimed in claim 5,
`characterized in that the
`frames transmitting the same
`data item are transmitted
`during a single wheel
`revolution.
`
`
`
`
`The Gen 5 Sensor transmits several frames during each block transmission whether the sensor is
`stationary or rotating. See, e.g., SCH0002934 ‐ SCH0002971; SCH0004510 ‐ SCH0004596.
`
`
`
`
`Gen 5 Sensors transmit three frames for the same data item during a single wheel revolution.
`See, e.g., SCH0004510 ‐ SCH0004596.
`
`
`
`3
`
`A/74941103.1
`
`Page 1002-14
`
`