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`EXHIBIT 1013
`
`EXHIBIT 1013
`
`

`

`
`
`Appendix A – Sony1
`
`
`The following chart is based on information known to date. Plaintiff Network-1 reserves
`
`the right to amend and update this chart as additional information is obtained and analyzed.
`
`
`
`Plaintiff Network-1 contends that Sony (1) directly infringes, (2) contributorily infringes,
`
`and (3) induces infringement of the Asserted Claims. Plaintiff Network-1 contends that Sony:
`
`
`
`(1) directly infringes the Asserted Claims by practicing a method for remotely powering access
`
`equipment in a data network that satisfies all of the claimed elements as described below. In
`
`directly infringing the Asserted Claims by practicing such a method, (a) the power sourcing
`
`equipment2 (data nodes) and powered devices (access devices) used by Sony can both be
`
`
`1
`Consistent with P.R. 3-1(c), Network-1 contends that the following chart provided for
`Sony is sufficient to “identify[] specifically where each element of each asserted claim is found
`within each [Sony] Accused Instrumentality” (P.R. 3-1(c)) because the analysis of each element,
`for purposes of Network-1’s contentions relating to Sony’s Accused Instrumentalities, “would be
`identical for each product.” See Juxtacomm Techs., Inc. v. Ascential Software Corp., 2008 U.S.
`Dist. LEXIS 36590 *5-6 (E.D. Tex. May 2, 2008).
`
` 2
`
`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].”
`[N12530].
`
`
`
`
`
`1
`
`

`

`
`
`made by others or, (b) the power sourcing equipment (data nodes) can be made by others and
`
`the powered devices (access devices) can be made by Sony (e.g., a Sony SNC-CH120).3
`
`
`
`(2) contributory infringes the Asserted Claims by making, importing, offering to sell, and selling
`
` (i) powered devices (access devices) that, when combined and connected to power
`
`sourcing equipment (data nodes) 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 a method for remotely powering access equipment in a data network that
`
`satisfies all of the claimed elements as described below;
`
`
`
`
`
`
`
`(3) actively induces infringement of the Asserted Claims by instructing others to use power
`
`sourcing equipment (data nodes), combined with and connected to powered devices (access
`
`devices) (made by Sony or others), as suggested by Sony’s manuals, advertising, place cards,
`
`and other literature, to practice a method for remotely powering access equipment in a data
`
`network that satisfies all of the claimed elements as described below.
`
`
`
`Plaintiff Network-1 contends that each of the Sony Accused Instrumentalities is designed
`
`and functions consistent with the IEEE 802.3af4 or IEEE 802.3at5 Standards.6 Sample statements
`
`
`3
`In addition to making, using, selling, and offering to sell the identified powered devices
`(access devices), Sony also makes, uses, sells, and offers to sell other related equipment
`specifically designed to be used in connection with the power sourcing equipment (data nodes)
`and powered devices (access devices) in a data network that satisfies all of the claimed elements.
`
` 4
`
`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)
`[N12517-12649].
`
` 5
`
`“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) [N151839].
`
`All components of the 802.3af Standard are now integrated into 802.3-2008 Standard.
`
`2
`
` 6
`
`
`
`
`
`
`
`

`

`
`
`demonstrating that the Sony Accused Instrumentalities conform to the IEEE 802.3af or IEEE
`
`802.3at Standards include:
`
` “Power can also be supplied via an Ethernet CAT5 cable from an IEEE 802.3af-
`
`compliant power supply system*. AC 24 V, DC 12 V, or PoE (Power-over-
`
`Ethernet) is automatically selected according to the power supplied.” (SNC-
`
`Z20N Brochure) [N210222];
`
` “The SNC-CS50 offers a choice of three types of power: 24 V AC, 12 V DC, or
`
`PoE (Power-over-Ethernet, IEEE 802.3af).” (SNC-RX Series Brochure)
`
`[N210210];
`
` “These cameras offer a choice of three types of power: 24 V AC, 12 V DC, or
`
`PoE (Power-over-Ethernet, IEEE 802.3af).” (SNC-DM_DS Brochure)
`
`[N210168];
`
` “Variety of power options: AC24V, DV12V, or IEEE.802.3af PoE Compliant”
`
`(SNC-CS11N Overview) [N210090];
`
` “PoE (IEEE802.3af compliant)” (SNC-CH120 Specs) [N210056];
`
` “PoE (IEEE802.3af)” (SNC-CH180 Specs) [N210064];
`
` “PoE (IEEE802.3af)” (SNT-EXP/EP Series Brochure) [N210236];
` “HPoE (IEEE802.3at compliant), AC24V” (SNC-EP520 – DATA) [N210184];
`
` “IEEE802.3at HPoE (High Power over Ethernet) compliant.” (SNC-
`
`EP520/580/ER520/550/580 User Guide) [N253091];
`
` “HPoE LLDP function: Based on 802.3at, select whether to use the power
`
`adjustment function by LLDP (Link-Layer-Discovery-Protocol). Select ON in the
`
`case of IEEE802.3at compatible power adjustment by PSE (Power Sourcing
`
`Equipment).” (SNC-EP520/580/ER-520/550/580 User Guide) [N253127];
`
` “hPoE (High PoE, IEEE 802.3at)” (Sony Security Products Quick Reference)
`
`[N252128].
`
`
`
`
`3
`
`

`

`
`
`
`
`
`Claim language
`
`Claim 6 (‘930 Patent)
`
`Sony
`
`
`
`Pre: Method for remotely
`
`Sample evidence (Sony statements, depictions, and other
`
`powering access equipment
`
`documentation) includes:7
`
`in a data network,
`
` See elements [a] – [d] below;
`
`comprising
`
` “Power can also be supplied via an Ethernet
`
`CAT5 cable from an IEEE 802.3af-compliant
`
`power supply system*.” (SNC-Z20N Brochure)
`
`[N210222];
`
` “Supporting high Power over Ethernet (hPoE),
`
`the SNC-RS44/RS46 can be powered using the
`
`same Ethernet cable it uses for data transfer.”
`
`(SNC-RS Brochure) [N210203];
`
`
`7
`The “Sample evidence (Sony statements, depictions, and other documentation)” presented
`in this Appendix are illustrative examples of statements, depictions, and other documentation
`that help one understand and put into context the identification presented for each element. The
`identification presented for each element is in no way indented to be limited to the specific
`illustrative examples in such statements, depictions, and other documentation. For each claim
`element, the “sample evidence” identified in the Appendices of each Defendant is incorporated
`by reference into this Appendix for each corresponding claim element.
`
`4
`
`
`

`

`
`
` (SNC-CH110/210 Installation Manual)
`
`[N252229];
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`5
`
`
`
`
`

`

`
`
`
`
`
`
`
`
`(SNC-CH160/260 Installation Manual)
`
`[N252563].
`
`
`
`
`
`6
`
`
`
`
`

`

`
`
`
`
`802.3af, 802.3at, and 802.3-2008 Standards statements
`
`and depictions include:
`
` “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) [N12519];
`
` “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))
`
`[N12530];
`
` “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) [N12555]; (IEEE
`
`802.3at Standard 33.1) [N151872].
`
`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,
`
`
`
`
`7
`
`

`

`
`
`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), combined with powered devices (access
`
`devices, addressed below), made by Sony or
`
`others, are 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 are the
`
`powered devices (access devices) that access data
`
`and power through a network. Non-limiting
`
`examples of such access equipment include (a)
`
`phones (e.g., IP phones), (b) wireless access
`
`points, (c) cameras (e.g., security cameras), (d)
`
`magnetic card readers, and (e) video kiosks. Non-
`
`limiting examples of such access equipment are
`
`also listed in the main body of these Infringement
`
`Contentions and are identified as the Accused
`
`Instrumentalities for various Defendants under the
`
`headings: “powered devices (access devices).”
`
`
`
`(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).
`
`
`
`
`8
`
`

`

`
`
`[a-1] providing a data node
`
`Sample evidence (Sony statements, depictions, and other
`
`adapted for data switching
`
`documentation) includes:
`
` “Network equipment capable of supplying IEEE
`
`802.3afcompliant power is required.” (SNC-Z20N
`
`Brochure) [N210222];
`
`
`
`
`
`
`
`
`
`
`
`9
`
`
`
`
`

`

`
`
`
`
`
`
`(SNC-CH110/210 Installation Manual)
`
`[N252229];
`
`
`
`
`
`
`
`
`
`
`
`
`10
`
`

`

`
`
`
`
`
`
`(SNC-CH160/260 Installation Manual)
`
`[N252563];
`
` See evidence for element [a-1] for other
`
`Defendants.
`
`
`
`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) [N12557]; (IEEE 802.3-2008 Standard
`
`33.2) [N236612];
`
`11
`
`
`
`
`

`

`
`
`(IEEE 802.3af Standard Figure 33-4) [N12558];
`
`(IEEE802.3-2008 Standard Figure 33-4) [N236613];
`
`(IEEE 802.3at Standard Figure 33-4) [N151877];
`
`(IEEE 802.3at Standard Figure 33-5) [N151878];
`
`
`
`
`
`
`
`12
`
`
`
`
`

`

`
`
`(IEEE 802.3at Standard Figure 33-7) [N151880];
`
` “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, returning to the searching
`
`state.” (IEEE 802.3at Standard 33.2) [N151875].
`
`Under the IEEE 802.3af and 802.3at standards, switches
`
`and routers are Endpoint PSEs (power sourcing
`
`equipment) which are data nodes adapted for switching.
`
`
`
`Identification: The “data node adapted for data
`
`13
`
`
`
`
`

`

`
`
`switching” is each Power over Ethernet switch and router
`
`used in connection with Sony’s powered devices (access
`
`device).8 Power over Ethernet switches and routers have
`
`multiple ports (e.g., 8-ports, 24-ports) and can switch
`
`data between ports, providing switching functionality.
`
`Non-limiting examples of such switches and routers are
`
`listed in the main body of these Infringement Contentions
`
`and are identified as Accused Instrumentalities for
`
`various Defendants under the heading: “power sourcing
`
`equipment (data nodes).”
`
`
`
`[a-2] an access device
`
`Sample evidence (Sony statements, depictions, and other
`
`adapted for data
`
`documentation) includes:
`
`transmission
`
` “In addition, because these cameras incorporate a
`
`constant bitrate algorithm, they limit the data
`
`bitrate while maintaining high-quality images.”
`
`(SNC-RX Series Brochure) [N210208];
`
` “Supporting high Power over Ethernet (hPoE),
`
`the SNC-RS44/RS46 can be powered using the
`
`same Ethernet cable it uses for data transfer.”
`
`(SNC-RS Brochure) [N210203];
`
` “To connect the camera to a network, you need to
`
`assign a new IP address to the camera when you
`
`install it for the first time.” (CNC-
`
`
`8
`A router that transmits Ethernet packets or frames between Ethernet segments is an
`Ethernet switch (sometimes referenced as a Layer 3 switch). To the extent that such a router is
`not a “data node,” in the context of the ‘930 Patent, it is equivalent to a data node because a
`router (a) performs the same function, (b) in substantially the same way, (c) to obtain
`substantially the same result.
`
`
`
`14
`
`

`

`
`
`CH120/160/220/260 User Guide) [N252334];
`
` (SNC-CH110/210 Installation Manual)
`
`[N252229];
`
`
`
`
`
`
`
`
`
`
`
`15
`
`
`
`
`

`

`
`
`
`
`
`
`
`
`(SNC-CH160/260 Installation Manual)
`
`[N252563];
`
`
`
`Introducing the Sony SNC-RZ25, MPEG-4/JPEG
`
`network camera with a PTZ capability packaged
`
`
`
`
`16
`
`

`

`
`
`in a sleek and stylish body.” (SNC-RZ25N
`
`Brochure) [N210214];
`
` “Once the network connection is established,
`
`images from the camera can be efficiently
`
`streamed over the network.” (SNC-RZ25N
`
`Brochure) [N210214].
`
`
`
`802.3af, 802.3at, and 802.3-2008 Standards statements
`
`and depictions include:
`
`
`
`(IEEE 802.3af Standard Figure 33-4) [N12558];
`
`(IEEE802.3-2008 Standard Figure 33-4)
`
`[N236613]; (IEEE 802.3at Standard Figure 33-4)
`
`[N151877];
`
`
`
`
`17
`
`

`

`
`
`(IEEE 802.3at Standard Figure 33-5) [N151878].
`
` “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 no additional connections.” (IEEE
`
`802.3af Standard 33.1.1) [N12555]; (IEEE 802.3-
`
`2008 Standard 33.1.1) [N236610]; (IEEE 802.3at
`
`Standard 33.1.1.) [N151872].
`
`Power sourcing equipment (data nodes) are specifically
`
`designed for use with IEEE 802.3af and IEEE 802.3at
`
`compliant powered devices (access devices). The Sony
`
`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
`
`
`
`
`18
`
`

`

`
`
`– powered device (PD) is an access device adapted for
`
`data transmission.
`
`
`
`Identification: The “access device adapted for data
`
`transmission” is each of the powered devices (access
`
`devices) made by Sony or others, that are used in
`
`conjunction with the power sourcing equipment (data
`
`nodes, addressed above) that can receive and transmit
`
`data. Non-limiting examples of such access devices
`
`include (a) phones (including IP phones), (b) wireless
`
`access points, (c) cameras (e.g., security cameras), (d)
`
`magnetic card readers, and (e) video kiosks. Non-
`
`limiting examples of such access devices are also listed
`
`in the main body of these Infringement Contentions and
`
`are identified as Accused Instrumentalities for various
`
`Defendants under the headings: “powered devices (access
`
`devices).”
`
`
`
`[a-3] at least one data
`
`Sample evidence (Sony statements, depictions, and other
`
`signaling pair connected
`
`documentation) includes:
`
`between the data node and
`
` “Power can also be supplied via an Ethernet
`
`the access device and
`
`CAT5 cable from an IEEE 802.3af-compliant
`
`arranged to transmit data
`
`power supply system*.” (SNC-Z20N Brochure)
`
`therebetween
`
`[N210222];
`
` “LAN Connector {PoE} [RJ-45]
`
`Use network cable STP, category-5 (SNC-
`
`CH110) or network cable UTP, category-5
`
`(SNC-CH210) for network communications and
`
`19
`
`
`
`
`

`

`
`
`PoE power supply.” (SNC-CH110/210
`
`Installation Manual) [N252229];
`
` “This section provides the menus for connecting
`
`the camera through the network cable.” (SNC-
`
`C/DH120/160/220/260 User Guide) [N252376];
`
`
`
` (SNC-CS50 User Guide) [N252745];
`
` “Supporting high Power over Ethernet (hPoE),
`
`the SNC-RS44/RS46 can be powered using the
`
`same Ethernet cable it uses for data transfer.”
`
`(SNC-RS Brochure) [N210203];
`
`
`
`
`20
`
`

`

`
`
` (SNC-CH110/210 Installation Manual)
`
`[N252229];
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`21
`
`
`
`
`

`

`
`
`
`
`
`
`
`
`(SNC-CH160/260 Installation Manual)
`
`[N252563];
`
` “Using a commercially available network cable,
`
`connect the LAN port on the camera to a hub in
`
`
`
`
`22
`
`

`

`
`
`the network” (SNC-CS50N User Guide)
`
`[N252745].
`
`
`
`802.3af, 802.3at, and 802.3-2008 Standards statements
`
`and depictions include:
`
`
`
`(IEEE 802.3af Standard Table 33-1 and Figure
`
`33-5) [N12559]; (IEEE 802.3-2008 Standard
`
`Table 33-1 and Figure 33-5) [N236614]; (IEEE
`
`802.3at Standard Table 33-2 and Figure 33-8)
`
`[N151881];
`
`
`
`
`23
`
`

`

`
`
`
`
`(IEEE 802.3af Standard Figure 33-4) [N12558];
`
`(IEEE 802.3at Standard Figure 33-5) [N151878];
`
` “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.
`
`
`
`
`24
`
`

`

`
`
`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) [N12559]; (IEEE
`
`802.3-2008 Standard 33.2.2) [N236614]; (IEEE
`
`802.3at Standard 33.2.3) [N151881].
`
`Power sourcing equipment (data nodes) are designed to
`
`be connected to 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 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-TX, and 1000Base-T,
`
`this is 2 pair or greater Category 3, 4, 5, 5e or better cable
`
`designed and installed for data transmission. Under the
`
`802.3af and 802.3at Standards, 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.
`
`[N12558]. Table 33-1 details the particular pins that may
`
`be used by the data pairs. [N12559].
`
`
`
`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
`
`
`
`
`25
`
`

`

`
`
`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 non-
`
`limiting 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 sourcing equipment (data node) to the
`
`corresponding pins of the powered device (access
`
`device).
`
`
`
`[a-4] a main power source
`
`Sample evidence (Sony statements, depictions, and other
`
`connected to supply power
`
`documentation) includes:
`
`to the data node, and
`
` “Power can also be supplied via an Ethernet
`
`CAT5 cable from an IEEE 802.3af-compliant
`
`power supply system*.” (SNC-Z20N Brochure)
`
`[N210222];
`
`
`
` “They automatically adapt to whichever power
`
`source is used, making installation fast and
`
`effective.” (SNC-DM_DS Brochure) [N210168];
`
` See evidence for element [a-4] for other
`
`Defendants.
`
`
`
`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) [N12557]; (IEEE
`
`802.3-2008 Standard 33.2) [N236612];
`
`
`
`
`26
`
`

`

`
`
` “The PSE is the portion of the end station or
`
`midspan equipment that provides the power to a
`
`single PD.” (IEEE 802.3at Standard) [N151875].
`
`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.
`
`
`
`Identification: Power sourcing equipment (data nodes),
`
`used in connection with Sony powered devices (access
`
`devices), have access to “a main power source connected
`
`to supply power to the data node.” There are three
`
`theories 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 the data nodes:
`
`
`
`theory 1: The main power source that supplies
`
`power to the power sourcing equipment (data
`
`nodes, addressed above) is a DC power supply9
`
`that provides DC power to components of the
`
`data nodes. A non-limiting example of such a
`
`DC power supply is a power supply that
`
`provides 12V and 48V outputs to power
`
`
`9
`A power supply is a collection of electronic circuitry or components used to convert
`voltages and currents.
`
`
`
`27
`
`

`

`
`
`components of the data node.
`
`
`
`theory 2: The main power source is a
`
`combination of power supplies, arranged in
`
`series or parallel, that provides DC power to
`
`components of the data nodes. 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 power rack.
`
`
`
`theory 3: The main power source is an AC
`
`power source provided via a power cord that is
`
`adapted to connect an AC outlet to the power
`
`sourcing equipment (data nodes). The
`
`connection can be established by, for example,
`
`plugging one end of the power cord into a
`
`dedicated grounded AC outlet or power strip
`
`and the other end into the AC power socket of
`
`the data node.10
`
`
`
` doctrine of equivalents: To the extent that the
`
`
`10
`For example, switches and routers (data nodes) are often sold with a power cord adapted
`for connection to an AC outlet, either directly or using an external power supply, connected to
`supply main power to the switches and routers (and to semiconductor logic circuits within the
`switch).
`
`
`
`
`28
`
`

`

`
`
`contentions described above do not constitute
`
`literal infringement of this element, they constitute
`
`infringement under the doctrine of equivalents.
`
`
`
`doctrine of equivalents for theory 3: To the
`
`extent that an AC source of power is not literally
`
`a main power source, an AC source of power, in
`
`the context of the ‘930 Patent, is equivalent to a
`
`main power source (if a main power source is
`
`limited to a DC source of power) because an AC
`
`and DC source of power are interchangeable (they
`
`can be converted back and forth) and perform (a)
`
`substantially the same function, (b) in
`
`substantially the same way, (c) to obtain
`
`substantially the same result.11 Specifically,
`
`whether the power source is originally DC or AC,
`
`that is converted into DC, is immaterial in the
`
`context of the invention.12
`
`doctrine of equivalents for theory 2: To the
`
`extent that a combination of power supplies (e.g.,
`
`a combination of power supplies in serial or in
`
`
`11
`From a technical perspective, there is really no such thing as “AC power” or “DC
`power.” Power is measured in watts. AC and DC refer to the current flow and are related to the
`waveform of the current through a load (i.e., the voltage waveform applied to the load).
`
`12
`Both an AC power source (e.g., AC outlet or power cord) and a DC power source are
`sources of power that are arranged to supply operating power to the power sourcing equipment
`(data nodes) by providing power that meets, or can be converted to meet, the power requirements
`(e.g., voltages) that can be used by the internal circuitry of the power sourcing equipment (data
`nodes) to perform the appropriate functions.
`
`
`
`
`29
`
`

`

`
`
`parallel) is not literally a main power source, such
`
`a combination would constitute a main power
`
`source under the doctrine of equivalents because
`
`such a combination performs (a) substantially the
`
`same function, (b) in substantially the same way,
`
`(c) to obtain substantially the same result.13
`
`Specifically, whether the power supply consists of
`
`a single power supply or multiple power supplies,
`
`in series, in parallel, or a combination of both, is
`
`immaterial in the context of the invention.
`
`
`
`[a-5] a secondary power
`
`Sample evidence (Sony statements, depictions, and other
`
`source arranged to supply
`
`documentation) includes:
`
`power from the data node
`
`
`
` “Power can also be supplied via an Ethernet
`
`via said data signaling pair
`
`CAT5 cable from an IEEE 802.3af-compliant
`
`to the access device,
`
`power supply system*.” (SNC-Z20N Brochure)
`
`[N210222];
`
` See evidence for element [a-4];
`
` See evidence for element [a-5] for other
`
`Defendants.
`
`
`
`802.3af, 802.3at, and 802.3-2008 Standards statements
`
`and depictions include:
`
`
`13
`A single power supply or combination of power supplies provides the source of power to
`the electrical circuitry of the power sourcing equipment (data node) and the low level current by
`providing a source of power that meets, or can be converted to meet, the power requirements
`(e.g., voltages) of at least some internal circuitry of the power sourcing equipment (data nodes)
`to perform their appropriate functions.
`
`
`
`30
`
`

`

`
`
`
`
`(IEEE 802.3af Standard Figure 33-4); [N12558];
`
`(IEEE 802.3-2008 Standard Figure 33-4)
`
`[N236613]; (IEEE 802.3at Standard Figure 33-4)
`
`[N151877];
`
`(IEEE 802.3at Standard Figure 33-5) [N151878];
`
` “DTE powering is intended to provide a
`
`10BASE-T, 100BASE-TX, or 1000BASE –T
`
`31
`
`
`
`
`

`

`
`
`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)
`
`[N236610]; (IEEE 802.at Standard 33.1.1)
`
`[N151872].
`
` “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) [N12571]; (IEEE
`
`802.3-2008 Standard 33.2.8.4) [N236626];
`
` “33.2.8.1 Output voltage. The specification for
`
`VPort in Table 33–5 shall include line and
`
`
`
`
`32
`
`

`

`
`
`temperature variations. The voltage potential
`
`shall be measured between any conductor of one
`
`power pair and any conductor of the other power
`
`pair.” (IEEE 802.3af Standard 33.2.8.1)
`
`[N12571]; (IEEE 802.3-2008 Standard 33.2.8.1)
`
`[N236626];
`
`
`
` (IEEE 802.3at Standard Table 33-11) [N151898-
`
`99];
`
` “When the PSE provides power to the PI, it shall
`
`conform with Table 33-11.” (IEEE 802.3at at
`
`33.2.7) [N151898].
`
`IEEE 802.3af and IEEE 802.at compliant power sourcing
`
`equipment have a source of secondary power which
`
`provides operating power from the Switch/Hub (the
`
`Power Sourcing Equipment (PSE)) to the Powered End
`
`Station (Powered Device (PD)).
`
`33
`
`
`
`
`

`

`
`
`
`
`Identification: Power sourcing equipment (data nodes,
`
`addressed above) used in connection with Sony’s
`
`powered devices (access devices), use “a secondary
`
`power source arranged to supply power from the data
`
`node via said data signaling pair to the access device.”
`
`When a properly configured powered device (access
`
`device, addressed above) is detected, the secondary
`
`power source supplies power (for example (non-
`
`limiting), 48 Volts DC for an access device that requires
`
`such a power load) from the power sourcing equipment
`
`(data node, addressed above) through the data signaling
`
`pairs (addressed above, e.g., Ethernet Category 5 cables)
`
`to the powered device (access device) to supply operating
`
`power to the powered device (access device) under the
`
`following two theories:
`
`theory 1: the power sourcing equipment (data
`
`nodes) incorporate a control valve or switch
`
`(which may be part of an integrated circuit) that
`
`controls the application of power to the access
`
`device derived from the main power source
`
`(addressed above). The control valve or switch
`
`(for example (non-limiting), a MOSFET switch or
`
`other transistor) is electrically located between the
`
`main power source and the access device, and is a
`
`downstream or separate driving point from the
`
`main power source, for the function of providing
`
`operating power to the powered device (access
`
`34
`
`
`
`
`

`

`
`
`device).
`
`theory 2: The secondary power source is the
`
`same source of power as the main power source.
`
`Under this theory, the secondary power source is
`
`the source of secondary power that provides
`
`power for the secondary function of supplying
`
`power from the data node via said data signaling
`
`pair to the powered device (access device) which
`
`occurs, under certain circumstances, after the
`
`main power source performs the main or primary
`
`functions of (i) providing power to the power
`
`sourcing equipment (data nodes), and (ii)
`
`delivering the low level current to the powered
`
`device (access devices). The power sourcing
`
`equipment (data nodes) use a secondary power
`
`source (source of secondary power) which can be
`
`the same as the main power source under the
`
`three theories for main power source set forth
`
`above (e.g., (i) a power supply, (ii) a multiple
`
`power supply configuration, or (iii) the AC outlet
`
`or power strip connected to the power sourcing
`
`equipment (data node) using a power cord.
`
`
`
`doctrine of equivalents: To the extent that the
`
`contentions described above do not constitute literal
`
`infringement of this element, they constitute infringement
`
`under the doctrine of equivalents. To the extent that the
`
`main power source and the secondary power source are
`
`
`
`
`35
`
`

`

`
`
`required to be separate, a power source that is arranged to
`
`supply power from the data node via said data signaling
`
`pair to the access device, that is the same source of power
`
`as the main power source, is equivalent to a separate
`
`main and secondary power source because it (a) performs
`
`the same function – supplying power from the power
`
`sourcing equipment (data node) to the powered device
`
`(access device), (b) in substantially the same way – via
`
`the data signaling pair, (c) to obtain substantially the
`
`same result – provide operating power to power the
`
`powered device (access device).
`
`
`
`[b] delivering a low level
`
`Sample evidence (Sony statements, depictions, a