Exhibit B2:
`Exemplary claim chart for
`U.S. Pat. No. 7,384,177
`
`The feature/functionality primarily relied upon for this chart is LCD navigation/entertainment display units found in
`Toyota and Lexus automobiles, including, for example, the Toyota 86140-06010 navigation system display.
`
`On present information and belief, IDT understands that Toyota currently offers multiple automobile models having
`LCD navigation/entertainment display 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 LCD displays 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 B2: Infringement of U.S. Pat. No. 7,384,177
`
`TOYOTA EXHIBIT 1016
`
`Page 1 of 22
`
`
`Exemplary claim chart for
`U.S. Pat. No. 7,384,177
`
`The feature/functionality primarily relied upon for this chart is LCD navigation/entertainment display units found in
`Toyota and Lexus automobiles, including, for example, the Toyota 86140-06010 navigation system display.
`
`On present information and belief, IDT understands that Toyota currently offers multiple automobile models having
`LCD navigation/entertainment display 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 LCD displays 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 B2: Infringement of U.S. Pat. No. 7,384,177
`
`TOYOTA EXHIBIT 1016
`
`Page 1 of 22
`
`
`
`Toyota 86140-06010
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 2
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 2 of 22
`
`
`
`Asserted Claims:
`1. A light emitting assembly comprising a tray having a back wall and continuous
`side walls that form a hollow cavity or recess completely surrounded by the
`side walls, at least one light source located, mounted or positioned in the
`cavity or recess, and at least one sheet, film or substrate overlying the
`assembly for controlling the light emitted from the assembly to fit a particular
`application, wherein the tray acts as at least one of a back, side edge, and
`end edge reflector and has one or more secondary flat, angled, faceted or
`curved reflective or refractive surfaces to redirect at least a portion of the light
`emitted by the light source in a predetermined manner within the cavity or
`recess.
`
`
`
`6. The assembly of claim 1 wherein there are at least two light sources located,
`mounted or positioned in the cavity or recess.
`
`
`7. The assembly of claim 6 wherein each light source is positioned in close
`proximity to a group of the refractive or reflective surfaces.
`
`
`9. The assembly of claim 6 wherein a portion of the light emitted from the light
`sources mixes in the cavity or recess.
`
`
`10. The assembly of claim 9 wherein the sheet, film or substrate provides
`additional light mixing.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 3
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 3 of 22
`
`
`
`Asserted Claims:
`13. The assembly of claim 1 wherein there is at least one sheet, film or substrate
`that is a diffuser, colored film or filter, label, transparent or semi-transparent
`overlay, label or display, reflector, polarizer or reflective polarizer.
`14. The assembly of claim 1 wherein the at least one sheet, film or substrate has
`deformities for controlling the light output ray angle distribution to fit a
`particular application.
`15. A light emitting assembly comprising a tray having a back wall and continuous
`side walls that form a hollow cavity or recess completely surrounded by the
`side walls, at least two light sources located, mounted or positioned in the
`cavity or recess, and at least one sheet, film or substrate overlying the
`assembly for controlling the light emitted from the assembly to fit a particular
`application, wherein the tray acts as at least one of a back, side edge and end
`edge reflector and has at least one secondary flat, angled, faceted or curved
`reflective or refractive surface to facilitate better mixing of light rays within the
`cavity or recess to produce a desired light output color or uniformity.
`19. The assembly of claim 15 wherein at least some of the light sources are
`LEDs.
`22. The assembly of claim 15 wherein the sheet, film or substrate is comprised of
`multiple layers.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 4
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 4 of 22
`
`
`
`Sheets or Films 1-3
`
`Light Sources
`
`1. A light emitting assembly
`Claim 1:
`1. A light emitting panel
`comprising
`assembly comprising
` light emitting assembly
`comprising
`
` A
`
`Light Emitting Assembly
`
`Tray
`
`Comment: This product includes a
`light emitting assembly with
`elements such as a tray, sheets or
`films, and light sources.
`
`The graphical representation above
`is provided as a simplified example
`of a generic light emitting assembly
`and LCD panel to demonstrate the
`relative arrangement of some
`elements discussed in this chart.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 5
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 5 of 22
`
`
`
`a tray having a back wall and
`continuous side walls that form
`a hollow cavity or recess
`completely surrounded by the
`side walls,
`
`Comment:
`
`The light emitting assembly includes
`a tray having a back wall and
`continuous side walls that form a
`hollow cavity or recess completely
`surrounded by the side walls.
`
`Partial View of Tray
`
`Back Wall
`
`Side Walls
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 6
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 6 of 22
`
`
`
`at least one light source
`located, mounted or positioned
`in the cavity or recess,
`
`Close-Up View of Area of Tray with Light Sources
`
`Comment:
`
`Multiple light sources (LEDs) are
`located in the cavity or recess of the
`tray.
`
`Light Sources
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 7
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 7 of 22
`
`
`
`and at least one sheet, film or
`substrate overlying the
`assembly for controlling the
`light emitted from the assembly
`to fit a particular application,
`
`Comment:
`Films/sheets 1-3 overlie the assembly
`for controlling the light emitted from
`the assembly to fit a particular
`application, e.g., illuminating an LCD
`display.
`
`Staggered View of Films/Sheets 1-3 on Top of Tray
`
`Light Emitting Assembly
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 8
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 8 of 22
`
`
`
`wherein the tray acts as at
`least one of a back, side edge,
`and end edge reflector and has
`one or more secondary flat,
`angled, faceted or curved
`reflective or refractive surfaces
`to redirect at least a portion of
`the light emitted by the light
`source in a predetermined
`manner within the cavity or
`recess.
`
`Comment: The back wall of the tray
`acts as a back reflector. The
`continuous side walls act as side and
`end edge reflectors.
`
`All surfaces of the tray that are not
`the back wall or continuous side walls
`are parts of the tray that are
`secondary flat, angled, faceted or
`curved reflective or refractive
`surfaces (see, e.g., the flat secondary
`reflective surfaces identified on the
`right).
`
`Those secondary reflectors
`necessarily redirect at least a portion
`of the light emitted by the light source
`in a predetermined manner within the
`cavity or recess.
`
`Partial View of Tray
`
`Secondary Reflective
`Surfaces
`Side/End Edge
`Reflectors
`
`Back Reflector
`
`Secondary Reflective
`Surfaces
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 9
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 9 of 22
`
`
`
`Claim 6:
`The assembly of claim 1
`wherein there are at least two
`light sources located, mounted
`or positioned in the cavity or
`recess.
`
`Close-Up View of Area of Tray with Light Sources
`
`Comment:
`
`light sources (LEDs) are
`Multiple
`located in the cavity or recess.
`
`Light Sources
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 10
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 10 of 22
`
`
`
`Close-Up View of Area of Tray with Light Sources
`
`Claim 7:
`
`The assembly of claim 6
`wherein each light source is
`positioned in close proximity to
`a group of the refractive or
`reflective surfaces.
`
`Comment:
`
`Each light source is positioned in the
`tray in close proximity to the
`secondary refractive or reflective
`surfaces as described in claim 1.
`
`
`Light Sources
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 11
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 11 of 22
`
`
`
`Claim 9:
`
`The assembly of claim 6
`wherein a portion of the light
`emitted from the light sources
`mixes in the cavity or recess.
`
`Partial View of Tray
`
`Light Emitting Assembly
`
`Comment: In the light emitting
`assembly, a portion of the light
`emitted from the light sources mixes
`in the cavity or recess.
`
` A
`
` portion of the light emitted from the
`light sources mixes in the empty
`space within the cavity or recess
`created by the back wall and
`continuous side walls.
`
` A
`
` portion of the light also mixes in the
`components that are placed in the
`cavity or recess such as the light
`emitting panel member.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 12
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 12 of 22
`
`
`
`Staggered View of Films/Sheets (Nos. 1-3) on Top of Tray
`
`Close-up of Removal of Films/Sheets (Nos. 1-3) from Tray
`
`Claim 10:
`
`The assembly of claim 9
`wherein the sheet, film or
`substrate provides additional
`light mixing.
`
`Comment:
`
`In the light emitting assembly,
`sheets/films 1-3 provide additional
`light mixing.
`
`The graphical representation above
`shows this arrangement as found in
`the accused product.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 13
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 13 of 22
`
`
`
`Claim 13:
`
`The assembly of claim 1
`wherein there is at least one
`sheet, film or substrate that is a
`diffuser, colored film or filter,
`label, transparent or semi-
`transparent overlay, label or
`display, reflector, polarizer or
`reflective polarizer.
`
`Comment:
`
`Film 3 is a diffuser.
`
`Film 3
`
`Film 3 at 5x
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 14
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 14 of 22
`
`
`
`Claim 14:
`
`The assembly of claim 1
`wherein the at least one sheet,
`film or substrate has
`deformities for controlling the
`light output ray angle
`distribution to fit a particular
`application.
`
`Comment: Films/sheets 1 and 3 have
`deformities
`for controlling
`the
`light
`output ray angle distribution to fit a
`particular application, e.g.., illuminating
`an LCD.
`
`Deformities on Front Surface
`of Film/Sheet 1 at 5x
`
`Deformities on Top Surface
`of Film/Sheet 3 at 5x
`
`Deformities on Back Surface
`of Film/Sheet 1 at 5x
`
`Deformities on Bottom Surface
`of Film/Sheet 3 at 5x
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 15
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 15 of 22
`
`
`
`Sheets or 1-3
`
`Light Sources
`
`1. A light emitting assembly
`Claim 15:
`1. A light emitting panel
`comprising
`assembly comprising
` light emitting assembly
`comprising
`
` A
`
`Light Emitting Assembly
`
`Partial View of Tray
`
`Comment:
`This product includes a light emitting
`assembly with elements such as a
`tray, sheets or films, and light
`sources.
`
`The graphical representation above
`is provided as a simplified example
`of a generic light emitting assembly
`and LCD panel to demonstrate the
`relative arrangement of some
`elements discussed in this chart.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 16
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 16 of 22
`
`
`
`a tray having a back wall and
`continuous side walls that form
`a hollow cavity or recess
`completely surrounded by the
`side walls,
`
`Comment:
`
`The light emitting assembly includes
`a tray having a back wall and
`continuous side walls that form a
`hollow cavity or recess completely
`surrounded by the side walls.
`
`Partial View of Tray
`
`Back Wall
`
`Side Walls
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 17
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 17 of 22
`
`
`
`at least two light sources
`located, mounted or positioned
`in the cavity or recess,
`
`Close-Up View of Area of Tray with Light Sources
`
`Comment:
`Multiple light sources (LEDs) are
`located, mounted or positioned in the
`cavity or recess of the tray.
`
`Light Sources
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 18
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 18 of 22
`
`
`
`and at least one sheet, film or
`substrate overlying the
`assembly for controlling the
`light emitted from the assembly
`to fit a particular application,
`
`Comment:
`In the light emitting assembly,
`films/sheets (nos. 1-3 in the image on
`the right) overlie the assembly for
`controlling the light emitted from the
`assembly to fit a particular
`application, e.g., illuminating an LCD
`display.
`
`Staggered View of Film/Sheet Arrangement
`
`Light Emitting Assembly
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 19
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 19 of 22
`
`
`
`wherein the tray acts as at
`least one of a back, side edge
`and end edge reflector and has
`at least one secondary flat,
`angled, faceted or curved
`reflective or refractive surface
`to facilitate better mixing of
`light rays within the cavity or
`recess to produce a desired
`light output color or uniformity.
`
`Comment: The back wall of the tray
`acts as a back reflector. The
`continuous side walls act as side and
`end edge reflectors.
`
`All surfaces of the tray that are not
`the back wall or continuous side walls
`are parts of the tray that are
`secondary flat, angled, faceted or
`curved reflective or refractive
`surfaces (see, e.g., the flat secondary
`reflective surfaces identified on the
`right).
`
`Those secondary reflective surfaces
`facilitate better mixing of light rays
`within the cavity or recess to produce
`a desired light output uniformity for
`illuminating an LCD.
`
`Partial View of Tray
`
`Secondary Reflective
`Surfaces
`Side/End Edge
`Reflectors
`
`Back Reflector
`
`Secondary Reflective
`Surfaces
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 20
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 20 of 22
`
`
`
`Claim 19:
`
`The assembly of claim 15
`wherein at least some of the
`light sources are LEDs.
`
`Comment:
`The light sources of the assembly are
`LEDs.
`
`Light Sources
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 21
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 21 of 22
`
`
`
`Claim 22:
`The assembly of claim 15
`wherein the sheet, film or
`substrate is comprised of
`multiple layers.
`
`Comment:
`Films/sheets 1-3 overlie the assembly
`for controlling the light emitted from
`the assembly to fit a particular
`application, e.g., illuminating an LCD
`display.
`
`Staggered View of Films/Sheets 1-3 on Top of Tray
`
`Light Emitting Assembly
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 22
`
`Exhibit B2: Infringement of U.S. Pat. No. 7,384,177
`
`Page 22 of 22
`
`
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