Exhibit B3:
`Exemplary claim chart for
`U.S. Pat. No. 7,404,660
`
`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 displays 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 B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 1 OF 20
`
`TOYOTA EXHIBIT 1012
`
`
`Exemplary claim chart for
`U.S. Pat. No. 7,404,660
`
`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 displays 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 B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 1 OF 20
`
`TOYOTA EXHIBIT 1012
`
`
`
`Toyota 86140-06010
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 2
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 2 OF 20
`
`
`
`Asserted Claims:
`1.
`A light emitting panel assembly comprising: a generally planar optical
`conductor having at least one input edge with a greater cross-sectional width
`than thickness; and a plurality of light sources configured to generate light
`having an output distribution defined by a greater width component than
`height component, the light sources positioned adjacent to the input edge,
`thereby directing light into the optical conductor; the optical conductor having
`at least one output region and a predetermined pattern of deformities
`configured to cause light to be emitted from the output region, the optical
`conductor having a transition region disposed between the light source and
`the output region.
`The assembly of claim 1 wherein the transition region is integral with the
`optical conductor.
`10. The assembly of claim 1 wherein the transition region and the output region of
`the optical conductor have substantially the same thickness.
`16. The assembly of claim 1 wherein the light sources are focused light sources.
`
`
`
`
`3.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 3
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 3 OF 20
`
`
`
`Asserted Claims:
`17. The assembly of claim 16 wherein the focused light sources are LEDs.
`25. The assembly of claim 1 further comprising a tray in which the optical
`conductor is received.
`33. A light emitting panel assembly comprising: a generally planar optical
`conductor having at least one input edge with a greater cross-sectional width
`than thickness; and a plurality of LED light sources each having a greater
`width than height positioned adjacent to the input edge, thereby directing light
`into the optical conductor, each light source being configured to generate light
`having an output distribution defined by a greater width component than
`height component; the optical conductor having at least one output region and
`a predetermined pattern of deformities configured to cause light to be emitted
`from the output region, the optical conductor having a transition region
`disposed between the light source and the output region.
`34. The assembly of claim 33 wherein each light source has a light output
`distribution with a greater width component than height component.
`
`
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 4
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 4 OF 20
`
`
`
`Claim 1:
`A light emitting panel assembly
`comprising:
`
`Light Emitting Panel Assembly
`
`Optical Conductor
`
`Comment: This product includes a
`light emitting panel assembly with
`elements such as an optical
`conductor and light sources.
`
`The graphical representation above
`is provided as a simplified example
`of a generic light emitting panel
`assembly and LCD panel to
`demonstrate the relative
`arrangement of some elements
`discussed in this chart.
`
`Light Sources
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 5
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 5 OF 20
`
`
`
`a generally planar optical
`conductor having at least one
`input edge with a greater
`cross-sectional width than
`thickness; and
`
`Optical Conductor
`Dimensions
`Length: 142.70 mm
`Width:
`78.35 mm
`
`Thickness:
`
`3.00 mm
`
`5.62 in
`3.08 in
`
`0.12 in
`
`Optical Conductor
`
`Close-up on LEDs Alignment to Optical Conductor Input Edge
`
`Thickness
`
`Width
`
`Side View of Optical Conductor
`
`Comment: The assembly includes a
`generally planar optical conductor
`having at least one input edge that
`receives light from the light sources.
`The input edge has a greater cross-
`sectional width than thickness.
`
` generic graphical depiction is
`shown at the upper left for illustrative
`purposes.
`
` A
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 6
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 6 OF 20
`
`
`
`a plurality of light sources
`configured to generate light
`having an output distribution
`defined by a greater width
`component than height
`component, the light sources
`positioned adjacent to the input
`edge, thereby directing light
`into the optical conductor;
`
`Light Sources and Optical Conductor
`
`Light Sources (LEDs)
`
`Close-up on LEDs
`Positioned Adjacent
`to Optical Conductor
`Input Edge
`
`Comment: The assembly includes a plurality of light sources (LEDs) - each with a greater width than height.
`Because the LEDs have a greater width than height, they are configured to generate light having an output
`distribution defined by a greater width component than height component. The LEDs are positioned adjacent
`to the input edge of the optical conductor, thereby directing light into the optical conductor.
`
` A
`
` generic graphical depiction is shown at the upper left for illustrative purposes.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 7
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 7 OF 20
`
`
`
`the optical conductor having at
`least one output region and a
`predetermined pattern of
`deformities configured to cause
`light to be emitted from the
`output region,
`
`Comment:
`The optical conductor has at least one
`output region on the portion of its front
`surface defined by the boundary of the
`back side deformities (see next slide).
`The optical conductor has a
`predetermined pattern of deformities
`on its back surfaces that are
`configured to cause light to be emitted
`from the output region.
`
`The output region is defined as the
`area of the front surface of the optical
`conductor corresponding to the area in
`which back side deformities are
`present (see next slide).
`
`Optical Conductor (Front View)
`
`Back of Panel Member
` Middle Center at 1x
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 8
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 8 OF 20
`
`
`
`the optical conductor having a
`transition region disposed
`between the light source and
`the output region.
`
`Light Sources and Optical Conductor
`
`Transition Region
`
`Output Region
`
`Comment:
`The optical conductor has a transition
`region disposed between the light
`source and the output region.
`
`The transition region is defined as the
`area of the optical conductor between
`the light sources and the edge of the
`deformities on the back side.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 9
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 9 OF 20
`
`
`
`Light Sources and Optical Conductor at 1x
`
`Transition Region
`
`Output Region
`
`Claim 3:
`The assembly of claim 1
`wherein the transition region is
`integral with the optical
`conductor.
`
`Comment:
`
`The transition region is integral with
`the optical conductor.
`
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 10
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 10 OF 20
`
`
`
`Light Sources and Optical Conductor
`
`Claim 10:
`The assembly of claim 1
`wherein the transition region
`and the output region of the
`optical conductor have
`substantially the same
`thickness.
`
`Comment:
`The transition region and the output
`region of the optical conductor have
`substantially the same thickness:
`here, ~3.00 mm.
`
`Optical Conductor
`Dimensions
`Length: 142.70 mm
`Width:
`78.35 mm
`
`Thickness:
`
`3.00 mm
`
`5.62 in
`3.08 in
`
`0.12 in
`
`Thickness
`
`Side View of Optical Conductor
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 11
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 11 OF 20
`
`
`
`Claim 16:
`The assembly of claim 1
`wherein the light sources are
`focused light sources.
`
`Comment:
`The light sources in the assembly are
`LEDs that are focused light sources.
`
`Light Sources (LEDs)
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 12
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 12 OF 20
`
`
`
`Claim 17:
`The assembly of claim 16
`wherein the focused light
`sources are LEDs.
`
`Comment: The light sources in the
`assembly are LEDs that are focused
`light sources.
`
`Light Sources (LEDs)
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 13
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 13 OF 20
`
`
`
`Claim 25:
`The assembly of claim 1
`further comprising a tray in
`which the optical conductor is
`received.
`
`Partial View of Tray
`
`Comment:
`The assembly includes a tray in
`which the optical conductor is
`received.
`
`Partial View of Tray with Optical Conductor
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 14
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 14 OF 20
`
`
`
`1. A light emitting assembly
`Claim 33:
`1. A light emitting panel
`comprising
`
`assembly comprising A light emitting panel assembly
`comprising:
`
`Light Emitting Panel Assembly
`
`Optical Conductor
`
`Comment: This product includes a
`light emitting panel assembly with
`elements such as an optical
`conductor and light sources.
`
`The graphical representation above
`is provided as a simplified example
`of a generic light emitting panel
`assembly and LCD panel to
`demonstrate the relative
`arrangement of some elements
`discussed in this chart.
`
`Light Sources
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 15
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 15 OF 20
`
`
`
`a generally planar optical
`conductor having at least one
`input edge with a greater
`cross-sectional width than
`thickness; and
`
`Optical Conductor
`Dimensions
`Length: 142.70 mm
`Width:
`78.35 mm
`
`Thickness:
`
`3.00 mm
`
`5.62 in
`3.08 in
`
`0.12 in
`
`Optical Conductor
`
`Close-up on LEDs Adjacent to Optical Conductor Input Edge
`
`Comment: The assembly includes a
`generally planar optical conductor
`having at least one input edge with a
`greater cross-sectional width than
`thickness.
`
` A
`
` generic graphical depiction is
`shown above for illustrative purposes.
`
`Thickness
`
`Width
`
`Side View of Optical Conductor
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 16
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 16 OF 20
`
`
`
`a plurality of LED light sources
`each having a greater width than
`height positioned adjacent to the
`input edge, thereby directing light
`into the optical conductor, each
`light source being configured to
`generate light having an output
`distribution defined by a greater
`width component than height
`component;
`
`LED Light Sources and Optical Conductor
`
`Light Sources (LEDs)
`
`Close-up on LEDs
`Positioned Adjacent to
`Optical Conductor
`Input Edge
`
`Comment: The assembly includes a plurality of LED light sources – each having a greater width than
`height. Because the LEDs have a greater width than height, they are each configured to generate light
`having an output distribution defined by a greater width component than height component.
`The LEDs are positioned adjacent to the input edge of the optical conductor, thereby directing light into
`the optical conductor.
`A generic graphical depiction is shown at left for illustrative purposes.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 17
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 17 OF 20
`
`
`
`the optical conductor having at
`least one output region and a
`predetermined pattern of
`deformities configured to cause
`light to be emitted from the
`output region,
`the optical conductor having a
`transition region disposed
`between the light source and
`the output region.
`
`Slide 1 of 2
`
`Comment:
`The optical conductor has at least one
`output region on the portion of its front
`surface defined by the boundary of the
`back side deformities (see next slide).
`The optical conductor has a
`predetermined pattern of deformities
`on its back surfaces configured to
`cause light to be emitted from the
`output region.
`
`Optical Conductor (Front View)
`
`Back of Panel Member
` Middle Center at 1x
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 18
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 18 OF 20
`
`
`
`LED Light Sources and Optical Conductor
`
`Transition Region
`
`Output Region
`
`the optical conductor having at
`least one output region and a
`predetermined pattern of
`deformities configured to cause
`light to be emitted from the
`output region,
`the optical conductor having a
`transition region disposed
`between the light source and
`the output region.
`
`Slide 2 of 2
`
`Comment: The optical conductor has
`a transition region disposed between
`the light source and the output region.
`
`The transition region is defined as the
`area of the optical conductor between
`the light sources and the edge of the
`deformities on the back side.
`
`The output region is defined as the
`area of the front surface of the optical
`conductor corresponding to the area
`in which back side deformities are
`present.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 19
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 19 OF 20
`
`
`
`Claim 34:
`The assembly of claim 33
`wherein each light source has
`a light output distribution with a
`greater width component than
`height component.
`
`LED Light Sources
`
`Comment: The assembly includes a
`plurality of LED light sources (LEDs)
`– each having a greater width than
`height. Because the LEDs have a
`greater width than height, they each
`have a light output distribution with a
`greater width component than height
`component.
`
` A
`
` generic graphical depiction is
`shown above for illustrative purposes.
`An actual identification of infringing
`elements is made on the right side of
`the chart.
`
`IDT’s preliminary infringement contentions vs. Toyota
`
`Page 20
`
`Exhibit B3: Infringement of U.S. Pat. No. 7,404,660
`
`PAGE 20 OF 20
`
`
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