U.S. Patent No. 9,119,495 (’495 Patent)
`
`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`’495 Patent
`Claims
`1.[a] An artificial
`tree comprising:
`
`Infringing Products (Willis “Infringing Pre-Lit Trees”)
`
`The preamble is not limiting. To the extent it is limiting, the Holiday Living Tree #20 (HLT #20) meets this limitation. The
`HLT #20 is a 7.5 ft. pre-lit artificial pine tree.
`
`See photograph of HLT #20 (above); See Second Amended Complaint (“SAC”), item 89, p. 21.
`
`1.[b] a plurality of
`tree trunk sections;
`
`The HLT #20 satisfies this limitation. The HLT #20 includes a plurality of tree trunk sections – a bottom section, a middle
`section, and a top section as shown below.
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`1 of 37
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`Willis Exhibit 1015 - 1
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`’495 Patent
`Claims
`1.[a] An artificial
`tree comprising:
`
`Infringing Products (Willis “Infringing Pre-Lit Trees”)
`
`The preamble is not limiting. To the extent it is limiting, the Holiday Living Tree #20 (HLT #20) meets this limitation. The
`HLT #20 is a 7.5 ft. pre-lit artificial pine tree.
`
`See photograph of HLT #20 (above); See Second Amended Complaint (“SAC”), item 89, p. 21.
`
`1.[b] a plurality of
`tree trunk sections;
`
`The HLT #20 satisfies this limitation. The HLT #20 includes a plurality of tree trunk sections – a bottom section, a middle
`section, and a top section as shown below.
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`1 of 37
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`Willis Exhibit 1015 - 1
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`Top Section
`
`Middle Section
`
`Bottom Section
`
`See photograph of HLT #20 tree trunk sections (annotated, above, left); See picture taken from HLT #20 User’s Manual; See
`Second Amended Complaint (“SAC”), item 90, p. 21 (annotated, above, right).
`
`The HLT #20 satisfies this limitation. As shown below, the HLT #20 includes a male end of a first trunk section of the
`plurality of tree trunk sections, the male end having a central prong and a channel prong, the central prong and the channel
`prong configured to conduct electricity. Shown below is a cutaway of the male end of a first trunk sections, showing the
`central prong and the channel prong. These prongs are made of a metallic material that conducts electricity when engaged,
`and thus the prongs are “configured to conduct electricity.”
`
`1.[c] a male end of
`a first trunk section
`of the plurality of
`tree trunk sections,
`the male end
`having a central
`prong and a
`channel prong, the
`central prong and
`the channel prong
`configured to
`conduct electricity
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`2 of 37
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`Willis Exhibit 1015 - 2
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`See photograph of HLT #20 male end (above); See Second Amended Complaint (“SAC”), items 91-92, p. 21.
`
`The HLT #20 satisfies this limitation. The HLT #20 includes a female end of a second trunk section of the plurality of tree
`trunk sections, the female end having a central void and a channel void, as shown below.
`
`Second Trunk
`Section
`
`Central Void
`
`1.[d] a female end
`of a second trunk
`section of the
`plurality of tree
`trunk sections, the
`female end having
`a central void and a
`channel void
`
`Female
`End
`
`Channel Void
`
`See photograph of HLT #20 female end (above); See SAC, items 93-94, p. 22.
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`3 of 37
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`Willis Exhibit 1015 - 3
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`The HLT #20 satisfies this limitation. The HLT #20 includes a central void having a central contact device disposed at least
`partially therein, and the channel void having a channel contact device disposed at least partially therein, the channel contact
`device disposed around the central void, and the central contact device and the channel contact device configured to conduct
`electricity.
`
`1.[e] the central
`void having a
`central contact
`device disposed at
`least partially
`therein, and the
`channel void
`having a channel
`contact device
`disposed at least
`partially therein,
`the channel contact
`device disposed
`around the central
`void, and the
`central contact
`device and the
`channel contact
`device configured
`to conduct
`electricity
`
`See photograph of HLT #20 female end (above); See SAC, items 95-96, p. 22-23.
`
`The central contact device is disposed at least partially in the central void, but is not easily visible when assembled. The
`central contact was removed from the central void for easier inspection. The removed contact device is shown below:
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`4 of 37
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`Willis Exhibit 1015 - 4
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`The central contact device is made of a metallic material which conducts electricity, and is thus “configured to conduct
`electricity.”
`
`The channel contact device is at least partially in the channel void and the channel contact device disposed around the central
`void, as shown below:
`
`See photograph of HLT #20 female end (above, trunk section cut away to show inner detail); See SAC, items 95-96, p. 22-
`23.
`
`The channel contact device is made of a metallic material which conducts electricity, and is thus “configured to conduct
`electricity.”
`
`1.[f] wherein the
`
`The HLT #20 satisfies this limitation. The HLT #20 includes a central prong of the male end configured to engage the central
`5 of 37
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`Willis Exhibit 1015 - 5
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`contact device of the female end and a channel prong of the male end configured to engage the channel contact device of the
`female end to conduct electricity between the male end of the first trunk section and the female end of the second trunk
`section. For example, shown below is the central prong of the male end engaging with the contact device of the female end.
`The female end has been disassembled to show this electrical connection.
`
`central prong of the
`male end is
`configured to
`engage the central
`contact device of
`the female end and
`the channel prong
`of the male end is
`configured to
`engage the channel
`contact device of
`the female end to
`conduct electricity
`between the male
`end of the first
`trunk section and
`the female end of
`the second trunk
`section
`
`See photograph of HLT #20 central prong and central contact device (above, central contact device removed from female
`end, with a portion of the safety cover and channel prong removed to show detail).
`
`The Holiday Living #20 Tree further includes a channel prong of the male end that is configured to engage the channel
`contact device of the female end to conduct electricity between the male end of the first trunk section and the female end of
`the second trunk section.
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`6 of 37
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`Willis Exhibit 1015 - 6
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`Male
`End
`
`Channel
`Prong
`
`Male
`End
`Female
`End
`Channel
`Contact
`Device
`
`Channel
`Prong
`
`Female
`End
`
`Channel
`Contact
`Device
`
`Disengaged
`
`Engaged
`
`See photograph of HLT #20 channel prong and channel contact device (disengaged, with a portion of the safety cover
`removed to show detail) (above, left); See photograph of HLT #20 channel prong and channel contact device (engaged, with
`a portion of the safety cover removed to show detail) (above, right).
`
`The HLT #20 satisfies this limitation. The HLT #20 includes a channel prong in its male end configured to engage the
`channel contact device of the female end in a plurality of configurations, each configuration providing a different rotational
`alignment of the first trunk section with respect to the second trunk section. As shown below, the male end is fitted inside
`the first trunk section, and the female end is fitted inside the second trunk section. Both the male and female ends are fitted
`with clutch elements, or teeth, that mechanically engage to lock the two ends together.
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`7 of 37
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`1.[g] wherein the
`channel prong of
`the male end is
`configured to
`engage the channel
`contact device of
`the female end in a
`plurality of
`configurations,
`each configuration
`providing a
`different rotational
`alignment of the
`first trunk section
`with respect to the
`second trunk
`section.
`
`Willis Exhibit 1015 - 7
`
`
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`That engagement can occur at a plurality of configurations at varying rotational alignments of the male end with respect to
`the female end, and consequently, the first trunk section with respect to the second trunk section. In each of the figures
`below, a line is drawn beneath a “B” marking on each of the male and female ends. As the male end is rotated with respect to
`the female end, the “B” marking on the male end moves, showing the two ends engaging at a plurality of configurations.
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`8 of 37
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`Willis Exhibit 1015 - 8
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`See photographs of HLT #20 male and female ends (above); See SAC, items 97-98, p. 23.
`
`The HLT #20 satisfies this limitation. The HLT #20 Tree includes a channel prong of the male end configured to engage the
`channel contact device of the female end in at least three configurations. As discussed above, the male end is fitted inside the
`first trunk section, and the female end is fitted inside the second trunk section. Both the male and female ends are fitted with
`clutch elements, or teeth, that mechanically engage to lock the two ends together.
`
`2. The artificial
`tree of claim 1,
`wherein the
`channel prong of
`the male end is
`configured to
`engage the channel
`contact device of
`the female end in
`at least three
`configurations.
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`9 of 37
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`Willis Exhibit 1015 - 9
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`That engagement can occur in at least three configurations at varying rotational alignments of the male end with respect to
`the female end, and consequently, the first trunk section with respect to the second trunk section. In each of the figures
`below, a line is drawn beneath a “B” marking on each of the male and female ends. As the male end is rotated with respect to
`the female end, the “B” marking on the male end moves, showing the two ends engaging in at least three configurations.
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`10 of 37
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`Willis Exhibit 1015 - 10
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`See photographs of HLT #20 male and female ends (above).
`
`The HLT #20 satisfies this limitation. The channel void of the female end of the HLT #20 is disposed 360 degrees around
`the central void of its female end.
`
`3. The artificial
`tree of claim 1,
`wherein the
`channel void of the
`female end is
`disposed 360
`degrees around the
`central void of the
`female end.
`
`11 of 37
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`Willis Exhibit 1015 - 11
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`See photographs of HLT #20 void and contact sections (above).
`
`The HLT #20 satisfies this limitation. For example, the channel contact device of the female end of the HLT #20 is disposed
`360 degrees around the central void of its female end.
`
`4. The artificial
`tree of claim 1,
`wherein the
`channel contact
`device of the
`female end is
`disposed 360
`degrees around the
`central void of the
`female end.
`
`12 of 37
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`Willis Exhibit 1015 - 12
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`
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`See photographs of HLT #20 void and contact sections (above).
`The HLT #20 satisfies this limitation. For example, the channel void of the female end of the HLT #20 is substantially
`circular. Further, the central void of the female end is disposed proximate the center of the substantially circular channel
`void.
`
`5. The artificial
`tree of claim 1,
`wherein the
`channel void of the
`female end is
`substantially
`circular, and the
`central void of the
`female end is
`disposed proximate
`the center of the
`substantially
`circular channel
`void.
`
`13 of 37
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`Willis Exhibit 1015 - 13
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`See photographs of HLT #20 void and contact sections (above).
`The HLT #20 satisfies this limitation. For example, the channel contact device of the female end of the HLT #20 is at least
`partially cylindrical. As can be seen below, the central void is formed inside a cylindrical member that extends, in a vertical
`orientation, inside the female end. The channel void surrounds this vertically extending member in a similarly cylindrical
`configuration.
`
`6. The artificial
`tree of claim 1,
`wherein the
`channel contact
`device of the
`female end is at
`least partially
`cylindrical.
`
`7. The artificial
`
`See photograph of HLT #20 contact device (above).
`The HLT #20 satisfies this limitation. For example, the central void of the female end of the HLT #20 is disposed within a
`14 of 37
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`Willis Exhibit 1015 - 14
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`
`
`tree of claim 6,
`wherein the central
`void of the female
`end is disposed
`within a vertically
`extending section
`of the female end,
`and wherein the
`channel contact
`device of the
`female end is
`disposed around
`the vertically
`extending section.
`
`8. The artificial
`tree of claim 7,
`wherein the
`channel contact
`device of the
`female end is
`disposed on the
`surface of the
`vertically
`extending section
`of the female end.
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`vertically extending section of the female end and the channel contact device of the female end is disposed around the
`vertically extending section. As can be seen below, the central void is formed inside a cylindrical member that extends, in a
`vertical orientation, inside the female end. The channel contact device surrounds this vertically extending member.
`
`See photograph of HLT #20 female end (above).
`
`The HLT #20 satisfies this limitation. For example, the channel contact device of the female end of the HLT #20 is disposed
`on the surface of the vertically extending section of the female end. As discussed above, there is a cylindrical member that
`extends, in a vertical orientation, inside the female end. The channel contact device is disposed on the outer circumference of
`the vertically extending member.
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`15 of 37
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`Willis Exhibit 1015 - 15
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`See photograph of HLT #20 female end (above).
`The HLT #20 satisfies this limitation. For example, the light strings of the HLT #20 are in electrical communication with the
`central prong of the male end, the channel prong of the male end, the central contact device of the female end, and the
`channel contact device of the female end. The light string enters an aperture in the body of the trunk section to electrically
`connect to the central prong and channel prong of the male end. The central prong and channel prong are made of metallic
`pieces that engage the metallic central contact device and the metallic channel contact device of the female end to conduct
`electricity. This electricity facilitates the electrical communication with the light string, as confirmed by plugging in the tree
`and the light strings turning on.
`
`9. The artificial
`tree of claim
`1 further
`comprising a light
`string in electrical
`communication
`with the central
`prong of the male
`end, the channel
`prong of the male
`end, the central
`contact device of
`the female end, and
`the channel contact
`device of the
`female end.
`
`16 of 37
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`Willis Exhibit 1015 - 16
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`10. The artificial
`tree of claim 9, one
`or more of the
`plurality of tree
`trunk sections
`comprising an
`inner sleeve and
`one or more of the
`plurality of tree
`trunk sections
`comprising an
`outer sleeve, the
`inner sleeve
`configured to slide
`inside the outer
`sleeve to provide
`
`See photograph of HLT #20 light string connection to male end (above).
`The HLT #20 satisfies this limitation. One or more of the plurality of tree trunk sections of the HLT #20 comprise an inner
`sleeve and one or more of the plurality of tree trunk sections of the HLT #20 comprise an outer sleeve, the inner sleeve
`configured to slide inside the outer sleeve to provide lateral support to the artificial tree. For example, the first tree trunk
`section of the HLT #20 comprises an inner sleeve and the second trunk section comprising an outer sleeve, the inner sleeve
`configured to slide into the inside of the outer sleeve. This sleeve configuration provides lateral support to the tree by
`preventing sideways movement of each of the trunk sections.
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`17 of 37
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`Willis Exhibit 1015 - 17
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`lateral support to
`the artificial tree.
`
`11.[a] An artificial
`tree comprising:
`
`11.[b] a plurality of
`tree trunk sections;
`11.[c] a male end
`of a first trunk
`section of the
`plurality of tree
`trunk sections, the
`male end having a
`central prong and a
`channel prong, the
`central prong and
`the channel prong
`configured to
`conduct electricity
`11.[d] a female end
`of a second trunk
`section of the
`plurality of trunk
`
`See photographs of HLT #20 inner and outer sleeves (above).
`The preamble is not limiting. Nevertheless, to the extent it is limiting, the HLT #20 satisfies this limitation. See supra, at
`Claim 1.a.
`
`The HLT #20 satisfies this limitation. See supra, at Claim 1.b
`
`The HLT #20 satisfies this limitation. See supra, at Claim 1.c
`
`The HLT #20 satisfies this limitation. See supra, at Claim 1.d
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`18 of 37
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`Willis Exhibit 1015 - 18
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`
`
`sections, the
`female end having
`a central void and a
`channel void
`11.[e] the central
`void having a
`central contact
`device disposed at
`least partially
`therein, and the
`channel void
`having a channel
`contact device
`disposed at least
`partially therein,
`the channel contact
`device disposed
`around the central
`void, and the
`central contact
`device and the
`channel contact
`device configured
`to conduct
`electricity
`11.[f] wherein the
`central prong of the
`male end is
`configured to
`engage the central
`contact device of
`the female end and
`the channel prong
`of the male end is
`configured to
`engage the channel
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`The HLT #20 satisfies this limitation. See supra, at Claim 1.e
`
`The HLT #20 satisfies this limitation. See supra, at Claim 1.f
`
`19 of 37
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`Willis Exhibit 1015 - 19
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`
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`The HLT #20 satisfies this limitation. The Holiday Living #20 Tree includes a channel prong in its male end configured to
`engage the channel contact device of the female end at a plurality of locations on the channel contact device, each location
`providing a different rotational alignment of the first trunk section with respect to the second trunk section. As shown below,
`the male end is fitted inside the first trunk section, and the female end is fitted inside the second trunk section. Both the male
`and female ends are fitted with clutch elements, or teeth, that mechanically engage to lock the two ends together.
`
`contact device of
`the female end to
`conduct electricity
`between the male
`end of the first
`trunk section and
`the female end of
`the second trunk
`section
`11.[g] wherein the
`channel prong of
`the male end is
`configured to
`engage the channel
`contact device of
`the female end at a
`plurality of
`locations on the
`channel contact
`device, each
`location providing
`a different
`rotational
`alignment of the
`first trunk section
`with respect to the
`second trunk
`section.
`
`That engagement can occur at a plurality of locations at varying rotational alignments of the male end with respect to the
`female end, and consequently, the first trunk section with respect to the second trunk section. In each of the figures below, a
`20 of 37
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`Willis Exhibit 1015 - 20
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`line is drawn beneath a “B” marking on each of the male and female ends. As the male end is rotated with respect to the
`female end, the “B” marking on the male end moves, showing the two ends engaging at a plurality of locations.
`
`21 of 37
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`Willis Exhibit 1015 - 21
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`
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`See photographs of HLT #20 male and female ends (above).
`The HLT #20 satisfies this limitation. The Holiday Living #20 Tree includes a channel prong of the male end configured to
`engage the channel contact device of the female end at at least three locations around the central void. As shown below, the
`male end is fitted inside the first trunk section, and the female end is fitted inside the second trunk section. Both the male and
`female ends are fitted with clutch elements, or teeth, that mechanically engage to lock the two ends together.
`
`12. The artificial
`tree of claim 11,
`wherein the
`channel prong of
`the male end is
`configured to
`engage the channel
`contact device of
`the female end at at
`least three
`locations around
`the central void.
`
`That engagement can occur in at least three locations at varying rotational alignments of the male end with respect to the
`female end, around the central void. In each of the figures below, a line is drawn beneath a “B” marking on each of the male
`and female ends. As the male end is rotated with respect to the female end, the “B” marking on the male end moves, showing
`the two ends engaging at at least three locations around the central void.
`
`22 of 37
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`Willis Exhibit 1015 - 22
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`13. The artificial
`tree of claim 11,
`
`See photograph of HLT #20 male and female ends (above).
`The HLT #20 satisfies this limitation. See supra, at Claim 3.
`
`23 of 37
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`Willis Exhibit 1015 - 23
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`wherein the
`channel void of the
`female end is
`disposed 360
`degrees around the
`central void of the
`female end.
`14. The artificial
`tree of claim 11,
`wherein the
`channel contact
`device of the
`female end is
`disposed 360
`degrees around the
`central void of the
`female end.
`15. The artificial
`tree of claim 11,
`wherein the
`channel void of the
`female end is
`substantially
`circular, and the
`central void of the
`female end is
`disposed proximate
`the center of the
`substantially
`circular channel
`void.
`
`The HLT #20 satisfies this limitation. See supra, at Claim 4.
`
`The HLT #20 satisfies this limitation. See supra, at Claim 5.
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`24 of 37
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`Willis Exhibit 1015 - 24
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`
`
`16. The artificial
`tree of claim 11,
`wherein the
`channel contact
`device of the
`female end is at
`least partially
`cylindrical.
`17. The artificial
`tree of claim 16,
`wherein the central
`void of the female
`end is disposed
`within a vertically
`extending section
`of the female end,
`and wherein the
`channel contact
`device of the
`female end is
`disposed around
`the vertically
`extending section.
`18. The artificial
`tree of claim 17,
`wherein the
`channel contact
`device of the
`female end is
`disposed on the
`surface of the
`
`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`The HLT #20 satisfies this limitation. See supra, at Claim 6.
`
`The HLT #20 satisfies this limitation. See supra, at Claim 7.
`
`The HLT #20 satisfies this limitation. See supra, at Claim 8.
`
`25 of 37
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`Willis Exhibit 1015 - 25
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`
`
`vertically
`extending section
`of the female end.
`19. The artificial
`tree of claim 11,
`the male end
`having a vertically
`extending section,
`the vertically
`extending section
`having a central
`void, and wherein
`the central prong
`and the channel
`prong are disposed
`at least partially
`within the central
`void of the
`vertically
`extending section
`of the male end.
`
`20. The artificial
`tree of claim
`11 further
`comprising one or
`more alignment
`mechanisms to
`prevent the first
`tree trunk section
`from rotating with
`
`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
`
`The HLT #20 satisfies this limitation. For example, the male end has a vertically extending section, the vertically extending
`section having a central void, and wherein the central prong and the channel prong are disposed at least partially within the
`central void of the vertically extending section of the male end. As can be seen below, both the channel prong and the central
`prong of the male end are housed inside a cylindrical member that extends, in a vertical orientation, from the male end.
`Between the vertically extending section and the channel prong is a void, the central void of the vertically extending section.
`
`See photograph of HLT #20 male end (above).
`
`The HLT #20 satisfies this limitation. For example, the HLT #20 includes one or more alignment mechanisms to prevent the
`first trunk section from rotating with respect to the second trunk section when the first tree trunk section and the second tree
`trunk section engage. In the image below, the male and female ends, and accordingly the first trunk section and the second
`trunk section, are connected, and their rotational motion is prevented by interlocking clutch elements or teeth.
`
`26 of 37
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`Willis Exhibit 1015 - 26
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`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
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`respect to the
`second tree trunk
`section when the
`first tree trunk
`section and the
`second tree trunk
`section engage.
`
`21.[a] An artificial
`tree comprising:
`21.[b] a plurality of
`tree trunk sections;
`21.[c] a male end
`of a first trunk
`section of the
`plurality of tree
`trunk sections, the
`male end having a
`central prong and a
`channel prong, the
`central prong and
`the channel prong
`
`See photograph of the HLT #20 male end interlocking with female end (above).
`
`The preamble is not limiting. Nevertheless, to the extent it is limiting, the Holiday Living Tree #20 (HLT #20) meets this
`limitation. See supra, at Claim 1.a
`The HLT #20 satisfies this limitation. See supra, at Claim 1.b.
`
`The HLT #20 satisfies this limitation. See supra at Claim 1.c.
`
`27 of 37
`
`Willis Exhibit 1015 - 27
`
`
`
`configured to
`conduct electricity
`21.[d] a female
`end of a second
`trunk section of the
`plurality of tree
`trunk sections, the
`female end having
`a central void
`disposed within a
`vertically
`extending section,
`the central void
`having a central
`contact device
`disposed at least
`partially therein,
`
`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
`
`The HLT #20 satisfies this limitation. For example, the HLT #20 includes a female end of a second trunk section of the
`plurality of tree trunk sections, the female end having a central void disposed within a vertically extending section.
`
`Second Trunk
`Section
`
`See photograph of HLT #20 female end (trunk section cut away to show inner detail).
`
`Additionally, the central void has a central contact device disposed at least partially therein. The central contact device is
`disposed at least partially in the central void, but is not easily visible when assembled. The central contact was removed
`from the central void for easier inspection. The removed contact device is shown below:
`
`28 of 37
`
`Willis Exhibit 1015 - 28
`
`
`
`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
`
`See photograph of HLT #20 central contact device (above).
`
`The HLT #20 satisfies this limitation. For example, the HLT #20 includes a female end also having a channel void disposed
`around the vertically extending section, the channel void having a channel contact device disposed at least partially therein,
`the channel contact device disposed around the vertically extending section, and the central contact device and the channel
`contact device configured to conduct electricity. As shown below, the channel void is disposed around the vertical extending
`section, and the channel contact device is disposed on and around the vertically extending section. Accordingly, the channel
`contact device is disposed at least partially in the channel void.
`
`See photograph of HLT #20 female end (trunk section cut away to show inner detail).
`
`Both the central contact device and the channel contact device are made of a metallic material which conducts electricity, and
`thus “configured to conduct electricity.”
`
`The HLT #20 satisfies this limitation. See supra, at Claim 1.f.
`
`29 of 37
`
`21.[e] the female
`end also having a
`channel void
`disposed around
`the vertically
`extending section,
`the channel void
`having a channel
`contact device
`disposed at least
`partially therein,
`the channel contact
`device disposed
`around the
`vertically
`extending section,
`and the central
`contact device and
`the channel contact
`device configured
`to conduct
`electricity,
`
`21.[f] wherein the
`central prong of the
`male end is
`
`Willis Exhibit 1015 - 29
`
`
`
`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
`
`configured to
`engage the central
`contact device of
`the female end and
`the channel prong
`of the male end is
`configured to
`engage the channel
`contact device of
`the female end to
`conduct electricity
`between the male
`end of the first
`trunk section and
`the female end of
`the second trunk
`section
`21.[g] wherein the
`channel prong of
`the male end is
`configured to
`engage the channel
`contact device of
`the female end in a
`plurality of
`configurations,
`each configuration
`providing a
`different rotational
`alignment of the
`first trunk section
`with respect to the
`second trunk
`section.
`22. The artificial
`tree of claim 21,
`
`The HLT #20 satisfies this limitation. See supra, at Claim 1.g.
`
`The HLT #20 satisfies this limitation. See supra, at Claim 8.
`
`30 of 37
`
`Willis Exhibit 1015 - 30
`
`
`
`wherein the
`channel contact
`device of the
`female end is
`disposed on the
`surface of the
`vertically
`extending section
`of the female end.
`23. The artificial
`tree of claim 21,
`wherein the
`vertically
`extending section
`of the female end
`is substantially
`cylindrical.
`
`24. The artificial
`tree of claim 21,
`the male end
`having a vertically
`extending section,
`the vertically
`extending section
`
`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
`
`The HLT #20 satisfies this limitation. For example, the channel contact device of the female end of the HLT #20 is
`substantially cylindrical. As can be seen below, the channel contact device is formed outside a cylindrical member that
`extends, in a vertical orientation, inside the female end. That vertically extending section is substantially cylindrical.
`
`See photograph of HLT #20 female end (above).
`
`The HLT #20 satisfies this limitation. See supra, at Claim 19.
`
`31 of 37
`
`Willis Exhibit 1015 - 31
`
`
`
`having a central
`void, and wherein
`the central prong
`and the channel
`prong are disposed
`at least partially
`within the central
`void of the
`vertically
`extending section
`of the male end.
`
`25. The artificial
`tree of claim 24,
`wherein the
`vertically
`extending section
`of the male end is
`substantially
`cylindrical.
`
`26. The artificial
`tree of claim 21,
`wherein the
`channel contact
`device of the
`female end is at
`
`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
`
`The HLT #20 satisfies this limitation. For example, the vertically extending section of the male end is substantially
`cylindrical.
`
`See photograph of HLT #20 male end (above).
`
`The HLT #20 satisfies this limitation. See supra, at Claim 6.
`
`32 of 37
`
`Willis Exhibit 1015 - 32
`
`
`
`least partially
`cylindrical.
`27. The artificial
`tree of claim 21,
`wherein the
`channel contact
`device of the
`female end is
`disposed 360
`degrees around the
`central void of the
`female end.
`
`28.[a] An artificial
`tree comprising:
`28.[b] a plurality of
`tree trunk sections;
`28.[c] a male end
`of a first trunk
`section of the
`plurality of tree
`trunk sections, the
`male end having a
`vertically
`extending section,
`a central prong,
`and a channel
`prong, the central
`prong and the
`channel prong
`disposed at least
`partially interior to
`the vertically
`extending section,
`and the central
`prong and the
`
`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
`
`The HLT #20 satisfies this limitation. See supra, at Claim 4.
`
`The preamble is not limiting. Nevertheless, to the extent it is limiting, it is met. See supra, at Claim 1.a
`
`The HLT #20 satisfies this limitation. See supra, at Claim 1.b.
`
`The HLT #20 satisfies this limitation. For example, the HLT #20 includes a male end of a first trunk section of the plurality
`of tree trunk sections, the male end having a vertically extending section, a central prong, and a channel prong, the central
`prong and the channel prong disposed at least partially interior to the vertically extending section, and the central prong and
`the channel prong configured to conduct electricity. As shown below, the vertically extending section is formed with a
`central void that houses both the channel prong and the central prong at least partially in the interior of the vertically
`extending section.
`
`33 of 37
`
`Willis Exhibit 1015 - 33
`
`
`
`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
`
`channel prong
`configured to
`conduct electricity
`
`28.[d] a female end
`of a second trunk
`section of the
`plurality of trunk
`sections, the
`female end having
`a central void and a
`channel void,
`28.[e] the central
`void having a
`central contact
`device disposed at
`least partially
`therein, and the
`channel void
`having a channel
`
`See photograph of HLT #20 male end (above).
`
`Both the central prong and the channel prong are made of a metallic material which conducts electricity, and thus
`“configured to conduct electricity.”
`The HLT #20 satisfies this limitation. See supra, at Claim 1.d.
`
`The HLT #20 satisfies this limitation. See supra, at Claim 1.e.
`
`34 of 37
`
`Willis Exhibit 1015 - 34
`
`
`
`Polygroup Macau Limited (BVI) v. Willis Electric Co., Ltd. – Exhibit D
`
`contact device
`disposed at least
`partially therein,
`the channel contact
`device disposed
`around the central
`void, and the
`central contact
`device and the
`channel contact
`device configured
`to conduct
`electricity
`28.[f] wherein the
`central prong of the
`male end is
`configured to
`engage
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