`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`1. A remote control system
`with data coupling including:
`
`
`Logitech’s manufacture, sale, offer for sale, and use in the United States and importation into the United
`States of certain remote controls and related technology, including but not limited to the following
`accused systems, products and services: Harmony H300, H650, H700, H900, One, and H1100 remote
`controls, associated software and hardware, programming and data available on cd, Logitech’s website
`and/or from Logitech’s database, and any similar products and related technology, constitutes
`infringement of at least Claims 1, 9, 10, 11, and 14 of the ‘761 Patent under 35 U.S.C. § 271 (a), (b), and
`(c).
`
`More specifically, Logitech infringes Claims 1, 9, 10, 11, and 14 of the ‘761 Patent under § 271 (a)
`through its manufacture, importation, use, operation, configuration, control, and testing of its Harmony
`H300, H650, H700, H900, One, and H1100 remote controls, associated software and hardware,
`programming and data available on cd, Logitech’s website and/or from Logitech’s database, and any
`similar products and related technology.
`
`Logitech also infringes Claims 1, 9, 10, 11, and 14 of the ‘761 Patent under § 271 (b) and (c) through its
`sale and offer to sell in the United States, Harmony H300, H650, H700, H900, One, and H1100 remote
`controls, to customers or users along with instructions and associated software and hardware,
`programming and data for use, activation, set-up, and operation of its Harmony H300, H650, H700,
`H900, One, and H1100 remote controls. Logitech’s actions constitute active inducement of infringement
`of Claims 1, 9, 10, 11, and 14 of the ‘761 Patent by these users and also constitute contributory
`infringement insofar as Logitech offers to sell and sells within the United States, and/or imports into the
`United States, a component of a patented machine, manufacture, combination, or composition, or a
`material or apparatus for use in practicing a patented process claimed in Claims 1, 9, 10, 11, and 14 of the
`‘761 Patent, which constitutes a material part of the claimed process, knowing the same to be especially
`made or especially adapted for use in an infringement of Claims 1, 9, 10, 11, and 14 of the ‘761 Patent,
`and not a staple article or commodity of commerce suitable for substantial noninfringing use. Such
`instructions and associated software, programming and data include guides, manuals and applications on
`how to use, activate, set-up, and operate the Harmony H300, H650, H700, H900, One, and H1100 remote
`controls, that is provided with the remote controls in written form or on a cd or other medium, and any
`guides, instructions and associated software, programming and data available online on Logitech’s
`website at www.logitech.com. In turn, the users of the Harmony H300, H650, H700, H900, One, and
`
`
`
`1
`
`Universal Electronics Exhibit 2032, Page 1
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`H1100 remote controls who use, activate, set-up, and operate such infringing technology, infringe Claims
`1, 9, 10, 11, and 14 of the ‘761 Patent under § 271 (a).
`
`
`
`Logitech Harmony 300 Universal Remote
`
`“Logitech® Harmony® 300 Remote.” (H300 Quick-start Guide, UE015160.) The Harmony 300 makes
`it easy to sit back and enjoy better control of your entertainment devices.” (H300 Quick-start Guide,
`UE015166.)
`
`“Simple online setup. Just connect your remote to your computer. Find your devices from a simple
`software menu. Download a full set of commands into your remote. No more codes you can’t find. No
`more buttons that don’t work.” (H300 Packaging, UE015159.)
`
`
`Logitech Harmony 650 Universal Remote
`
`
`“The Harmony 650 is an Activity-based infrared (IR) universal remote control” (H650 User Manual, p. 4,
`UE015344.)
`
`“Works with 5000+ brands Our online library includes more than 225,000 devices—and the list grows
`every day. So your remote is never out of date.” (H650 Packaging, UE015138.)
`
`
`
`
`2
`
`Universal Electronics Exhibit 2032, Page 2
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`(H650 User Manual, p. 12, UE015352.)
`
`
`
`
`
`Logitech Harmony 700 Universal Remote
`
`
`“The Harmony 700 is an Activity-based infrared (IR) universal remote control.” (H700 User Manual, p.
`1, UE015381.)
`
`“Yes it works with your system How can you be sure? Harmony already supports more than 5,000
`brands and 225,000 devices. And with more added every day, you’ll be covered tomorrow, too.” (H700
`Packaging, UE015085.)
`
`
`
`
`3
`
`Universal Electronics Exhibit 2032, Page 3
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`
`
`(H700 User Manual, p. 8, UE015388.)
`
`
`
`Logitech Harmony 900 Universal Remote
`
`
`“The Harmony 900 is an Activity-based universal remote control.” (H900 User Manual, p. 6.)
`
`“It’s possible that a device’s commands may not be recognized. Maybe you have a very rare device? Or
`a new one? Although we update our device list regularly, there are always new devices in the market. To
`remedy this, you can teach your Harmony how to control this device by using the device’s original
`remote.” (H900 User Manual, p. 35, UE054467.)
`
`
`
`
`4
`
`Universal Electronics Exhibit 2032, Page 4
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`(H900 User Manual, p. 13, UE054445.)
`
`
`
`Logitech Harmony One Universal Remote
`
`
`
`
`“The Harmony One is an Activity-based infrared (IR) universal remote control.” (One User Manual, p. 4,
`UE015456.)
`
`“From Betamax to Blu-ray™ and beyond Harmony already works with more than 5,000 brands and
`225,000 devices. And our library of home entertainment devices grows every day. So, you can be sure
`your remote will work with what you own today and what you add tomorrow.” (One Packaging,
`UE015180.)
`
`
`
`
`
`5
`
`Universal Electronics Exhibit 2032, Page 5
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`
`
`(One User Manual, p. 13, UE015465.)
`
`
`
`Logitech Harmony 1100 Universal Remote
`
`
`“The Harmony 1100 is an Activity-based infrared (IR) universal remote control.” (H1100 User Manual,
`p. 5, UE015407.)
`
`“It’s possible that a device’s commands are not recognized by your Harmony 1100. Maybe you have a
`very rare device? Or a new one? Although we update our device list regularly, there are always new
`devices in the market. To remedy this, you can teach your Harmony remote how to control this device by
`using the device’s original remote.” (H1100 User Manual, p. 26, UE015428.)
`
`
`
`
`6
`
`Universal Electronics Exhibit 2032, Page 6
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`(H1100 User Manual, p. 14, UE015416.)
`
`
`
`The Harmony H300, H650, H700, H900, One, and H1100 remotes are each a remote control.
`
` •
`
`“Logitech® Harmony® 300 Remote.” (H300 Quick-start Guide, UE015160.) The Harmony 300
`
`makes it easy to sit back and enjoy better control of your entertainment devices.” (H300 Quick-start
`Guide, UE015166.)
`
`a remote control comprising
`
`
` •
`
`“The Harmony 650 is an Activity-based infrared (IR) universal remote control” (H650 User
`
`Manual, p. 4, UE015344.)
`
` •
`
`“The Harmony 700 is an Activity-based infrared (IR) universal remote control.” (H700 User
`
`Manual, p. 1, UE015381.)
`
` •
`
`“The Harmony 900 is an Activity-based universal remote control.” (H900 User Manual, p. 6,
`
`UE054438.)
`
`
`
`
`7
`
`Universal Electronics Exhibit 2032, Page 7
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`“The Harmony One is an Activity-based infrared (IR) universal remote control.” (One User
`•
`Manual, p. 4, UE015456.)
`
` •
`
`“The Harmony 1100 is an Activity-based infrared (IR) universal remote control.” (H1100 User
`
`Manual, p. 5, UE015407.)
`
`Further, each of the H300, H650, H700, H900, One, and H1100 remotes meets this limitation under the
`doctrine of equivalents, at least because any corresponding control used by the H300, H650, H700, H900,
`One, and H1100 performs the same function as the claimed remote control, in the same way, to achieve
`the same result.
`
`input means including a set of
`keys or pushbuttons for
`inputting commands into the
`remote control,
`
`
`The Harmony H300, H650, H700, H900, One, and H1100 remotes have input means including a set of
`keys or pushbuttons for inputting commands into the remote control.
`
`
`Logitech Harmony H300 Universal Remote
`
`
`
`8
`
`
`(H300 Buttons 2.pdf - H300 Website, UE054524.)
`
`Universal Electronics Exhibit 2032, Page 8
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`Logitech Harmony H650 Universal Remote
`
`
`(H650 User Manual, UE015345.)
`
`
`
`
`
`
`
`
`
`
`
`9
`
`Universal Electronics Exhibit 2032, Page 9
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`Logitech Harmony H700 Universal Remote
`
`(H700 User Manual, UE015382.)
`
`
`
`
`
`
`
`
`
`
`
`10
`
`Universal Electronics Exhibit 2032, Page 10
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`Logitech Harmony H900 Universal Remote
`
`
`(H900 User Manual, p. 8, UE054440.)
`
`
`
`
`
`
`
`
`
`11
`
`Universal Electronics Exhibit 2032, Page 11
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`Logitech Harmony ONE Universal Remote
`
`
`(One User Manual, p. 4, UE015457.)
`
`
`
`
`
`
`
`12
`
`Universal Electronics Exhibit 2032, Page 12
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`Logitech Harmony H1100 Universal Remote
`
`
`(H1100 User Manual, UE015408.)
`
`Further, each of the H300, H650, H700, H900, One, and H1100 remotes meets this limitation under the
`doctrine of equivalents at least because any input means used by the H300, H650, H700, H900, One, and
`H1100 remotes, including any after-arising technology, performs the same function as the claimed input
`means, in the same way, to achieve the same result.
`
`
`
`infrared signal output means
`
`The Harmony H300, H650, H700, H900, One, and H1100 remotes have infrared signal output means
`
`
`
`13
`
`Universal Electronics Exhibit 2032, Page 13
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`including IR lamp driver means
`for supplying an infrared signal
`to a controlled device,
`
`
`including IR lamp driver means for supplying an infrared signal to a controlled device.
`
`
`Logitech Harmony 300 Universal Remote
`
`The H300 can learn IR codes from other remote controls, (H300 Packaging, UE015159,)
`that, themselves, supply an infrared signal to a controlled device. Further, the H300, as a universal remote
`control, replaces such other remote controls. (H300 Packaging, UE015159.) If the H300 did not have
`infrared signal output means for supplying an infrared signal, then the H300 would be unable to control a
`device, such as a TV, using the H300, rendering the H300 useless. Therefore, the H300 has infrared
`signal output means including IR lamp driver means for supplying an infrared signal to a controlled
`device.
`
`
`“Simple online setup. Just connect your remote to your computer. Find your devices from a simple
`software menu. Download a full set of commands into your remote. No more codes you can’t find. No
`more buttons that don’t work.” (H300 Packaging, UE015159.)
`
`“4. Try your remote Once you’ve completed the online setup and synced your Harmony 300, please try
`it out. A. Unplug your Harmony 300 from your computer and take it to your entertainment system. B.
`Point your Harmony 300 at your television and try it to confirm that it works.” (H300 Quick Start Guide,
`UE015162.)
`
`
`Logitech Harmony 650 Universal Remote
`
`
` “The Harmony 650 is an Activity-based infrared (IR) universal remote control. Using the Harmony
`Remote Software, you can configure the Harmony 650 to control up to 5 devices.” (H650 User Manual,
`p. 4, UE015344.)
`
`“IR Status Indicator The status indicator flashes whenever an IR command is being sent from your
`Harmony 650.” (H650 User Manual, p. 6, UE015346.)
`
`“Because obstacles or distance can interfere with the signals the Harmony 650 sends when it starts an
`
`
`
`14
`
`Universal Electronics Exhibit 2032, Page 14
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`Activity (For example, someone walks between your Harmony 650 and the TV when you press Watch
`TV, or you’re very far away from the system when you start an activity), your Harmony 650 can become
`‘out of sync’ with your devices.” (H650 User Manual, p. 8, UE015348.)
`
`“IR Learning│Yes (Up to 200Khz);” “Learning Capabilities│Any IR Device (Up to 200Khz);” “IR
`Transmitters│2;” “IR Transmission Range│Up to 50 ft.” (H650 User Manual, p. 35, UE015375.)
`
`
`Logitech Harmony 700 Universal Remote
`
`
`“The Harmony 700 is an Activity-based infrared (IR) universal remote control. Using Harmony software,
`you can set up the Harmony 700 to control up to 8 devices.” (H700 User Manual, p. 1, UE015381.)
`
`“IR Status Indicator The status indicator flashes in the bottom right corner whenever command is being
`sent from your Harmony 700.” (H700 User Manual, p. 3, UE015383.)
`
`“Because obstacles or distance can interfere with the signals the Harmony 700 sends when it starts an
`Activity (for example, someone walks between your Harmony 700 and the TV when you press Watch
`TV, or you’re very far away from the system when you start an activity), your Harmony 700 can become
`‘out of sync’ with your devices.” (H700 User Manual, p.6, UE015386.)
`
`“IR Learning│Yes (Up to 200Khz);” “Learning Capabilities│Any IR Device;” “IR Transmitters│2;” “IR
`Transmission Range│Up to 50 ft.” (H700 User Manual, p. 21, UE015401.)
`
`
`Logitech Harmony 900 Universal Remote
`
`The Logitech Harmony 900 Universal Remote emits both infrared (IR) as well as radio frequency (RF)
`signals. The H900 emits IR signals when used to control devices having a direct line of sight to the H900.
`However, when the controlled device is located, for example, behind a closed cabinet door, the H900 can
`be configured to emit RF signals, which, unlike IR signals, travel through objects. An RF receiver
`receives the emitted RF signals from the H900, converts them to IR signals, and emits IR signals to any
`in-range controlled devices.
`
`
`
`15
`
`Universal Electronics Exhibit 2032, Page 15
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`
`“Your RF System allows you to control devices that are behind closed doors. Remote controls generally
`use infrared (IR) commands to communicate with your devices. These IR commands need a direct line
`of sight between the remote and the device to work. Your Harmony 900 also sends radio frequency (RF)
`signals, like the ones used for cordless phones, that can go through objects, such as a closed cabinet door.
`Your RF system converts these signals into IR commands that reach the devices and perform the
`requested action, such as turning on your TV or playing your DVD.” (H900 User Manual, p. 7,
`UE054439.)
`
`“Here’s how it works:
`•
`You press Watch TV on your Harmony 900 to start watching the news
`•
`The RF signals are sent from your Harmony 900 through your cabinet door
`•
`The Harmony 900 RF System converts the signals into IR commands
`•
`The IR commands reach your TV and your cable box
`•
`Your TV and cable box turn on”
`(H900 User Manual, p. 7, UE054439.)
`
`
`
`
`16
`
`Universal Electronics Exhibit 2032, Page 16
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`(H900 User Manual, p. 7, UE054439.)
`
`
`
`
`“IR Learning│Yes (Up to 500Khz);” “Learning Capabilities│Any IR Device;” “IR Transmitters│2;” “IR
`Transmission Range│Up to 65 ft.” (H900 User Manual, p. 59, UE054491.)
`
`
`Logitech Harmony ONE Universal Remote
`
`“The Harmony One is an Activity-based infrared (IR) universal remote control. Using the Harmony
`Remote Software, you can configure the Harmony On to control up to 15 devices.” (One User Manual, p.
`4, UE015456.)
`
`
`
`
`17
`
`Universal Electronics Exhibit 2032, Page 17
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`
`
`(One User Manual, p. 7, UE015459.)
`
`“Because obstacles or distance can interfere with the signals the Harmony One sends when it starts an
`Activity (for example, someone walks between your Harmony One and the TV when you press Watch
`TV, or you’re very far away from the system when you start an Activity), your Harmony One can become
`‘out of sync’ with your devices.” (One User Manual, p. 9, UE015461.)
`
`“IR Learning│Yes (Up to 200Khz);” “Learning Capabilities│Any IR Device;” “IR Transmitters│2;” “IR
`Transmission Range│Up to 65 ft.” (One User Manual, p. 38, UE015490.)
`
`
`Logitech Harmony 1100 Universal Remote
`
`“The Harmony 1100 is an Activity-based infrared (IR) universal remote control. Using the Harmony
`Remote Software, you can configure the Harmony 1100 to control up to 15 devices.” (H1100 User
`Manual, p. 5, UE015407.)
`
`
`
`
`18
`
`Universal Electronics Exhibit 2032, Page 18
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`
`
`(H1100 User Manual, p. 9, UE015411.)
`
`“When you start an Activity, the Harmony 1100 sends out commands to turn your devices on and sets
`them to the right input. However, if someone walks between your Harmony 1100 and the TV when you
`press Watch TV, or you’re too far away from the system when you start an Activity, or the remote isn’t
`aimed at your entertainment system, the command may not reach the device. This causes the device to
`not respond and your Harmony 1100 becomes ‘out of sync’ with your devices.” (H1100 User Manual, p.
`11, UE015413.)
`
`“IR Learning│Yes (Up to 200Khz);” “IR Transmitters│2;” “IR Transmission Range│Up to 65 ft.”
`(H1100 User Manual, p. 47, UE015449.)
`
`Further, each of the H300, H650, H700, H900, One, and H1100 remotes meets this limitation under the
`doctrine of equivalents at least because any infrared signal output means in the H300, H650, H700, H900,
`One, and H1100 remotes, including any after-arising technology, performs the same function as the
`claimed infrared signal output means, in the same way, to achieve the same result.
`
`a central processing unit (CPU)
`coupled to the input means and
`
`The Harmony H300, H650, H700, H900, One, and H1100 remotes have a central processing unit
`(CPU) coupled to the input means and to the signal output means.
`
`
`
`19
`
`Universal Electronics Exhibit 2032, Page 19
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`
`Each of the H300, H650, H700, H900, One, and H1100 remotes operate such that depressing a particular
`remote button causes the remote to emit an IR signal, for receipt by a controlled device. The CPU allows
`for (1) extraction of the relevant IR code data from the remote’s memory after a particular remote button
`is depressed and (2) the decoding, use, and/or relaying of such IR code data to the remote’s infrared signal
`output means. Therefore, each of the H300, H650, H700, H900, One, and H1100 universal remote
`controls has a central processing unit (CPU) coupled to said input means and to said signal output means.
`
`Further, each of the H300, H650, H700, H900, One, and H1100 remotes meets this limitation under the
`doctrine of equivalents, applying the plain and ordinary meaning of the term “central processing unit,” at
`least because any corresponding processor in the H300, H650, H700, H900, One, and H1100 remotes
`performs the same function as the claimed central processing unit, in the same way, to achieve the same
`result.
`
`The Harmony H300, H650, H700, H900, One, and H1100 remotes have memory means coupled to the
`CPU.
`
`The CPU has the capability to extract IR code data from the remote control’s memory. Accordingly, each
`of the Accused Products has memory means coupled to the CPU.
`
`
`Logitech Harmony 300 Universal Remote
`
`“Simple online setup. Just connect your remote to your computer. Find your devices from a simple
`software menu. Download a full set of commands into your remote. No more codes you can’t find. No
`more buttons that don’t work.” (H300 Packaging, UE015159.)
`
`Logitech Harmony 650 Universal Remote
`
`
`“Memory Type│Flash;” “Memory Amount│2MB.” (H650 User Manual, P. 35, UE015375.)
`
`
`
`Claim 1
`to the signal output means,
`
`
`memory means coupled to the
`CPU and
`
`
`
`
`20
`
`Universal Electronics Exhibit 2032, Page 20
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`Logitech Harmony 700 Universal Remote
`
`“Memory type│Flash;” “Memory capacity│2MB.” (H700 User Manual, p. 21, UE015401.)
`
`Logitech Harmony 900 Universal Remote
`
`
`“Memory Type│Flash;” “Memory Amount│64MB.” (H900 User Manual, p. 59, UE054491.)
`
`
`Logitech Harmony One Universal Remote
`
`“Memory Type│Flash;” “Memory Amount│4MB.” (One User Manual, p. 38, UE015490.)
`
`
`Logitech Harmony 1100 Universal Remote
`
`
`“Updating the remote After you enter your device and Activity information, the software saves your
`information. It also transfers the information to your Harmony 1100. After the software updates your
`remote, you’re ready to test your setup.” (H1100 User Manual, p. 16, UE015418.)
`
`Further, each of the H300, H650, H700, H900, One, and H1100 remotes meets this limitation under the
`doctrine of equivalents at least because any memory means used by the H300, H650, H700, H900, One,
`and H1100 remotes, including any after-arising technology, performs the same function as the claimed
`memory means, in the same way, to achieve the same result.
`
`data coupling means including
`receiving means coupled to the
`CPU for enabling at least one of
`(a) instruction codes or (b) code
`data for creating appropriate IR
`lamp driver instructions for
`causing the infrared signal
`output means to emit infrared
`
`The Accused Products, Harmony H300, H650, H700, H900, One, and H1100 remotes, have data
`coupling means including receiving means coupled to the CPU for enabling at least one of (a)
`instruction codes or (b) code data for creating appropriate IR lamp driver instructions for causing the
`infrared signal output means to emit infrared signals which will cause specific functions to occur in a
`specific controlled device, for operating a variety of devices to be controlled, to be supplied from outside
`the remote control through the receiving means directly to the CPU for direct entry to the memory to
`enable the remote control to control various devices to be controlled upon the inputting of commands
`to the keys of the input means.
`
`
`
`21
`
`Universal Electronics Exhibit 2032, Page 21
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`signals which will cause
`specific functions to occur in a
`specific controlled device, for
`operating a variety of devices to
`be controlled, to be supplied
`from outside the remote control
`through the receiving means
`directly to the CPU for direct
`entry to the memory to enable
`the remote control to control
`various devices to be controlled
`upon the inputting of commands
`to the keys of the input means
`and
`
`
`
`Each of the H300, H650, H700, H900, One, and H100 remotes attaches, via a USB cable, to a local
`computer, from which IR code data from the computer or server housing Logitech’s database of IR code
`data may be accessed and downloaded (through the Harmony software and an Internet connection), into
`the local computer’s memory and then onto each of the H300, H650, H700, H900, One, and H1100
`remotes. Each of the H300, H650, H700, H900, One, and H100 remotes can emit infrared signals
`corresponding to the downloaded IR code data to cause specific functions to occur in a specific controlled
`device. Each of the H300, H650, H700, H900, One, and H1100 remotes can control more than one
`device. Each such device is controlled by inputting commands into the keys of the input means.
`
`
`Logitech Harmony 300 Universal Remote
`
`“Replaces 4 other remotes.” (H300 Packaging, UE015159.)
`
`“Simple online setup. Just connect your remote to your computer. Find your devices from a simple
`software menu. Download a full set of commands into your remote. No more codes you can’t find. No
`more buttons that don’t work.” (H300 Packaging, UE015159.)
`
`
`Logitech Harmony 650 Universal Remote
`
`
`“Updating the remote After you enter your device and Activity information, the software saves your
`information and shows the Finish Setup page. It also transfers the information to your Harmony 650.”
`(H650 User Manual, p. 14, UE015354.)
`
`“Simple online setup Just connect your remote to your computer. Find your devices from a simple
`software menu. Download a full set of commands into your remote. No more codes you can’t find. No
`more buttons that don’t work.” (H650 Packaging, UE015138.)
`
`“When you select an Activity, your Harmony 650 sends a series of commands to your entertainment
`system to turn on the necessary devices and configure them for the selected Activity. After you select an
`Activity, your Harmony 650 assigns the buttons on your remote so they control the proper devices and the
`
`
`
`22
`
`Universal Electronics Exhibit 2032, Page 22
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`screen displays other commands for that Activity.” (H650 User Manual, p. 4, UE015344.)
`
`
`(H650 User Manual, p. 12, UE015352.)
`
`
`
`
`“The Harmony 650 is an Activity-based infrared (IR) universal remote control. Using the Harmony
`Remote Software, you can configure the Harmony 650 to control up to 5 devices.” (H650 User Manual,
`p. 4, UE015344.)
`
`
`Logitech Harmony 700 Universal Remote
`
`
`“Updating the remote When you’re finishing adding Activities, click Sync to transfer your setup
`information to your Harmony 700.” (H700 User Manual, p. 9, UE015389.)
`
`“Easy to set up You connect your Harmony remote to your computer and tell us what equipment you
`
`
`
`23
`
`Universal Electronics Exhibit 2032, Page 23
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01104
`
`
`
`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,414,761 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘761 Patent Claim
`
`Claim 1
`
`have. Instead of looking up codes and punching them into your remote, you can sit back and let our
`online softw