Exhibit C2:
`Exemplary claim chart for
`U.S. Pat. No. 6,886,956
`
`The feature/functionality primarily relied upon for this chart is headlights and taillights found in Lexus automobiles,
`including, for example, the Lexus 81551-50160 and 81561-50160 rear combination lamps.
`
`On present information and belief, IDT understands that Toyota currently offers multiple automobile models having
`headlights or taillights that are identical or substantially the same, at least with respect to the features relating to the
`elements of the asserted claims of the patent. The Accused Instrumentalities are identified by model in Exhibit A and
`further include any other Toyota and Lexus vehicles having headlights or taillights that operate identically or
`substantially in the same manner with respect to the features relating to the elements of the asserted claims.
`
`To the extent discovery later shows that the functionality of any accused product differs, at least with respect to the
`elements of the asserted claims, IDT reserves the right to amend or further supplement these contentions with
`additional information learned in the course of discovery or further investigation.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 1
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 1 of 18
`
`TOYOTA EXHIBIT 1009
`
`
`Exemplary claim chart for
`U.S. Pat. No. 6,886,956
`
`The feature/functionality primarily relied upon for this chart is headlights and taillights found in Lexus automobiles,
`including, for example, the Lexus 81551-50160 and 81561-50160 rear combination lamps.
`
`On present information and belief, IDT understands that Toyota currently offers multiple automobile models having
`headlights or taillights that are identical or substantially the same, at least with respect to the features relating to the
`elements of the asserted claims of the patent. The Accused Instrumentalities are identified by model in Exhibit A and
`further include any other Toyota and Lexus vehicles having headlights or taillights that operate identically or
`substantially in the same manner with respect to the features relating to the elements of the asserted claims.
`
`To the extent discovery later shows that the functionality of any accused product differs, at least with respect to the
`elements of the asserted claims, IDT reserves the right to amend or further supplement these contentions with
`additional information learned in the course of discovery or further investigation.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 1
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 1 of 18
`
`TOYOTA EXHIBIT 1009
`
`
`
`Asserted Claims:
`1.
`A light emitting assembly for vehicle illumination comprising a light guide having opposite
`sides and at least one light input surface along at least one edge of said light guide, one
`or more light emitting diodes along said light input surface for receiving light from said
`light emitting diodes and conducting the light from said edge for emission of the light from
`at least one of said sides, a plurality of light extracting deformities on at least one of said
`sides, said deformities having shapes for controlling an output ray angle distribution of
`emitted light to suit a particular application, and a transparent substrate overlying at least
`one of said sides, said substrate providing an exterior portion of a vehicle for vehicle
`illumination at said exterior portion.
`
`The assembly of claim 1 wherein said substrate covers said at least one of said sides.
`
`
`
`4. The assembly of claim 1 wherein said substrate is positioned against said light guide.
`
`5.
`
`6.
`
`The assembly of claim 1 wherein said deformities are at least one of depressions and
`raised surfaces on at least one of said sides.
`
`The assembly of claim 1 wherein said light emitting diodes are attached to a circuit.
`
`9.
`
`31. The assembly of claim 1 wherein said substrate provides protection for the light guide.
`
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 2
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 2 of 18
`
`
`
`Overview
`
`The infringing tail light assemblies are found at
`each rear corner of the vehicle.
`
`Left side (pictured): part no. 81561-50160
`
`Right side: part no. 81551-50160
`
`Elements lit up
`
`Transparent substrate removed
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 3
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 3 of 18
`
`
`
`Overview
`
`The tail light assembly includes three light pipes, which are a type of light guide.
`
`End view of light pipe
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 4
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 4 of 18
`
`
`
`Overview
`
`Each light pipe is illuminated by an LED.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 5
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 5 of 18
`
`
`
`Overview
`
`The bottom half of the lens (running/brake light) is also a light guide,
`illuminated by an array of LEDs facing upward.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 6
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 6 of 18
`
`
`
`Claim 1:
`A light emitting assembly
`for vehicle illumination
`comprising a light guide
`
`
`The tail light assembly contains multiple light guides:
`
`Left: bottom half of lens
`
`Right: light pipes
`
`IDT’s preliminary infringement contentions vs. Toyota
`7
`
`Page 7
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 7 of 18
`
`
`
`Opposite Sides of Light Guide
`
`having opposite sides and
`at least one light input
`surface along at least one
`edge of said light guide
`
`Light Input Surfaces
`
`Comment:
`
`Each light guide has opposite
`sides and a light input surface
`along one edge.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 8
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 8 of 18
`
`
`
`one or more light emitting
`diodes along said light
`input surface for receiving
`light from said light
`emitting diodes
`
`Each of the three light pipes is illuminated by an LED.
`
`The light guide at the bottom half of the leans is illuminated by an array of LEDs.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 9
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 9 of 18
`
`
`
`and conducting the light
`from said edge for
`emission of the light from
`at least one of said sides
`
`Edge of panel assembly
`
`Light is emitted from the top
`surface of each light pipe
`
`IDT’s preliminary infringement contentions vs. Toyota
`10
`
`Page 10
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 10 of 18
`
`
`
`and conducting the light
`from said edge for
`emission of the light from
`at least one of said sides
`(continued)
`
`Edge of panel assembly
`
`Light is emitted from the top
`surface of the light guide in the
`bottom half of the lens
`
`IDT’s preliminary infringement contentions vs. Toyota
`11
`
`Page 11
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 11 of 18
`
`
`
`a plurality of light
`extracting deformities on
`at least one of said sides,
`said deformities having
`shapes for controlling an
`output ray angle
`distribution of emitted light
`to suit a particular
`application
`
`Each light guide has light extracting deformities having
`shapes that determine an output distribution to suit a
`particular application, i.e., illuminating portions of the tail
`light assembly.
`
`IDT’s preliminary infringement contentions vs. Toyota
`12
`
`Page 12
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 12 of 18
`
`
`
`and a transparent
`substrate overlying at
`least one of said sides,
`said substrate providing
`an exterior portion of a
`vehicle for vehicle
`illumination at said
`exterior portion
`
`The red exterior lens is a transparent substrate that covers
`the light guides and forms an exterior portion of the vehicle
`for illumination at that portion.
`
`IDT’s preliminary infringement contentions vs. Toyota
`13
`
`Page 13
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 13 of 18
`
`
`
`Claim 4:
`The assembly of claim 1
`wherein said substrate is
`positioned against said light
`guide.
`
`The red exterior lens is a transparent substrate that covers
`the light guides and forms an exterior portion of the vehicle
`for illumination at that portion.
`
`IDT’s preliminary infringement contentions vs. Toyota
`14
`
`Page 14
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 14 of 18
`
`
`
`Claim 5:
`The assembly of claim 1
`wherein said substrate
`covers said at least one of
`said sides.
`
`The red exterior lens is a transparent substrate that covers
`the light guides and forms an exterior portion of the vehicle
`for illumination at that portion.
`
`IDT’s preliminary infringement contentions vs. Toyota
`15
`
`Page 15
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 15 of 18
`
`
`
`Claim 6:
`The assembly of claim 1
`wherein said deformities are
`at least one of depressions
`and raised surfaces on at
`least one of said sides.
`
`The deformities on the side of the light guide are alternating
`raised surfaces and depressions.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 16
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 16 of 18
`
`
`
`Claim 9:
`The assembly of claim 1
`wherein said light emitting
`diodes are attached to a
`circuit.
`
`Comment:
`The LEDs attached to a
`printed circuit board which
`is part of a circuit that
`provides power to the
`assembly.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 17
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 17 of 18
`
`
`
`Claim 31:
`The assembly of claim 1
`wherein said substrate
`provides protection for the
`light guide.
`
`The red exterior lens is a transparent substrate that covers
`the light guides and forms an exterior portion of the vehicle
`for illumination at that portion.
`
`IDT’s preliminary infringement contentions vs. Toyota
`18
`
`Page 18
`
`Exhibit C2: Infringement of U.S. Pat. No. 6,886,956
`
`Page 18 of 18
`
`
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