`
`
`
`
`
`
`
`
`See SkyCaddie SGX User Guide at pages 13 and 14.
`Below are exemplary screen shots showing recording and reporting golf scores and statistics.
`
`
`
`
`
`information to increase a player’s ability to improve from experience.
`The Accused Products are handheld portable apparatuses for recording and reporting golf
`Infringing Instrumentalities
`operate the Accused Products.
`fulfillment of the above-recited claim feature by selling its Accused Products to end-users who
`through print and web advertisements and user manuals. SkyHawke actively contributed to
`above-recited claim feature by encouraging the use of the Accused Products, for example,
`SkyHawke actively induced end-users to operate the Accused Products so as to fulfill the
`
`
`
`entered by a user and reports scores and statistics.
`For example, the Accused Products record golf scores, number of putts, and other statistics
`
`the apparatus comprising:
`ability to improve from experience,
`information to increase a player’s
`for recording and reporting golf
`17. A handheld portable apparatus
`Claim 17:
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 1
`
`
`
` Exhibit A – Page 124
`
`
`
`
`
`
`See also, SkyCaddie SGX User Guide at page 14, stating:
`
`
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 2
`
`
`
` Exhibit A – Page 125
`
`port. See SkyCaddie SGX User Guide at page 3.
`Below is an exemplary product illustration showing the display screen and power Micro-USB
`
`the associated data.
`stored in the memory, the information screens including screen-dependent data input fields for
`and a display for selectively displaying a plurality of information screens and associated data
`The Accused Products include a self-contained computer unit having a memory, a power source
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`
`
`
`
`for the associated data;
`screen-dependent data input fields
`information
`including
`data stored in the memory, the
`information screens and associated
`displaying
`of
`source and a display for selectively
`unit having a memory, a power
`17a. a, self-contained computer
`
`plurality
`
`screens
`
`a
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 3
`
`
`
`screen dependent data input fields. See SkyCaddie SGX User Guide at pages 13 and 14.
`Below are exemplary product screen shots showing a plurality of information screens with
`
`
`
`
`
` Exhibit A – Page 126
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 4
`
`
`
` Exhibit A – Page 127
`
`SGX User Guide at page 9.
`Note that the right key’s function is to display the next screen in the sequence. See SkyCaddie
`pre-game information screens used for manually selecting a golf course for an upcoming game.
`Below is an exemplary excerpt from the SkyCaddie SGX User Guide showing a sequence of
`
`
`
`Sequence of pre-game information screens:
`
`
`
`operation, the first key entry means comprising one entry key.
`displaying one or more game-interactive information screens in a game-interactive mode of
`pre-game information screens in a pre-game mode of operation, and subsequently sequentially
`The Accused Products include a first key entry means for sequentially displaying one or more
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`
`
`
`
`
`
`comprising one entry key;
`operation, the first key entry means
`game-interactive
`of
`interactive information screens in a
`displaying one or more game-
`and
`sequentially
`in a pre-game mode of operation,
`more pre-game information screens
`sequentially displaying one or
`17b. first key entry means for
`
`subsequently
`
`mode
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 5
`
`
`
` Exhibit A – Page 128
`
`screens. See SkyCaddie SGX User Guide at pages 7 and 13.
`Below are exemplary product screen shots showing an example sequence of game interactive
`
`
`
`
`
`Sequence of game-interactive information screens:
`
`
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`
`
`SKYHAWKE Ex. 1013, page 6
`
`
`
` Exhibit A – Page 129
`
`SkyCaddie SGX User Guide at page 13.
`are finished, simply press “Next” using the Right Key to continue to the next hole.” See
`moving the Joystick left/right on the Scorecard screen (the score will default to par). When you
`the number of shots it took to complete the hole. You can enter your total score for each hole by
`“At the end of each hole, you will be prompted with the Digital Scorecard where you can input
`
`
`
`
`
`Joystick. To enter additional stats.” See SkyCaddie SGX User Guide at page 14.
`“If you want to track additional stats including Putts and Fairways Hit, select the hole using the
`
`
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 7
`
`
`
` Exhibit A – Page 130
`
`displayed information screen, the second key means comprising two bi-directional keys.
`The Accused Products include a second key means for selecting a particular data field on a
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`
`
`
`
`User Guide at page 3.
`key means, including the up and down keys accessed by the joystick. See SkyCaddie SGX
`Below is an exemplary product illustration showing the second screen dependent field select
`
`
`
`
`
`bi-directional keys;
`second key means comprising two
`a displayed information scree, the
`selecting a particular data field on
`for
`17c.
`
` second key means
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 8
`
`
`
`screen dependent manner. See SkyCaddie SGX User Guide at pages 13 and 14.
`up and down keys allow a user to scroll in opposite directions through data input fields in a
`and down. Below are exemplary product screen shots showing information screens where the
`The up and down keys accessed by the joystick allow a user to select data fields by tabbing up
`
`
`
`
`
` Exhibit A – Page 131
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 9
`
`
`
` Exhibit A – Page 132
`
`selected data field, the third key means comprising two bi-directional keys.
`The Accused Products include a third key means for selectively recording or altering data in a
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`
`
`
`
`
`
`User Guide at page 3.
`key means, including the left and right keys accessed by the joystick. See SkyCaddie SGX
`Below is an exemplary product illustration showing the second screen dependent field select
`
`
`
`
`
`directional keys; wherein,
`third key means comprising two bi-
`data in a selected data field, the
`selectively recording or altering
`for
`17d.
`
`third key means
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 10
`
`
`
`SkyCaddie SGX User Guide at pages 13 and 14.
`in opposite directions through the predefined data associated with a data input field. See
`information screens where the left and right keys accessed by the joystick allow a user to scroll
`selected data in a data input field. Below are exemplary product screen shots showing
`The left and right keys accessed by the joystick allow a user to selectively record and alter
`
`
`
`
`
` Exhibit A – Page 133
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 11
`
`
`
` Exhibit A – Page 134
`
`recording screen that does not allow this level of recording detail.
`detail in the game-interactive mode, e.g., a recording screen that allows input of “putts” or a
`selecting game-interactive information screens representing different levels of data-recording
`For example, the screen shots below show pre-game information screens that include means for
`
`
`
`
`
`recording detail in the game-interactive mode.
`of a plurality of game-interactive information screens representing different levels of data-
`the entry of data which defines parameters of an upcoming game, and means for selecting one
`The Accused Products include pre-game information screens that include means for prompting
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`
`
`
`
`
`
`mode.
`detail
`the game-interactive
`different levels of data-recording
`information screens representing
`of a plurality of game-interactive
`game, and means for selecting one
`defines parameters of an upcoming
`prompting the entry of data which
`screens
`for
`17e. the pre-game information
`
`include means
`
`in
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 12
`
`
`
` Exhibit A – Page 135
`
`See SkyCaddie SGX User Guide at pages 13 and 14.
`Below are exemplary screen shots showing recording and reporting golf scores and statistics.
`
`
`
`entered by a user and reports scores and statistics.
`For example, the Accused Products record golf scores, number of putts, and other statistics
`
`
`
`
`
`ability to improve from experience.
`The Accused Products are used to record and report golf information to increase a player’s
`Infringing Instrumentalities
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`
`
`
`
`
`
`
`
`
`
`comprising the following steps:
`improve
`experience,
`increase a player’s ability
`to
`information
`reporting golf
`to
`18. A method for recording and
`Claim 18:
`
`from
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 13
`
`
`
` Exhibit A – Page 136
`
`
`
`
`
`
`
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 14
`
`
`
` Exhibit A – Page 137
`
`
`
`
`
`
`See also, SkyCaddie SGX User Guide at page 14.
`
`
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 15
`
`
`
` Exhibit A – Page 138
`
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`
`
`
`
`entry keys.
`The Accused Products include a computer unit with a memory, a display and data selection
`operate the Accused Products.
`fulfillment of the above-recited claim feature by selling its Accused Products to end-users who
`through print and web advertisements and user manuals. SkyHawke actively contributed to
`above-recited claim feature by encouraging the use of the Accused Products, for example,
`SkyHawke actively induced end-users to operate the Accused Products so as to fulfill the
`
`3.
`keys accessed by what SkyHawke calls a “joystick.” See SkyCaddie SGX User Guide at page
`labeled at least as the “right key,” “left key,” “menu button,” and the left/right and up/down
`Below is an exemplary product illustration showing the display and data selection entry keys,
`
`
`
`
`
`selection entry keys;
`with a memory, a display and data
`18a. providing a computer unit
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 16
`
`
`
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`
`
`
`
` Exhibit A – Page 139
`
`fields corresponding to the golf play information of each information screen.
`memory of the computer unit, the information screens including screen-dependent data input
`The Accused Products store a plurality of information screens of golf play information in the
`operate the Accused Products.
`fulfillment of the above-recited claim feature by selling its Accused Products to end-users who
`through print and web advertisements and user manuals. SkyHawke actively contributed to
`above-recited claim feature by encouraging the use of the Accused Products, for example,
`SkyHawke actively induced end-users to operate the Accused Products so as to fulfill the
`
`
`
`computer unit,
`information
`information in the memory of the
`information screens of golf play
` storing a plurality of
`18b.
`
`the
`
`SKYHAWKE Ex. 1013, page 17
`
`
`
` Exhibit A – Page 140
`
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`information screens are displayed to prompt the entry of data which defines parameters of an
`The Accused Products provide a pre-game mode of data entry in which one or more pre-game
`operate the Accused Products.
`fulfillment of the above-recited claim feature by selling its Accused Products to end-users who
`through print and web advertisements and user manuals. SkyHawke actively contributed to
`above-recited claim feature by encouraging the use of the Accused Products, for example,
`SkyHawke actively induced end-users to operate the Accused Products so as to fulfill the
`
`
`
`
`
`
`
`
`
`of data entry in which one or more
`18c. providing a pre-game mode
`
`dependent data input fields. See SkyCaddie SGX User Guide at pages 13 and 14.
`Below are exemplary SC screen shots showing a plurality of information screens with screen
`
`
`
`information screen;
`the golf play information of each
`data input fields corresponding to
`screens including screen-dependent
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 18
`
`
`
` Exhibit A – Page 141
`
`
`
`
`Advanced Play modes, and to choose between scoring modes.
`information screens. The data input fields, e.g., allow the user to choose between Basic and
`The exemplary product screen shots below show exemplary pre-game parameter recording
`
`
`
`levels of data recording detail
`information screens in a subsequent game-interactive mode of operation representing different
`upcoming game, and provides a choice of at least one of a plurality of game-interactive
`
`
`
`levels of data recording detail;
`of operation representing different
`subsequent game-interactive mode
`information
`a
`plurality
`game-interactive
`a choice of at least one of a
`an upcoming game, and providing
`data which defines parameters of
`displayed to prompt the entry of
`pre-game information screens are
`
`in
`
`screens
`
`of
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 19
`
`
`
`SkyCaddie SGX User Guide at pages 9, 10, 11, 17, and 20.
`The exemplary product screen shots below show other pre-game information screens. See
`
`
`
`
`
` Exhibit A – Page 142
`
`
`
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 20
`
`
`
` Exhibit A – Page 143
`
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 21
`
`
`
` Exhibit A – Page 144
`
`
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 22
`
`
`
` Exhibit A – Page 145
`
`
`
`
`
`
`
`
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 23
`
`
`
` Exhibit A – Page 146
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 24
`
`
`
`13 and 14.
`representing different levels of data recording detail. See SkyCaddie SGX User Guide at pages
`For example, see the product screen shots below that illustrate game-interactive screens
`
`
`
`
`
` Exhibit A – Page 147
`
`
`
`
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 25
`
`
`
` Exhibit A – Page 148
`
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`
`
`
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`
`
`
`
`entry of game data as the game is played.
`the pre-game mode, and display a chosen game-interactive recording information screen for
`The Accused Products are used to enter the game-interactive mode during the game defined in
`operate the Accused Products.
`fulfillment of the above-recited claim feature by selling its Accused Products to end-users who
`through print and web advertisements and user manuals. SkyHawke actively contributed to
`above-recited claim feature by encouraging the use of the Accused Products, for example,
`SkyHawke actively induced end-users to operate the Accused Products so as to fulfill the
`
`The exemplary product screen shots below show one or more game-interactive recording
`
`
`
`recording information screen for
`a
`game-interactive
`the pre-game mode, and displaying
`mode during the game defined in
`18d. entering the game-interactive
`
`chosen
`
`SKYHAWKE Ex. 1013, page 26
`
`
`
` Exhibit A – Page 149
`
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`factual reports for retrieval by the player after the game.
`The Accused Products stores the recorded golf information in the memory as statistical or
`operate the Accused Products.
`fulfillment of the above-recited claim feature by selling its Accused Products to end-users who
`through print and web advertisements and user manuals. SkyHawke actively contributed to
`above-recited claim feature by encouraging the use of the Accused Products, for example,
`SkyHawke actively induced end-users to operate the Accused Products so as to fulfill the
`
`
`
`
`
`
`
`
`
`in
`the memory as
`the recorded golf
`
`information
`18e. storing
`
`fields and change the value thereof. See SkyCaddie SGX User Guide at pages 13 and 14.
`information screens. The data input fields, e.g., allow the user to select “score” and “putts”
`
`
`
`played; and
`entry of game data as the game is
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 27
`
`
`
` Exhibit A – Page 150
`
`result as the requirement of the claim.
`same function and (2) work in substantially the same way (3) to achieve substantially the same
`forth above to be “insubstantial” or would have found that they: (1) perform substantially the
`would have considered the differences between the claim language and the product features set
`nonetheless infringe under the doctrine of equivalents. A person having ordinary skill in the art
`To the extent that the Accused Products are not found to literally infringe the limitation, they
`
`operate the Accused Products.
`fulfillment of the above-recited claim feature by selling its Accused Products to end-users who
`through print and web advertisements and user manuals. SkyHawke actively contributed to
`above-recited claim feature by encouraging the use of the Accused Products, for example,
`SkyHawke actively induced end-users to operate the Accused Products so as to fulfill the
`
`
`
`
`
`
`
`
`
`SkyCaddie SGX User Guide at page 14.
`and can be viewed at any point during the game or afterwards on a summary screen. See
`multiple selectable data input screens for tracking golf statistics. The golf statistics are stored
`Below are exemplary product screen shots showing an example information screen with
`
`
`
`
`
`
`
`game.
`retrieval by the player after the
`statistical or factual reports for
`
`PLAINTIFF L&H CONCEPTS, LLC’S DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
`SKYHAWKE Ex. 1013, page 28
`
`