UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`1. A universal remote control
`system 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, 2, and 20 of the ‘313 Patent under 35 U.S.C. § 271 (a), (b), and (c).
`
`More specifically, Logitech infringes Claims 1, 2, and 20 of the ‘313 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, 2, and 20 of the ‘313 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, 2, and 20
`of the ‘313 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, 2, and 20 of the ‘313 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, 2, and 20 of the ‘313 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 H1100 remote controls who use, activate, set-up, and operate such
`infringing technology, infringe Claims 1, 2, and 20 of the ‘313 Patent under § 271 (a).
`
`
`
`1
`
`Universal Electronics Exhibit 2032, Page 1
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`
`
`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.)
`
`
`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.)
`
`
`
`“The Harmony 900 is an Activity-based universal remote control.” (H900 User Manual, p. 6.)
`
`Logitech Harmony 900 Universal Remote
`
`
`
`2
`
`Universal Electronics Exhibit 2032, Page 2
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`
`“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.)
`
`
`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.)
`
`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.)
`
`The computer or server that houses Logitech’s database of IR code data is a computer having a
`memory. IR code data that corresponds to a particular controlled device is downloadable from the
`Logitech database of IR code data onto each of the Accused Products, the H300, H650, H700, H900, One,
`and H1100 universal remote.
`
`Additionally, the local computer to which Harmony remotes attach is also a computer having a
`
`a computer having a memory,
`
`
`
`
`3
`
`Universal Electronics Exhibit 2032, Page 3
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`memory. The IR code data is stored in the local computer memory’s during the remote set-up and
`configuration process.
`
`
`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
`
`
`“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.)
`
`
`Logitech Harmony 700 Universal Remote
`
`
`“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.)
`
`
`Logitech Harmony 900 Universal Remote
`
`
`“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.)
`
`
`Logitech Harmony One Universal Remote
`
`
`“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
`
`
`
`4
`
`Universal Electronics Exhibit 2032, Page 4
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`your remote will work with what you own today and what you add tomorrow.” (One Packaging,
`UE015180.)
`
`Logitech Harmony 1100 Universal Remote
`
`
`“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.)
`
`Further, each of the Accused Products meets this limitation under the doctrine of equivalents, applying the
`plain and ordinary meaning of the phrase “a computer having a memory,” at least because any
`corresponding structure used by the Accused Products performs the same function as the claimed
`computer having a memory, in the same way, to achieve the same result.
`
`The Accused Products, Harmony H300, H650, H700, H900, One, and H1100 remotes, 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, have code data for creating
`appropriate infrared (IR) lamp driver instructions for causing an infrared signal generator 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, stored in said memory of said computer.
`
`Logitech stores IR code data in the memory of a computer or server (referred to above as Logitech’s
`database of IR code data). IR code data may be accessed and downloaded through the Harmony software
`onto each of the Accused Products, the H300, H650, H700, H900, One, and H1100 universal remote
`control systems. As further noted above, a local computer stores, IR code data in memory during the
`remote set-up and configuration process. After the IR code data is downloaded onto the Harmony remote,
`the remote can then emit infrared signals corresponding to the downloaded IR code data to cause specific
`functions to occur in a specific controlled device. Further, each Accused Product can control more than
`one device.
`
`
`Logitech Harmony 300 Universal Remote
`
`code data for creating
`appropriate infrared (IR) lamp
`driver instructions for causing
`an infrared signal generator 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, stored
`in said memory of said
`computer,
`
`
`
`
`5
`
`Universal Electronics Exhibit 2032, Page 5
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`
`“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. Our online device library includes more than 225,000 devices—and the list
`grows every day. So your remote is never out of date.” (H300 Packaging, UE015159.)
`
`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.)
`
`“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
`screen displays other commands for that Activity.” (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.)
`
`“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.)
`
`“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
`
`
`
`6
`
`Universal Electronics Exhibit 2032, Page 6
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`more buttons that don’t work.” (H650 Packaging, UE015138.)
`
`
`Logitech Harmony H700 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.)
`
`“An activity is something you do with your entertainment system, like watching TV, listening to music, or
`playing a game. You Harmony remote automates Activities so that a single button turns on all the
`necessary devices for each Activity, and switches them to the required inputs. For example, pressing the
`Watch TV button might turn on your TV, your cable or satellite receiver, and your audio receiver, and
`switch to the correct video and audio inputs.” (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.)
`
`“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.)
`
`“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.)
`
`“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.)
`
`“Easy to set up You connect your Harmony remote to your computer and tell us what equipment you
`
`
`
`7
`
`Universal Electronics Exhibit 2032, Page 7
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`have. Instead of looking up codes and punching them into your remote, you can sit back and let our
`online software do the work for you.” (H700 Packaging, UE015085.)
`
`
`Logitech Harmony 900 Universal Remote
`
`“The Harmony 900 Universal Remote is your answer to effortless home entertainment. The Activities
`button puts control of all your devices in one convenient location. You can go from watching TV to
`watching a DVD to listening to music with the touch of a button. You no longer need to type in codes to
`get your remote working with your entertainment system. the guided online setup walks you through the
`step-by-step configuration of your Harmony 900 with your entertainment system and then you’ll be ready
`to sit back and enjoy!” (H900 User Manual, p. 6, UE054438.)
`
`“When you select an Activity, your Harmony 900 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 900 assigns the buttons on your remote so they control the proper devices and the
`screen displays other commands for that Activity.” (H900 User Manual, p. 6, UE054438.)
`
`“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”
`
`
`
`8
`
`Universal Electronics Exhibit 2032, Page 8
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`(H900 User Manual, p. 7, UE054439.)
`
`
`(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.
`
`
`
`9
`
`Universal Electronics Exhibit 2032, Page 9
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`4, UE015456.)
`
`“When you select an Activity, your Harmony One 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 One assigns the buttons on your remote so they control the proper devices and
`the screen displays other commands for that Activity.” (One User Manual, p. 4, UE015456.)
`
`
`
`(One User Manual, p. 7, UE015459.)
`
`
`
`
`“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.)
`
`“Updating the remote After you enter your device and Activity information, the software saves your
`information. It also transfers the information to your Harmony One.” (One User Manual, p. 15,
`UE015467.)
`
`“Setup, meet simplicity You connect your Harmony remote to your computer and tell us about your
`equipment. Instead of looking up codes and punching them into your remote, you can sit back and let our
`online software do the work for you.” (One Packaging, UE015180.)
`
`
`
`10
`
`Universal Electronics Exhibit 2032, Page 10
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`
`
`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.)
`
`
`
`
`(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.)
`
`
`
`11
`
`Universal Electronics Exhibit 2032, Page 11
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`
`“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, the Harmony H300, H650, H700, H900, One, and H1100 remotes, 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, meets this limitation under the doctrine of equivalents,
`applying the plain and ordinary meaning of the term “code data,” at least because any corresponding data
`or information used by the Accused Products performs the same function as the claimed code data, in the
`same way, to achieve the same result.
`
`The Harmony H300, H650, H700, H900, One, and H1100 remotes are each a universal 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.)
`
` •
`
`“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.)
`
` •
`
`“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
`
` •
`
`
`
`a universal remote control
`comprising
`
`
`
`
`12
`
`Universal Electronics Exhibit 2032, Page 12
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`input means including a set of
`keys or pushbuttons for
`inputting commands into the
`remote control,
`
`
`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 Accused Products performs
`the same function as the claimed universal remote control, in the same way, to achieve the same result.
`
`The Harmony H300, H650, H700, H900, One, and H1100 universal remote controls have input means
`including a set of keys or pushbuttons for inputting commands into the remote control.
`
`
`Logitech Harmony H300 Universal Remote
`
`
`
`
`
`
`
`
`
`(H300 Buttons 2.pdf - H300 Website, UE054524.)
`
`
`
`13
`
`Universal Electronics Exhibit 2032, Page 13
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`Logitech Harmony H650 Universal Remote
`
`
`
`
`
`(H650 User Manual, UE015345.)
`
`
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`
`
`
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`
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`
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`
`
`14
`
`Universal Electronics Exhibit 2032, Page 14
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`Logitech Harmony H700 Universal Remote
`
`
`
`
`
`
`(H700 User Manual, UE015382.)
`
`
`
`
`
`
`
`
`
`
`
`15
`
`Universal Electronics Exhibit 2032, Page 15
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`Logitech Harmony H900 Universal Remote
`
`
`
`
`
`
`(H900 User Manual, p. 8, UE054440.)
`
`
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`
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`
`
`16
`
`Universal Electronics Exhibit 2032, Page 16
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`Logitech Harmony ONE Universal Remote
`
`
`
`(One User Manual, p. 4, UE015457.)
`
`
`
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`
`
`
`
`17
`
`Universal Electronics Exhibit 2032, Page 17
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`Logitech Harmony H1100 Universal Remote
`
`
`(H1100 User Manual, UE015408.)
`
`Further, each of the H300, H650, 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 input means claimed,
`in the same way, to achieve the same result.
`
`
`
`infrared signal output means
`
`The Harmony H300, H650, H700, H900, One, and H1100 universal remote controls have infrared
`
`
`
`18
`
`Universal Electronics Exhibit 2032, Page 18
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`including IR lamp driver
`circuitry for supplying an
`infrared signal to a controlled
`device,
`
`
`signal output means including IR lamp driver circuitry 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 circuitry 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.)
`
`
`
`
`19
`
`Universal Electronics Exhibit 2032, Page 19
`Universal Remote Control v. Universal Electronics, Trial No. IPR 2014-01106
`
`

`

`UEI’s Infringement Contentions and Asserted Claims Regarding Infringement of U.S. Patent No. 5,255,313 By
`Logitech, Inc., Logitech International S.A., and Logitech Europe S.A.
`
`Logitech’s Accused Systems, Products and/or Services
`
`‘313 Patent Claim
`
`Claim 1
`
`“Because obstacles or distance can interfere with the signals the Harmony 650 sends when it starts an
`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 Acti