throbber
Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 1 of 108 PageID #:
` 2545
`
`Exhibit A
`
`Exhibit A1: Fundamental's Intrinsic and Extrinsic Evidence for the '111, '586, '766 and '550 Patents
`
`Exhibit A2: Fundamental's Intrinsic and Extrinsic Evidence for the '319 and '514 Patents
`
`Exhibit A3: Fundamental's Intrinsic and Extrinsic Evidence for the '655 Patent
`
`Exhibit A4: Summary of Opinions by Dr. Kenneth Fernald
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 2 of 108 PageID #:
` 2546
`
`Exhibit A1: Fundamental's Intrinsic and Extrinsic Evidence for the '111, '586, '766 and '550 Patents
`
`
`
`Patent/
`Claim
`
`Term1
`
`'111 patent,
`claims 1-17
`
`USB
`connector
`
`Fundamental’s
`Proposed
`Construction
`USB connector:
`a component
`that includes
`pins for Vbus
`and Gnd power,
`and D+ and D-
`communications
`and that
`connects to a
`USB device,
`hub, host or
`adapter
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`'936, 6:46-7:2 ("FIG. 2 is a schematic
`diagram of a first embodiment of an adapter
`100 that can be used to couple the mobile
`device 10 of FIG. 1 to the data/power source
`56 of FIG. 1. In this example, the adapter
`100 is a USB adapter 100 that comprises a
`primary USB connector 102 . . . Also shown
`in FIG. 2 is an optional auxiliary USB
`connector 112 that can be used to couple the
`mobile device 10 to a data source (not
`shown) such as a personal computer. [¶] In
`the embodiment shown in FIG. 2, the
`primary USB connector 102 is configured to
`mate with the USB connector 54 of the
`mobile device 10. The USB adapter 100 is
`operable to provide power to the mobile
`device 10 through the Vbus and Gnd power
`pins in the USB connectors 54 and 102. The
`USB adapter 100 also optionally provides a
`communication for data across the D+ and
`D- data pins in the USB connectors 54 and
`102"); Fig. 2
`
`
`
`USB 2.0, pp. 1, 14, 24, 85-92
`(captive cables with one end
`terminated with a vendor-specific
`connector means);
`
`
`
`USB 2.0 ECN #1 (10/20/2000), e.g.,
`p.1 ("Reason for ECN:
`
`The USB 2.0 specified device-side
`connector – the B connector – is too
`large for use with a new generation
`of handheld and mobile devices,
`e.g., cell phones which would
`benefit from connectivity to the PC.
`This ECN incorporates a
`specification of a device-side mini
`connector (hereafter referred to as a
`mini-B connector). The new
`connector only applies to upstream
`facing ports, i.e., connectors on
`devices."); id. ("Assessment of
`Impact on Current Specification and
`Current USB Products:
`
`'936, 6:7-14 ("Coupled to the USB port 18 is
`a USB connector 54. The USB connector
`
`The connector specified in the ECN
`will not have any impact on
`
`
`1 The phrases in square brackets provide context and require no construction.
`2 The ’111, ’586, ’766, and ’550 patents share a common specification, along with U.S. Patent No. 6,936,936. Thus, citations to the
`specifications of each patent are interchangeable.
`
`
`
`
`A1-1
`
`
`
`

`

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` 2547
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`54 is the physical component that couples
`the USB port to the outside world. In the
`exemplary mobile device 10, the USB
`connector 54 is used to transmit and receive
`data from an external data/power source 56,
`receive power from the external data/power
`source 56, direct the transmitted/received
`data from/to the USB port 18, and direct the
`received power to the power subsystem
`20.");
`
`'936, 2:24-30 ("The primary USB connector
`is electrically coupled to the power
`converter and is operative to couple to the
`mobile device and to deliver the outputted
`power requirement to the mobile device.
`The identification subsystem is electrically
`coupled to the primary connector and is
`operative to provide an identification
`signal."); 2:40-45 ("The primary USB
`connector is electrically connected coupled
`to the power converter and is operative to
`couple to the mobile device and to deliver
`the outputted power requirement to the
`mobile device. The auxiliary USB connector
`has data lines that are electrically coupled to
`the data lines to the primary USB
`connector."); 2:46-60 ("Yet another aspect
`provides a method for providing energy to a
`
`hardware or software of existing
`USB products. The current USB
`spec already allows for vendor-
`specific device side connectors –
`such cable assemblies are called
`captive assemblies. All that the
`ECN does is to identify one such
`connector for use in devices which
`need the smaller size of connector.
`There is a potential for some end-
`user confusion because of two
`standard cable options; but this can
`be mitigated by appropriate end-user
`education."); p. 98 (pin assignment,
`adding an ID pin in addition to D+,
`D-, Gnd and Vbus).
`
`"Universal Serial Bus on-the-Go for
`Portable Devices" (2/29/2000
`Presentation) (contemplating new
`USB connector forms for USB OTG
`application);
`
`OTG Supplement 1.0 (Dec. 2001),
`p. 6, Section 3.8 (adding Mini-A
`plug, Min-A receptacle and mini-
`AB receptacle); pp. 9-32, Section 4
`(supplemental mechanical
`requirements on the newly
`
`A1-2
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 4 of 108 PageID #:
` 2548
`
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`mobile device using a USB adapter that
`comprises a plug unit, a primary USB
`connector, a power converter electrically
`coupled between the plug unit and the
`primary USB connector, and an
`identification subsystem electrically coupled
`to the primary USB connector. The method
`comprising the steps of coupling the USB
`connector the mobile device, coupling the
`plug unit to a power socket, outputting a
`power requirement to the mobile device via
`the power converter and the USB connector,
`and providing an identification signal to the
`mobile device, via the identification
`subsystem and the USB connector, that is
`operative to inform the mobile device that
`the USB adapter is not limited by the power
`limits imposed by the USB specification.");
`see also, e.g., Abstract ("The primary
`connector is electrically coupled to the
`power converter and is operative to couple
`to the mobile device and to deliver the
`outputted power requirement to the mobile
`device. The identification subsystem is
`electrically coupled to the primary
`connector and is operative to provide an
`identification signal."); 2:9-14 (same); 2:15-
`19 ("In accordance with another aspect, a
`USB adapter for providing a source of
`power to a mobile device through a USB
`
`introduced connector types,
`including new pins);
`
`
`
`USB Cables and Connectors Class
`Document v. 1.0 (1999), p.1, section
`1.1 ("In addition, this document
`provides detailed requirements for
`the design, approval and
`implementation of application
`specific USB connectors and
`fabricated cable assemblies."); p.2
`(ASUPS: "The acronym for
`Application Specific USB Product
`Specification. An ASUPS describes
`the unique characteristics of a
`special purpose nonstandard USB
`connector or cable assembly
`specification.");
`
`
`
`USB devices with proprietary USB
`ports and connectors, including
`Olympus C700 Ultrazoom (see user
`manual, images of CB-USB1 cable
`that came with the device, and
`image from Amazon.com site),
`Pentax Optio 330 Manual (see user
`manual and images); Sony
`Cybershot DSC-F505 (see user
`manual and images); Kodak
`
`A1-3
`
`
`
`
`
`
`
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 5 of 108 PageID #:
` 2549
`
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`port is provided. The USB adapter
`comprises a plug unit, a power converter, a
`primary USB connector, and an
`identification subsystem.")
`
`
`
`'936, 3:46-47 ("an industry standard
`interface 18 which in this example is a USB
`port");
`
`
`
`'936, 3:54-57 ("The USB port 18 provides
`the mobile device 10 with a serial port for
`linking directly with other computers and/or
`a means for receiving power from an
`external power source.");
`
`
`
`'936, 5:56-6:14 ("The USB port 18 provides
`the mobile device 10 with a serial port for
`linking directly with other computers to
`exchange data and/or to receive power. The
`USB port 18 also provides the mobile
`device 10 with a means for receiving power
`from an external power source. . . . .");
`
`
`
`'936, 7:31-33 ('The power
`converter 104 provides its energy output to
`the mobile device 10 via the Vbus and Gnd
`
`Easyshare DX3215 (see user manual
`and images); Kodak Easyshare Z612
`(see user manual, images and
`Kodak website information on
`devices that use USB Cable, Model
`U-8); see also, e.g., manuals and
`images related to Handspring
`Treo90 and Nikon Coolpix.
`
`
`
`USB Micro-USB Cables and
`Connectors Specification (2007) at
`p. 6, section 1.1;
`
`USB 3.0 Specification, pp. 5-1, 5-2,
`11-1, 11-2; section 5.2.1.;
`
`USB 3.1 Specification, pp. 5-1, 5-2,
`11-1, 11-2; sections 5.3 & 5.4;
`
`USB Type-C Cables and Connectors
`Specification v.1.3, pp. 21-23, 60,
`61, 66-67 section 3.4.2, Figure 3-23,
`Tables 3-5, 3-11;
`
`Dr. Fernald's testimony as
`summarized in Exhibit A4.
`
`[NB: The citations referenced are
`examples only. The entire
`document is relevant.]
`
`A1-4
`
`
`
`
`
`
`
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 6 of 108 PageID #:
` 2550
`
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`pins of the primary USB connector 102.");
`
`
`
`'936, 7:57-67 ("The power distribution and
`charging subsystem 58 of the mobile device
`10 can selectively use the power provided
`on the Vbus and Gnd lines of the USB
`connector 54 to provide power to the mobile
`device 10, charge the battery 60, or both. A
`more detailed discussion of how the
`charging function of mobile device 10 can
`be implemented is described in United
`States Provisional Application No.
`60/273,021 filed on Mar. 1st, 2001 and
`entitled 'System and Method for Adapting a
`USB to Provide Power for Charging a
`Mobile Device' which has been incorporated
`herein by reference.");
`
`
`
`'936, 8:1-12 ("Typically when a mobile
`device 10 receives power over the USB
`from a USB host, it is required to draw
`power in accordance with the USB
`specification. The USB specification
`specifies a process for transferring energy
`across the USB called enumeration and
`limits the electrical current that can flow
`across the USB. [¶] The USB adapter 100
`contributes to a system wherein a device 10
`that follows the USB specification when
`
`A1-5
`
`
`
`
`
`
`
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 7 of 108 PageID #:
` 2551
`
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`coupled to a typical USB host via its USB
`port can be informed that the USB adapter
`100 has been coupled to the device 10 and
`that the device 10 can now draw power
`without regard the USB specification and
`the USB specification imposed limits.");
`
`
`
`'936, 8:27-32 ("The identification
`subsystem 108 may optionally be
`configured to have the capability of
`electrically connecting or disconnecting the
`power output from the power
`converter 104 from the USB
`connector 102 and/or to connect or
`disconnect any data inputs from the USB
`adapter 100 to the USB connector 102.");
`
`
`
`'936, 8:33-40 ("In addition to providing
`power to the mobile device 10 over the
`primary USB connector 102, the USB
`adapter 100 may optionally be equipped
`with an auxiliary USB connector 112 that
`allows the USB adapter 100 to create a
`communication path between the mobile
`device 10 and some other device capable of
`communicating over the USB such as a
`personal computer, another mobile device or
`some other type of device.");
`
`A1-6
`
`
`
`
`
`
`
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 8 of 108 PageID #:
` 2552
`
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`'936, 8:41-49 ("The USB adapter 100
`preferably provides a communication path
`between the D+ and D- pins of the primary
`USB connector 102 and the D+ and D- pins
`of the auxiliary USB connector 112. In the
`embodiment shown, the communication
`path also traverses the identification
`subsystem 108. Alternatively, the
`communication path could bypass the
`identification subsystem 108. The USB
`adapter 100 can thus act as a pass through
`device for communication between a USB
`hub or host and a mobile device 10.");
`
`
`
`'936, 9:11-13 ("The preferred identification
`signal results from the application of voltage
`signals greater than 2 volts to both the D+
`and D− lines in the USB connector.");
`
`
`
`'936, 9:16-10:31 (method of identifying
`non-USB host power source, which also
`includes circumstances when the device
`determines that it is connected to a USB
`host (in which case, the device just
`undergoes normal enumeration for normal
`data/power transmission)).
`
`A1-7
`
`
`
`
`
`
`
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 9 of 108 PageID #:
` 2553
`
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`'936, 10:33-55 (describing Fig. 4 that adds a
`battery receptacle 318 to allow simultaneous
`charging of a mobile device's primary and
`spare battery, noting "The exemplary USB
`adapter 300 comprises a USB connector
`302, a power converter 304, a plug unit 306,
`and an identification subsystem 308. The
`USB connector 302, plug unit 306, and
`identification subsystem 308, preferably
`correspond to the USB connector 102, plug
`unit 106, and identification subsystem 108
`which were described earlier with respect to
`the first embodiment."); Fig. 4.
`
`
`
`'936, 11:10-27 ("Other alternative
`embodiments of the USB adapter may
`include various combinations of
`components described above with respect to
`the first and additional embodiments.
`Another embodiment of the USB adapter
`may include a second or more auxiliary
`USB connectors. A USB adapter having
`one or more auxiliary USB connectors may
`optionally be configured such that one or
`more of the auxiliary USB connectors may
`have power from the USB adapter's power
`converter made available to it so that
`multiple USB devices may draw power
`
`A1-8
`
`
`
`
`
`
`
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 10 of 108 PageID #:
` 2554
`
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`simultaneously. Preferably, a USB adapter
`having multiple auxiliary USB connectors
`will be configured such that the data lines in
`the auxiliary connectors can, on a selective
`basis, be electrically connected to or
`disconnected from the data lines in the
`primary USB connector. This allows
`mobile device connected to the primary
`USB connector to receive energy from the
`adapter regardless of whether a USB host or
`hub is connected to an auxiliary USB
`connector.").
`
`
`
`App. 60/330,486 (filed Oct. 2001, "486
`App") at 2:18-21 ("Given that USB
`connectors are popular widely supported in
`industry a USB chargeable device solves the
`problem of the combined interface at a USB
`chargeable mobile device.");
`
`
`
`'486 App, 14:1-5 ("Power flows out of
`adapter 100 via USB connector 52, on the
`Vbus and Gnd lines to USB connector 47 in
`USB device 10. Preferably, power
`distribution and charging subsystem 44
`selectively uses power on the Vbus and Gnd
`lines of USB connector 47 to optionally
`power device 10, and charge first battery
`
`A1-9
`
`
`
`
`
`
`
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 11 of 108 PageID #:
` 2555
`
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`48A via battery terminals 54A.");
`
`
`
`'486, App. 15:12-15 ("In this example, the
`charger identification block 53 of USB
`adapter 100 of Fig. 2 forces both D+ and D-
`to 5V, allowing step 220 to determine that
`the device connected to USB connector 47
`is not a typical USB host or a hub. . . .")
`
`
`
`'486 App, 18:10-19: 4 ("Although not
`expressly shown in the drawings, alternate
`embodiments of USB adapters may include
`a second or more USB connectors. If more
`than one USB connector is present in a USB
`adapter, then USB connector 52 refers to a
`downstream USB connector and as such
`many USB devices may draw power
`simultaneously from one or more USB
`downstream connectors. Preferably, a USB
`adapter configured with more than one USB
`connectors is connected to a host via one
`USB connector, which acts as an upstream
`USB connector, whereas a USB device is
`connected to the USB adapter via a
`downstream USB connector. It is envisaged
`that the USB adapter configured with
`downstream and at least one upstream
`connector can selectively electrically
`connect the data portions of the upstream
`
`A1-10
`
`
`
`
`
`
`
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 12 of 108 PageID #:
` 2556
`
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`and downstream USB connectors, thereby
`resulting in a USB device connected to a
`downstream connector being selectively
`attached and detached from the host or hub
`for data connected to the USB upstream
`connector for data communication purposes,
`while the USB device is still able to draw a
`maximum of power from the USB
`adapter.");
`
`
`
`'486 App., Figs. 1-4;
`
`
`
`App. 60/273,021 (filed Mar. 2001, "021
`App"), p. 3 ("Recently the hitherto separate
`fields of USB and mobile devices have
`collided. Certain rechargeable mobile
`devices have evolved to access USB
`capabilities in order to become USB
`peripherals for the purpose of
`communicating with USB host controllers
`such as a computer. [¶] In some cases, USB
`capabilities have been incorporated into the
`docking cradle, whereas in other cases USB
`capabilities have been integrated into the
`rechargeable mobile device itself, in a
`manner analogous to the location of the
`traditional charging system. Traditional
`rechargeable mobile devices having a USB
`already have access to two power supplies,
`
`A1-11
`
`
`
`
`
`
`
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 13 of 108 PageID #:
` 2557
`
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`specifically a portable power supply and an
`alternate power supply. Therefore USB
`capable rechargeable mobile devices
`traditionally operate as self-powered USB
`peripherals. [¶]There is a need for a system
`and method of adapting the charging system
`of a USB capable rechargeable mobile
`device to use the power traditionally
`available on the USB as an alternate power
`source for recharging the portable power
`supply of the mobile device thereby
`eliminating the need for a separate charging
`and USB interfaces.");
`
`
`
`'021 App., pp.5-6 ("In reference to Figure 1,
`a USB interface 100 comprising a Vbus
`power line 100, D+ data line 120, D- data
`line 130 and GND power line 140 is
`connected to a charging circuit 400 via the
`Vbus 110 and GND 140 power lines.").
`
`
`
`'021 App., p. 7 ("In another embodiment of
`the invention, the USB interface accessible
`to the mobile device is further adapted in
`order to favour two modes of operation: a
`charging mode and the traditional
`communications mode."); Fig. 1.
`
`[NB: The citations referenced are examples
`
`A1-12
`
`
`
`
`
`
`
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 14 of 108 PageID #:
` 2558
`
`
`Patent/
`Claim
`
`Term1
`
`Fundamental’s
`Proposed
`Construction
`
`Examples of Intrinsic Evidence2
`
`Examples of Extrinsic Evidence
`
`only. The entire document is relevant.]
`
`
`
`A1-13
`
`
`
`
`
`
`
`
`
`
`

`

`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 15 of 108 PageID #:
` 2559
`
`
`
`
`Patent/
`Claim
`
`Term
`
`Fundamental's
`Proposed
`Construction
`
`'586, claims
`8-13
`
`Universal
`Serial Bus
`("USB")
`interface
`[configured
`to allow
`reception of
`a] USB
`cable
`
`USB interface: an
`interface capable
`of communication
`according to a
`USB specification
`and capable of
`receiving power
`from an external
`power source
`
`USB cable: cable
`including
`conductors for
`Vbus and Gnd
`power and D+ and
`D-
`communications
`
`Examples of Intrinsic Evidence
`
`Examples of Extrinsic Evidence
`
`'936, 1:33-42 ("With regard to the mobile
`device, most mobile devices provide a
`distinct power interface for receiving power
`from a power source, for instance to
`recharge a battery, and a separate data
`interface for communicating. For example,
`many mobile devices presently use USB
`(Universal Serial Bus) interfaces for
`communicating and use a separate power
`interface, such as a barrel connector, for
`receiving power. [¶] It is desirable, however,
`to have a combined power and data
`interface"); see also, '486 App., 2:5-7 ("On
`one hand, most mobile devices provide a
`first power interface for receiving power
`from a power source, for instance to
`recharge a battery, and a second data
`interface for communicating that is separate
`from the power interface."), 2:12-14;
`
`'936, 1:48-63 ("Although the USB interface
`can be used as a power interface, the USB is
`typically not used for that purpose by
`mobile devices. In accordance with the USB
`specification, typical USB power source
`devices, such as hubs and hosts, require that
`a USB device participate in a host-initiated
`process called enumeration in order to be
`compliant with the current USB
`specification in drawing power from the
`
`USB 2.0, p.86, section 8.6 ("USB
`cable consists of four conductors,
`two power conductors, and two
`signal conductors."); pp.87-92
`(examples of USB cables);
`
`USB 2.0 ECN #1 (Mini-B
`connector), pp.85-94 (cable
`assemblies), 98 (pin assignment)
`
`OTG 1.0, p. 10 (mini-A pin
`assignment)
`
`see also, e.g.,
`
`USB 2.0, pp. 1, 14, 24, 85-92
`(captive cables );
`
`"Universal Serial Bus on-the-Go
`for Portable Devices" (2/29/2000
`Presentation)
`
`OTG Supplement 1.0 (Dec. 2001),
`p. 6, Section 3.8; pp. 9-32, Section
`4;
`
`USB Cables and Connectors Class
`Document v. 1.0 (1999), pp. 1-2
`USB devices with proprietary USB
`ports and connectors, including
`
`
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`A1-14
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`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 16 of 108 PageID #:
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`Patent/
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`Term
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`Fundamental's
`Proposed
`Construction
`
`Examples of Intrinsic Evidence
`
`Examples of Extrinsic Evidence
`
`USB interface. Although a mobile device
`could be adapted to participate in
`enumeration when drawing power over the
`USB interface, it would be preferable in
`many situations, such as when a host would
`not be available, as often happens during
`normal use of a mobile device, to be able to
`utilize alternate power sources such as
`conventional AC outlets and DC car sockets
`that are not capable of participating in
`enumeration to supply power to the mobile
`device via a USB interface."); '486 App.,
`3:1-8 ("[T]raditional USB power source
`devices, such as hubs and hosts, require that
`a USB device participate in a host-initiated
`process called enumeration in order to be
`compliant with the current USB
`specification in drawing power from the
`USB interface. Although a USB chargeable
`device is capable of enumeration, it is
`preferable in some situations, such as when
`a host is not available, as often happens
`during normal use of a mobile device, to be
`able to adapt alternate power sources such
`as conventional AC outlets and DC car
`sockets, to supply power to a USB device
`via a USB interface.");
`
` '936, 1:66-67 ("An adapter for providing a
`source of power to a mobile device through
`
`Olympus C700 Ultrazoom (see
`user manual, images of CB-USB1
`cable that came with the device,
`and image from Amazon.com site),
`Pentax Optio 330 Manual (see user
`manual and images); Sony
`Cybershot DSC-F505 (see user
`manual and images); Kodak
`Easyshare DX3215 (see user
`manual and images); Kodak
`Easyshare Z612 (see user manual,
`images and Kodak website
`information on devices that use
`USB Cable, Model U-8); see also,
`e.g., manuals and images related to
`Handspring Treo90 and Nikon
`Coolpix;
`
`USB Micro-USB Cables and
`Connectors Specification (2007) at
`p. 6, section 1.1
`USB 3.0 Specification, pp. 5-1, 5-
`2, 11-1, 11-2; section 5.2.1;
`
`USB 3.1 Specification, pp. 5-1, 5-
`2, 11-1, 11-2; sections 5.3 & 5.4;
`
`USB Type-C Cables and
`Connectors Specification v.1.3, pp.
`21-23, 60, 61, 66-67 section 3.4.2,
`
`A1-15
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`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 17 of 108 PageID #:
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`Fundamental's
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`
`Examples of Intrinsic Evidence
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`Examples of Extrinsic Evidence
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`an industry standard port is provided.");
`
`Figure 3-23, Tables 3-5, 3-11;
`
`extrinsic evidence cited for "USB
`connector";
`
`Dr. Fernald's testimony as
`summarized in Exhibit A4.
`
`[NB: The citations referenced are
`examples only. The entire
`document is relevant.]
`
`
`'936, Abstract ("The primary connector is
`electrically coupled to the power converter
`and is operative to couple to the mobile
`device and to deliver the outputted power
`requirement to the mobile device. The
`identification subsystem is electrically
`coupled to the primary connector and is
`operative to provide an identification
`signal.")
`
`'936, 2:15-19 ("In accordance with another
`aspect, a USB adapter for providing a source
`of power to a mobile device through a USB
`port is provided. The USB adapter
`comprises a plug unit, a power converter, a
`primary USB connector, and an
`identification subsystem.");
`
`'936, 2:24-30 ("The primary USB connector
`is electrically coupled to the power
`converter and is operative to couple to the
`mobile device and to deliver the outputted
`power requirement to the mobile device.
`The identification subsystem is electrically
`coupled to the primary connector and is
`operative to provide an identification
`signal.");
`
`A1-16
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`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 18 of 108 PageID #:
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`Fundamental's
`Proposed
`Construction
`
`Examples of Intrinsic Evidence
`
`Examples of Extrinsic Evidence
`
`'936, 2:40-45 ("The primary USB connector
`is electrically coupled to the power
`converter and is operative to couple to the
`mobile device and to deliver the outputted
`power requirement to the mobile device.
`The auxiliary USB connector has data lines
`that are electrically coupled to the data lines
`of the primary USB connector.");
`
`'936, 2:51-60 ("The method comprising the
`steps of coupling the USB connector to the
`mobile device, coupling the plug unit to a
`power socket, outputting a power
`requirement to the mobile device via the
`power converter and the USB connector,
`and providing an identification signal to the
`mobile device, via the identification
`subsystem and the USB connector, that is
`operate to inform the mobile device that the
`USB adapter is not limited by the
`power limits imposed by the USB
`specification.");
`
`'936, 3:46-47 ("an industry standard
`interface 18 which in this example is a USB
`port"); Figs. 1, 2 and 4.
`
`'936, 3:54-57 ("The USB port 18 provides
`the mobile device 10 with a serial port for
`linking directly with other computers and/or
`
`A1-17
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`Fundamental's
`Proposed
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`
`Examples of Intrinsic Evidence
`
`Examples of Extrinsic Evidence
`
`a means for receiving power from an
`external power source.");
`
`'936, 5:56-6:14 ("The USB port 18 provides
`the mobile device 10 with a serial port for
`linking directly with other computers to
`exchange data and/or to receive power. The
`USB port 18 also provides the mobile
`device 10 with a means for receiving power
`from an external power source. For
`example, in a personal digital assistant
`(PDA)-type communication device, the
`USB port 18 could be used to allow the
`mobile device 10 to synchronize data with a
`user's desktop computer (not shown). The
`USB port 18 could also enable a user to set
`parameters in the mobile device 10 such as
`preferences through the use of an external
`device or software application. In addition
`the USB port 18 may also be used to
`provide a means for downloading
`information or software to the mobile device
`10 without using the wireless
`communication network 34. The USB port
`18 can provide a direct and thus reliable and
`trusted connection that may for example be
`used to load an encryption key onto the
`mobile device 10 thereby enabling secure
`device communication. [¶] Coupled to the
`USB port 18 is a USB connector 54. The
`
`A1-18
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`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 20 of 108 PageID #:
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`Patent/
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`Term
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`Fundamental's
`Proposed
`Construction
`
`Examples of Intrinsic Evidence
`
`Examples of Extrinsic Evidence
`
`USB connector 54 is the physical
`component that couples the USB port to the
`outside world. In the exemplary mobile
`device 10, the USB connector 54 is used to
`transmit and receive data from an external
`data/power source 56, receive power from
`the external data/power source 56, direct the
`transmitted/received data from/to the USB
`port 18, and direct the received power to the
`power subsystem 20."); see also, e.g., '486
`App., 11:16-12:7;
`
`'936, 6:62-64 ("In the embodiment shown
`in FIG. 2, the primary USB connector 102 is
`configured to mate with the USB
`connector 54 of the mobile device 10.");
`
`'936, 6:66-7:2 (" The USB adapter 100 also
`optionally provides a communication path
`for data across the D+ and D− data pins in
`the USB connectors 54 and 102.");
`
`'936, 7:31-33 ('The power
`converter 104 provides its energy output to
`the mobile device 10 via the Vbus and Gnd
`pins of the primary USB connector 102.");
`
`'936, 7:57-67 ("The power distribution and
`charging subsystem 58 of the mobile
`device 10 can selectively use the power
`
`A1-19
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`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 21 of 108 PageID #:
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`Examples of Intrinsic Evidence
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`Examples of Extrinsic Evidence
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`provided on the Vbus and Gnd lines of the
`USB connector 54 to provide power to the
`mobile device 10, charge the battery 60, or
`both. A more detailed discussion of how the
`charging function of mobile device 10 can
`be implemented is described in United
`States Provisional Application No.
`60/273,021 filed on Mar. 1st, 2001 and
`entitled 'System and Method for Adapting a
`USB to Provide Power for Charging a
`Mobile Device' which has been incorporated
`herein by reference.");
`
`'936, 8:7-12 ("The USB adapter 100
`contributes to a system wherein a device 10
`that follows the USB specification when
`coupled to a typical USB host via its USB
`port can be informed that the USB adapter
`100 has been coupled to the device 10 and
`that the device 10 can now draw power
`without regard to the USB specification and
`the USB specification imposed limits.");
`
`'936, 8:27-32 (". . . The identification
`subsystem 108 may optionally be
`configured to have the capability of
`electrically connecting or disconnecting the
`power output from the power
`converter 104 from the USB
`connector 102 and/or to connect or
`
`A1-20
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`Case 2:16-cv-01425-JRG-RSP Document 103-1 Filed 12/29/17 Page 22 of 108 PageID #:
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`Fundamental's
`Proposed
`Construction
`
`Examples of Intrinsic Evidence
`
`Examples of Extrinsic Evidence
`
`disconnect any data inputs from the USB
`adapter 100 to the USB connector 102.");
`
`'936, 8:41-44 ("The USB
`adapter 100 preferably provides a
`communication path between the D+ and
`D− pins of the Primary USB
`connector 102 and the D+ and D− pins of
`the auxiliary USB connector 112.");
`
`'936, 9:8-9 ("the prese

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