Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 1 of 13 Page ID #:81
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`Exhibit D
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`1
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`KINGSTON 1006
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`Exhibit D
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`1
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`KINGSTON 1006
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 2 of 13 Page ID #:82
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`(cid:1)
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`Exhibit D
`U.S. Patent No. 6,088,802
`v.
`Kingston's DataTraveler Vault Privacy 3.01
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`
`
`Claim Language
`Claim 11
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`A peripheral device, comprising: Kingston designs, manufactures and sells peripheral devices. For example, Kingston sells encrypted
`USB flash drives, such as the DataTraveler Vault Privacy 3.0. The DataTraveler Vault Privacy 3.0, a
`peripheral device, intended to be plugged into external ports on a computer.
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`Selected Analysis and Evidence
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`(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)(cid:1)
`1 Investigation of both the patent and the potentially infringing product continues. This chart is constructed based on selections of the
`best available evidence and analysis at the time of filing. SPEX reserves the right to update and amend its contentions, including
`adding additional claims, as the litigation progresses.
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`1
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`2
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 3 of 13 Page ID #:83
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`Claim Language
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`Selected Analysis and Evidence
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`(cid:1)
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`[a] security means for enabling
`one or more security operations
`to be performed on data;
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`Kingston's DataTraveler Vault Privacy 3.0 includes a security means for enabling one or more
`security operations to be performed on data.
`
`If this claim element is treated as a means-plus-function claim element, the corresponding structures
`of this claim element are expected to be at least:
`1. Cryptographic processing device 801;
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`2
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`3
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 4 of 13 Page ID #:84
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`(cid:1)
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`Claim Language
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`Selected Analysis and Evidence
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`2. Security mechanism 302a;
`3. Security token; or
`4. Equivalents thereof.
`
`Kingston's DataTraveler Vault Privacy 3.0 meets this limitation. For example, this device has
`hardware-based encryption. See, e.g., http://www.kingston.com/us/usb/encrypted_security/dtvp30.
`This device uses the Phison PS2251-13-1 chip to perform security operations on data. For example,
`this device enables at least AES encryption/decryption (also known as FIPS 197).
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`3
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`4
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 5 of 13 Page ID #:85
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`(cid:1)
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`Claim Language
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`Selected Analysis and Evidence
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`The following is an X-ray of the device's components:
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`
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`The Phison PS2251-13-1 is not listed on Phison's website but the information available shows it can
`perform the AES256 algorithm.
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`4
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`5
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 6 of 13 Page ID #:86
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`(cid:1)
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`Claim Language
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`Selected Analysis and Evidence
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`[b] target means for enabling a
`defined interaction with a host
`computing device;
`
`
`
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`To the extent it can be argued that the single chip implementation in this device is not a
`cryptographic processing device 801, security mechanism 302a or security token as described in the
`'802 patent, it is an equivalent thereof. In light of the advancements of microchip technology since
`the '802 patent was filed on June 4, 1997, the combination of the mediation and cryptographic chip
`functionality is the equivalent because it has the same function, in the same way and with the same
`result as described in the '802 patent.
`
`Kingston's DataTraveler Vault Privacy 3.0 includes a target means for enabling a defined interaction
`with a host computing device.
`
`If this claim element is treated as a means-plus-function claim element, the corresponding structures
`of this claim element are expected to be at least:
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`5
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`6
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 7 of 13 Page ID #:87
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`Claim Language
`
`Selected Analysis and Evidence
`1. Non-volatile memory device, including ATA, SCSI and IDE disks;
`2. Data communications modem;
`3. LAN transceiver;
`4. Biometric device, conventional device for storing and/or manipulating data, and a sensor for
`physical characteristics;
`5. Smart card reader; or
`6. Equivalents thereof.
`
`Kington's DataTraveler Vault Privacy 3.0 meets this limitation. For example, the device contains
`non-volatile solid-state storage memory in a variety of storage sizes. See, e.g.,
`http://www.kingston.com/us/usb/encrypted_security/dtvp30. An example of the storage memory is
`shown below.
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`6
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`7
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 8 of 13 Page ID #:88
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`(cid:1)
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`Claim Language
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`Selected Analysis and Evidence
`
`
`The following is an X-ray of the device's components:
`
`
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`7
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`8
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 9 of 13 Page ID #:89
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`(cid:1)
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`Claim Language
`[c] means for enabling
`communication between the
`security means and the target
`means;
`
`Selected Analysis and Evidence
`Kingston's DataTraveler Vault Privacy 3.0 includes a means for enabling communication between
`the security means and the target means.
`
`If this claim element is treated as a means-plus-function claim element, the corresponding structures
`of this claim element are expected to be at least:
`1. Conventional computer bus 615; or
`2. Equivalents thereof.
`
`Kingston's DataTraveler Vault Privacy 3.0 meets this limitation. This device is built as a
`conventional computer device and uses conventional computer bus technology to communicate
`among the various components, including the security means and the target means. An example of
`the interface is shown below:
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`
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`[d] means for enabling
`communication with a host
`computing device; and
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`Kingston's DataTraveler Vault Privacy 3.0 includes a means for establishing communication with a
`host computing device.
`
`If this claim element is treated as a means-plus-function claim element, the corresponding structures
`of this claim element are expected to be at least:
`1. Communications interface 303;
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`8
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`9
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 10 of 13 Page ID #:90
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`(cid:1)
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`Claim Language
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`Selected Analysis and Evidence
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`2. I/O interface 806;
`3. PCMCIA;
`4. Cord between housing and matching receptacle;
`5. Wireless communication;
`6. Smart card interface;
`7. Serial interface (such as RS-232);
`8. Parallel interface;
`9. SCSI interface;
`10. IDE interface; or
`11. Equivalents thereof.
`
`Kingston's DataTraveler Vault Privacy 3.0 meets this limitation. For example, this device utilizes the
`Universal Serial Bus ("USB") to communicate with a host computer device, such as a computer. See,
`e.g., http://www.kingston.com/us/usb/encrypted_security/dtvp30. Thus, this device uses a serial
`interface.
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`9
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`10
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 11 of 13 Page ID #:91
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`(cid:1)
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`Claim Language
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`Selected Analysis and Evidence
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`[e] means for mediating
`communication of data between
`the host computing device and
`the target means so that the
`communicated data must first
`pass through the security means.
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`
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`Kingston's DataTraveler Vault Privacy 3.0 includes a means for mediating communication of data
`between the host computing device and the target means so that the communicated data must first
`pass through the security means.
`
`If this claim element is treated as a means-plus-function claim element, the corresponding structures
`of this claim element are expected to be at least:
`1. Interface control device 802;
`2. Interface control device 902; or
`3. Equivalents thereof.
`
`Kingston's DataTraveler Vault Privacy 3.0 meets this limitation. For example, this device ensures
`that all data that is passed to its storage drive (i.e., the target means) from the host computer is
`encrypted. See, e.g., http://www.kingston.com/us/usb/encrypted_security/dtvp30. Similarly, data
`read from the storage drive is decrypted before being passed to the host computer. See, e.g., id. The
`encryption/decryption algorithm is performed by the security means. All data between the host
`computer and the memory must be mediated such that it passes through the security means to be
`encrypted or decrypted. Additionally, on information and belief, communications of other types,
`such as signal information, are mediated such that it may not pass through the security means.
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`10
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`11
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 12 of 13 Page ID #:92
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`(cid:1)
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`Selected Analysis and Evidence
`Because this device uses a single chip interface and cryptographic chip configuration, the means for
`mediating is illustrated in the pictures below.
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`
`
`Claim Language
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`The following is an X-ray of the device's components:
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`11
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`12
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`Case 8:16-cv-01790 Document 1-4 Filed 09/27/16 Page 13 of 13 Page ID #:93
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`(cid:1)
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`Claim Language
`
`Selected Analysis and Evidence
`
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`To the extent it can be argued that the single chip implementation in this device is not an interface
`control device 802 or an interface control device 902 as described in the '802 patent, it is an
`equivalent thereof. In light of the advancements of microchip technology since the '802 patent was
`filed on June 4, 1997, the combination of the mediation and cryptographic chip functionality is the
`equivalent because it has the same function, in the same way and with the same result as described in
`the '802 patent.
`
`
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`
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`12
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`'802 Patent v. Kingston's DataTraveler Vault Privacy 3.0
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`13
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