`FOR THE DISTRICT OF DELAWARE
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`CYWEE GROUP LTD.,
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`CASE NO.
`
`Plaintiff,
`
`v.
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`GOOGLE, INC.,
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`Defendant.
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`PLAINTIFF’S ORIGINAL
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`JURY TRIAL DEMANDED
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`1.
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`Plaintiff CyWee Group Ltd. (“Plaintiff” or “CyWee”), by and through
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`its undersigned counsel, files this Original Complaint against Google, Inc.
`
`(“Google”) as follows:
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`THE PARTIES
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`2.
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`CyWee is a corporation existing under the laws of the British Virgin
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`Islands with a principal place of business at 3F, No.28, Lane 128, Jing Ye 1st
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`Road, Taipei, Taiwan 10462.
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`3.
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`CyWee is a world-leading technology company that focuses on
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`building products and providing services for consumers and businesses. CyWee
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`has one of the most significant patent portfolios in the industry and is a market
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`leader in its core development areas of motion processing, wireless high definition
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`video delivery, and facial tracking technology.
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`4.
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`Google, Inc. is a wholly-owned subsidiary of Alphabet, Inc. Google is
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`a Delaware company with its principal place of business in California at 1600
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`GOOGLE 1026
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`0001
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`
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`Amphitheatre Parkway, Mountain View, CA 94043. Google may be served
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`through its agent for service of process, Corporation Service Company, 2710
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`Gateway Oaks Drive, Suite 150N, Sacramento, CA 95833.
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`JURISDICTION AND VENUE
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`5.
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`This action arises under the patent laws of the United States, 35
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`U.S.C. § 1 et seq. This Court has subject matter jurisdiction pursuant to 28 U.S.C.
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`§§ 1331 and 1338(a).
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`6.
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`This Court has personal jurisdiction over Google. Google has
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`conducted and does conduct business within the State of Delaware. Google has
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`purposefully and voluntarily availed itself of the privileges of conducting business
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`in the United States and in the State of Delaware by continuously and
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`systematically placing goods into the stream of commerce through an established
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`distribution channel with the expectation that they will be purchased by consumers
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`in Delaware. Google is registered to do business in Delaware and has authorized
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`retailers for the accused products in this judicial district. Plaintiff’s cause of action
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`arises directly from Google’s business contacts and other activities in the State of
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`Delaware. Additionally, Google is incorporated in Delaware. Accordingly, this
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`Court has personal jurisdiction over Google because it resides in this District.
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`7.
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`Upon
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`information and belief, Google has committed acts of
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`infringement in this District giving rise to this action and does business in this
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`
`
`0002
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`
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`District, including making sales and/or providing service and support for their
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`respective customers in this District. Google purposefully and voluntarily sold one
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`or more of its infringing products with the expectation that they would be
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`purchased by consumers in this District. These infringing products have been and
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`continue to be purchased by consumers in this District. Google has committed acts
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`of patent infringement within the United States and the State of Delaware.
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`8.
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`Venue is proper as to Google under 28 U.S.C. § 1400(b) in that
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`Google is incorporated in Delaware and, therefore, resides in this District.
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`BACKGROUND
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`Patentee And The Asserted Patents.
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`9.
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`The Industrial Technology Research Institute (“ITRI”) is a Taiwanese
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`government- and industry-funded research and development center. In 2007,
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`CyWee, which was started at ITRI, was formed. Its goal was to provide innovative
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`motion-sensing technologies, such as those claimed in the patents-in-suit. Dr.
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`Shun-Nan Liu and Chin-Lung Li, two of the inventors of the patents-in-suit, came
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`to CyWee from ITRI. The third inventor, Zhou “Joe” Ye joined CyWee from
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`private industry as its President and served as CEO from 2006 to 2016.
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`10. The inventors, Zhou Ye, Chin-Lung Li, and Shun-Nan Liou,
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`conceived of the claims of the patents-in-suit—U.S. Patent No. 8,441,438 (the
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`“’438 patent”) and U.S. Patent No. 8,552,978 (the “’978 patent”)—at CyWee
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`
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`0003
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`
`
`
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`Group Ltd., located at 3F, No. 28, Lane 128, Jing Ye Road, Taipei. A true and
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`correct copy of the ’438 patent and the ’978 patent are attached hereto as Exhibit A
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`and Exhibit B respectively, in accordance with Local Rule 3.2.
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`11. Several claims of the patents-in-suit are entitled to a priority date of at
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`least January 6, 2010 based on U.S. Provisional Application Serial No. 61/292,558,
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`filed January 6, 2010 (“Provisional Application”).
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`12. Before May 22, 2009, CyWee began working on the “JIL Game
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`Phone Project” or “JIL Phone.” Before July 29, 2009, CyWee developed a solution
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`for the JIL Phone that practiced several claims of the ’438 patent. Those claims
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`were diligently and constructively reduced to practice thereafter through the filing
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`of the Provisional Application and were diligently and actually reduced to practice
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`as discussed below. Accordingly, CyWee is entitled to a priority date of at least
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`July 29, 2009 for several claims of the ’438 patent.
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`13. The JIL Phone was reduced to practice by at least September 25,
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`2009. The JIL Phone practiced several claims of both patents-in-suit. Accordingly,
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`CyWee is entitled to a priority date of at least September 25, 2009 for several
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`claims of the patents-in-suit.
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`Background Of The Technology.
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`14. The ’438 patent and ’978 patent are each directed to devices and
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`methods for tracking the motion of a portable electronic device in 3D space and
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`
`
`0004
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`
`
`
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`compensating for accumulated errors to map the 3D movements of the device onto
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`a display frame (’438 patent) or transform the 3D movements for a display, such as
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`a 2D display on a computer or handheld device (’978 patent). ’438 patent 1:17-52,
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`3:52-57; ’978 patent 1:22-27, 7:5-18; Exhibit C, Declaration of Nicholas Gans,
`
`Ph.D. (“Gans Decl.”) ¶ 8. At a high level, the patented inventions teach how to
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`determine a device’s current orientation based on motion data detected by its
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`motion sensors, such as an accelerometer, gyroscope, and magnetometer. ’438
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`patent 4:6-30; ’978 patent 4:15-44; Gans Decl. ¶ 8. The ’438 patent and ’978
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`patent describe portable electronic devices or pointing devices such as smartphones
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`and navigation equipment. ’978 patent 22:34-40, Fig. 6; ’438 patent 4:6-30, Fig. 6;
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`Gans. Decl. ¶ 8.
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`15. There are different types of motion sensors, including accelerometers,
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`gyroscopes, and magnetometers. Gans Decl. ¶ 9. Accelerometers measure
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`accelerations. Id. For example, airbags use accelerometers, such that the airbag is
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`triggered based on sudden deceleration. Accelerometers can also measure forces
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`due to gravity. Id. Gyroscopes measure rotation rates or angular velocities. Id.
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`Magnetometers measure magnetism, including the strength of a magnetic field
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`along a particular direction. Id. Each type of motion sensor is subject to
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`inaccuracies. Id. For example, a gyroscope sensor has a small, added offset or bias.
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`Id. This bias will accumulate over time and lead to large drift error. Id. Similarly,
`
`
`
`0005
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`
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`
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`magnetometers are subject to interference from natural and manmade sources (e.g.,
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`power electronics). Id. Additionally, errors can accumulate over time. Id. These
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`sensors typically take measurements along a single direction. Id. To accurately
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`measure motions along an arbitrary axis, three like sensors are grouped together
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`and aligned at right angles. Id. Such a sensor set is generally referred to as a 3-axis
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`sensor. Id.
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`16. Orientation information returned by the claimed inventions of the
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`’438 patent and ’978 patent has many uses, particularly for mobile cellular devices,
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`such as navigation, gaming, and augmented/virtual reality applications. Gans Decl.
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`¶ 12. Navigation applications can use orientation information to determine the
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`heading of the phone, indicate what direction the user is facing, and automatically
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`orient the map to align with the cardinal directions. Id. Increasing numbers of
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`games and other applications use the motion of the phone to input commands, such
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`as tilting the mobile device like a steering wheel. Id. Augmented and virtual reality
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`applications rely on accurate estimation of the device orientation in order to render
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`graphics and images at the proper locations on the screen. Id.
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`17. Prior to 2010, motion sensors had limited applicability to portable
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`electronic devices due to a variety of technological hurdles. Gans Decl. ¶ 13. For
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`example, different types of acceleration (e.g., linear, centrifugal, gravitational)
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`could not be readily distinguished from one another, and rapid, dynamic, and
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`
`
`0006
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`
`
`
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`unexpected movements caused significant errors and inaccuracies. Id. These
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`difficulties were compounded by the miniaturization of the sensors necessary to
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`incorporate them in portable electronic devices. Id. With the development of
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`micro-electromechanical systems, or “MEMS,” miniaturized motion sensors could
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`be manufactured and incorporated on a semiconductor chip, but such MEMS
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`sensors had significant limitations. Id.
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`18. For example, it is impossible for MEMS accelerometers to distinguish
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`different types of acceleration (e.g., linear, centrifugal, gravitational). Gans Decl. ¶
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`14. When a MEMS accelerometer is used to estimate orientation, it must measure
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`force along the direction of gravity (i.e., down), but that gravitational measurement
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`can be “interfused” with other accelerations and forces (e.g., vibration or
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`movement by the person holding the device). Id. Thus, non-gravitational
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`accelerations and forces must be estimated and subtracted from the MEMS
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`accelerometer measurement to yield an accurate result. Id. A MEMS gyroscope is
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`prone to drift, which will accumulate increasing errors over time if not corrected
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`by another sensor or recalibrated. Id. A MEMS magnetometer is highly sensitive to
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`not only the earth’s magnetic fields, but other sources of magnetism (e.g., power
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`lines and transformers) and can thereby suffer inaccuracies from environmental
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`sources of interference that vary both in existence and intensity from location to
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`location. Id.
`
`
`
`0007
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`
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`19. Additionally, orientation cannot be accurately calculated using only
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`one type of MEMS sensor. Gans Decl. ¶ 15. For example, if only a 3-axis MEMS
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`accelerometer is used to measure orientation, pitch and yaw can be measured, but
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`not roll. Id. If only a MEMS gyroscope is used to measure angular velocity, only
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`relative changes in orientation can be measured, not absolute orientation. Id.
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`20. Without orientation information, mobile device apps would be limited
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`to very static operation. Gans Decl. ¶ 16. This was the scenario with initial smart
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`phones and other mobile devices. Id. Navigation aids could render a map and
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`indicate the location of the device using GPS. Id. However, these maps would
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`orient with North on the map pointing to the top of the screen. Id. The user could
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`rotate the map using touch commands, but the map would not rotate automatically
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`as the user turned. Id. Nor could the device indicate what direction the device was
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`facing. Id.
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`21. Many games use motion of the device to control the game. Gans Decl.
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`¶ 17. A common control scheme, especially for driving and piloting games, is to
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`have the user rotate the device, such as a phone or game controller, like a steering
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`wheel to indicate the direction the vehicle should move. Id. Some puzzle games
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`also use motions to cause elements of the game to move. Id. As discussed
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`previously, accelerometers measure acceleration, which is a very noisy signal. Id.
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`Acceleration is the derivative of velocity, which is the derivative of position. Id.
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`
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`0008
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`
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`Small magnitude noise can have large derivatives, which means that small levels of
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`noise from vibration or electrical fluctuations will be magnified at the acceleration
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`level. Id. Even a stationary device will have notable noise measured by an
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`accelerometer. Id. A moving device will only amplify this noise. Id. Since
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`accelerometers measure linear and centripetal accelerations as well as the
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`acceleration of gravity, orientation estimates on a moving device will not be
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`accurate. Id.
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`22.
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`If only an accelerometer is used, a coarse estimate of the device
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`orientation can be obtained by averaging or numerically filtering the results. Gans
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`Decl. ¶ 18. Essentially, the device can determine if it is tilted left or right, up or
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`down, but the exact angle cannot be estimated accurately while in motion. Id. This
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`is suitable for games to move a character or steer a vehicle in a particular direction,
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`but generally cannot utilize the magnitude of tilt to move at corresponding faster or
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`slower speeds. Id.
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`23. Movement on a display can, of course, be controlled by means other
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`than a portable electronic device with orientation sensors. Gans Decl. ¶ 19. For
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`example, games could be controlled using traditional “joystick” type inputs. Id. For
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`smart phones with touch screens, commands are given by having the user touch
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`specific parts of the screen. Id.
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`
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`0009
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`
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`24. For other current applications, portable electronic devices with
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`orientation sensors are more crucial. Gans Decl. ¶ 20. Augmented reality (AR) and
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`virtual reality (VR) are new and growing classes of applications for smart phones
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`and mobile devices. Id. In AR, the device camera provides live video feed to the
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`screen, and the application overlays generate graphics onto the screen at specific
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`locations. Id. AR navigation apps can draw signs or labels to indicate what specific
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`places or objects are or can render arrows or other indicators. Id. AR games and
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`teaching applications can label objects or draw characters or items such that they
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`appear as if they are in the real world seen in the video. Id. Virtual reality is similar
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`but does not use the camera, rather it completely renders an artificial 3D
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`environment on the screen. Id. VR most often requires a head set such that the user
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`only sees the screen. Id. Mobile devices and smart phones used for VR generally
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`split the screen and display to two side-by-side images of the rendered
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`environment that are slightly offset to simulate a left and right eye. Id. The device
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`then sits in a headset with lenses such that the user has each eye see only one of the
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`split-screen images and has a sense of stereo (3D) vision. Id.
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`25. Without orientation sensing, AR and VR applications cannot work.
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`Gans Decl. ¶ 21. The system will have no ability to understand the orientation of
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`the device and know where to draw objects and/or the scene. Id. The rough
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`orientation estimate provided by an accelerometer (ideally with a magnetometer)
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`
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`0010
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`
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`will not be sufficient to track during typical head motions. Id. It has been
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`demonstrated that VR applications that use an accelerometer often cause motion
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`sickness, as the rendered images do track with the head motions. Id. An AR
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`application with the use of a gyroscope and fusion algorithm will not render
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`objects at the correct locations, and may obscure the view rather than provide
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`helpful information. Id.
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`26. There are ways to estimate orientation other than the approaches
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`presented in the ’438 patent or ’978 patent, which involve algorithms that filter and
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`fuse measurements from inertial and magnetic sensors. Gans Decl. ¶ 22. Most such
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`methods are based on cameras and computer vision algorithms. Id. However, the
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`limitations of these methods render them unusable for portable electronic devices.
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`Id. For example, there are a variety of motion capture systems that use cameras
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`arrayed around an environment. Id. Markers (e.g., reflective balls) can be placed on
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`objects, and the cameras can locate the markers, often to sub-mm accuracy. Id. If
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`an object has three or more markers on it, the orientation of the object can be
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`determined with sub-degree accuracy. Id. This method is very accurate, but quite
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`expensive (often about $100,000). Id. The cameras are fixed in place, and the
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`estimation can only work within a small space (a box of dimensions on the order of
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`tens of meters). Id. This is not suitable for the vast majority of mobile device users
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`or applications. Id.
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`
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`0011
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`27. A camera on a portable electronic device, such as a smart phone, can
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`be used to estimate orientation of the phone. Gans Decl. ¶ 23. One class of
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`approaches to this problem uses special patterns or markers in the environment. Id.
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`These often have the appearance of a QR code or 2D UPC. Id. Taking a picture of
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`the pattern, computer vision algorithms can determine the position and orientation
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`of the camera with respect to the marker. Id. AR applications have placed the
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`patterns on specific objects or consumer products so the device can render images
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`and graphics with respect to the pattern. Id. AR games have included patterned
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`mats that are placed on a table or other flat surface, and the device renders
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`characters and objects as if they were on the surface. Id.
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`28. Multiple unique patterns can be placed around an environment; so
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`long as one is always in view, the camera can maintain an estimate of the
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`orientation and position. Gans Decl. ¶ 24. In this way, it can be used for
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`navigation. Id. The necessity of placing patterns would make this approach useless
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`for a majority of applications, particularly outdoors. Id. The camera would also
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`need to remain on at all times, which would cause severe battery drain. Id.
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`29. Orientation of the camera can also be estimated over an indefinite
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`amount of time using vision algorithms known as visual odometry. Gans Decl. ¶
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`25. In visual odometry, changes in the image over time are used to estimate the
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`camera velocity. Id. This velocity can be integrated over time to estimate the
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`
`
`0012
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`
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`change in orientation. While these methods are well understood, they can only
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`track change in relative orientation, not give absolute orientation. Id. They also
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`require the camera to be on at all times, which will greatly reduce battery life. Id.
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`The Prior Art.
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`30. As noted in both the ’438 patent and ’978 patent, prior art portable
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`electronic devices, such as pointing devices, smartphones and navigation
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`equipment, had several deficiencies in addressing the technological challenges of
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`mapping and transforming movement in a 3D space to a 2D display. These prior
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`art portable devices could only output the movement of the device in 2D, rather
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`than the 3D reference frame of the ’438 and’978 patents. ’438 patent 2:47-55; ’978
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`patent 2:41-58. In addition, the portable devices could not accurately calculate and
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`account for movements of the device in a dynamic environment, such as erroneous
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`drift measurements of the device or accelerations along with the direction of
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`gravity. ’438 patent 2:55-62; ’978 patent 2:58-66. These prior art portable devices
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`were also limited to detecting gravitational acceleration detected by the
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`accelerometer and were therefore incapable of accurately outputting the actual
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`yaw, pitch and roll angles. ’438 patent 2:62-3:5; ’978 patent 2:66-3:13. Finally, for
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`the specific case of pointing devices, when they extended beyond the border or
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`boundary of the display, the absolute movement pattern was not mapped, but
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`instead the location outside the boundary was ignored and a relative movement
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`
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`0013
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`
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`pattern used, which resulted in uncompensated errors. ’438 patent 3:16-51; ’978
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`patent 3:20-52.
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`PATENT INFRINGEMENT OF U.S. PATENT NO. 8,441,438
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`31. Plaintiff repeats and re-alleges each and every allegation of
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`paragraphs 1-30 as though fully set forth herein.
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`32. The ’438 patent, titled “3D Pointing Device and Method for
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`Compensating Movement Thereof,” was duly and legally issued by the United
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`States Patent and Trademark Office on May 14, 2013 to CyWee Group Limited, as
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`assignee of named inventors Zhou Ye, Chin-Lung Li, and Shun-Nan Liou.
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`33. CyWee is the owner of all right, title, and interest in and to the ’438
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`patent with full right to bring suit to enforce the patent, including the right to
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`recover for past infringement damages.
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`34. The ’438 patent claims, inter alia, a machine capable of detecting,
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`measuring, and calculating the movements and rotations of the machine—utilizing,
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`inter alia, a six-axis motion sensor module, a data transmitting unit, and a
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`computing processor in one or more claimed configurations—and methods for
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`measuring and calculating the movements and rotations of a device within a spatial
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`reference frame. See, generally, Gans Decl.¶¶ 8-12.
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`35. The ’438 patent
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`is directed
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`to useful and novel particular
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`embodiments and methods for detecting, measuring, and calculating motion within
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`
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`0014
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`
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`a spatial reference frame. Id. ¶ 27. Specifically, the ’438 patent claims a novel
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`system involving multiple sensor types and a novel method for using those sensors
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`to overcome the limitations of the individual sensor types in accurately
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`determining the orientation of a device. See id. ¶¶ 26-28. The ’438 patent is not
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`intended to, and does not claim every possible means of detecting, measuring, and
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`calculating motion within a spatial reference frame. There are alternative methods
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`to determining orientation within a spatial reference frame, such as systems and
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`methods utilizing computer vision algorithms and/or cameras. See id. ¶¶ 22-25, 33.
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`The ’438 patent is directed to a technological solution to a technological problem.
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`Id. ¶¶ 33-35. Accordingly, the ’438 patent is not directed to, and does not claim,
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`the mere concept of motion sensing or of detecting, measuring, and calculating
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`motion within a spatial reference frame. Id. ¶¶ 29-35.
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`36. Each and every claim of the ’438 patent is valid and enforceable and
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`each enjoys a statutory presumption of validity separate, apart, and in addition to
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`the statutory presumption of validity enjoyed by every other of its claims. 35
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`U.S.C. § 282.
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`37. CyWee is informed and believes, and thereupon alleges, that Google
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`has been, and is currently, directly and/or indirectly infringing one or more claims
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`of the ’438 patent in violation of 35 U.S.C. § 271, including as stated below.
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`
`
`0015
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`38. CyWee is informed and believes, and thereupon alleges, that Google
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`has directly infringed, literally and/or under the doctrine of equivalents, and will
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`continue to directly infringe claims of the ’438 patent by making, using, selling,
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`offering to sell, and/or importing into the United States products that embody or
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`practice the apparatus and/or method covered by one or more claims of the ’438
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`patent including, but not limited to, Google’s following devices:
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`
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`0016
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` Google Pixel
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` Google Pixel 2
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` Google Pixel XL
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` Google Pixel 2 XL
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`The foregoing devices are collectively referred to as the “’438 Accused
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`Products” and include the below specifications and features.
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`39. On information and belief, Google indirectly infringes the ’438 patent
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`by inducing others to infringe one or more claims of the ’438 patent through sale
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`and/or use of the ’438 Accused Products. On information and belief, at least as a
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`result of the filing of this action, Google is aware of the ’438 patent; is aware that
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`its actions with regards to distributors, resellers, and/or end users of the ’438
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`Accused Products would induce infringement; and despite such awareness will
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`
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`0017
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`continue to take active steps—such as, creating and disseminating the ’438
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`Accused Products and product manuals, instructions, promotional and marketing
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`materials, and/or technical materials to distributors, resellers, and end users—
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`encouraging others’ infringement of the ’438 patent with the specific intent to
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`induce such infringement.1 Users of the ’438 Accused Products infringe through
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`the ordinary use of such products. Google further induces others to infringe by
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`marketing
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`the
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`accused
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`products VR
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`and/or AR
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`capabilities.
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`See
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`https://store.google.com/
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`us/product/pixel_2?utm_source=en-ha-na-
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`sem&utm_medium=text&utm_term=US
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`sale&ds_kid=43700024791423013&utm_content=bkws&utm_campaign=Pixel&g
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`clid=Cj0KCQiAyszSBRDJARIsAHAqQ4ouuVPL5FfpJ6LKd-eFT_H963mAond-
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`6M5FDxrDHnEZrtiKvPQsGFwaAqRGEALw_wcB&gclsrc=aw.ds&dclid=CPCzr
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`7D8yNgCFYYC0wodJwwB-Q (“Better with Pixel High quality VR, wherever you
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`go.”);
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`see
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`also
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`https://store.google.com/us/product/google_daydream_view
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`(describing “Google Daydream View.”). CyWee expects discovery to provide
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`more facts relevant to Google’s induced infringement.
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`40. The Google Pixel includes a display screen.
`
`
`1 To preempt any argument that such allegations are insufficient to establish a claim for induced infringement,
`CyWee respectfully notes that at least one court previously held such allegations sufficient. See, e.g., Huawei Techs.
`Co. v. T-Mobile US, Inc., Case No. 2:16-cv-00052-JRG-RSP, 2017 WL 1129951, at *3 (E.D. Tex. Feb. 21, 2017)
`(“Huawei’s complaints adequately plead knowledge. Huawei alleges that T-Mobile knew of the asserted patents
`‘since at least the filing of this action.’”).
`
`
`
`0018
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`41. The Google Pixel includes a housing.
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`42. The Google Pixel includes a 3-axis accelerometer.
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`43. The Google Pixel includes a 3-axis gyroscope.
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`44. The Google Pixel includes at least one printed circuit board (“PCB”).
`
`45. The Google Pixel includes a 3-axis accelerometer attached to a PCB.
`
`46. The Google Pixel includes a 3-axis gyroscope attached to a PCB.
`
`47. The Google Pixel includes a 3-axis accelerometer that is capable of
`
`measuring accelerations.
`
`48. The Google Pixel includes a 3-axis gyroscope that is capable of
`
`measuring rotation rates.
`
`49. The Google Pixel runs an AndroidTM operating system.
`
`50. The Google Pixel includes a 3-axis accelerometer that is capable of
`
`measuring accelerations using a “Sensor Coordinate System” as described in the
`
`AndroidTM developer
`
`library. See https://developer.android.com/guide/topics
`
`/sensors/sensors_overview.html (describing “Sensor Coordinate System”).
`
`51. The Google Pixel includes a 3-axis gyroscope that is capable of
`
`measuring rotation rates using a “Sensor Coordinate System.”
`
`52. The Google Pixel includes a processor that is capable of processing
`
`data associated with measurement from a 3-axis accelerometer.
`
`
`
`0019
`
`
`
`
`
`53. The Google Pixel includes a processor that is capable of processing
`
`data associated with measurement from a 3-axis gyroscope.
`
`54. The AndroidTM operating system that runs on the Google Pixel uses
`
`the measurement from a 3-axis accelerometer included in the device.
`
`55. The AndroidTM operating system that runs on the Google Pixel uses
`
`the measurement from a 3-axis gyroscope included in the device.
`
`56. The AndroidTM operating system that runs on the Google Pixel uses
`
`the measurement from a 3-axis accelerometer and the measurement from a 3-axis
`
`gyroscope to calculate an attitude of the device.
`
`57. The Google Pixel 2 includes a display screen.
`
`58. The Google Pixel 2 includes a housing.
`
`59. The Google Pixel 2 includes a 3-axis accelerometer.
`
`60. The Google Pixel 2 includes a 3-axis gyroscope.
`
`61. The Google Pixel 2 includes at least one PCB.
`
`62. The Google Pixel 2 includes a 3-axis accelerometer attached to a
`
`PCB.
`
`63. The Google Pixel 2 includes a 3-axis gyroscope attached to a PCB.
`
`64. The Google Pixel 2 includes a 3-axis accelerometer that is capable of
`
`measuring accelerations.
`
`
`
`0020
`
`
`
`
`
`65. The Google Pixel 2 includes a 3-axis gyroscope that is capable of
`
`measuring rotation rates.
`
`66. The Google Pixel 2 runs an AndroidTM operating system.
`
`67. The Google Pixel 2 includes a 3-axis accelerometer that is capable of
`
`measuring accelerations using a “Sensor Coordinate System” as described in the
`
`AndroidTM developer
`
`library. See https://developer.android.com/guide/topics
`
`/sensors/sensors_overview.html (describing “Sensor Coordinate System”).
`
`68. The Google Pixel 2 includes a 3-axis gyroscope that is capable of
`
`measuring rotation rates using a “Sensor Coordinate System.”
`
`69. The Google Pixel 2 includes a processor that is capable of processing
`
`data associated with measurement from a 3-axis accelerometer.
`
`70. The Google Pixel 2 includes a processor that is capable of processing
`
`data associated with measurement from a 3-axis gyroscope.
`
`71. The AndroidTM operating system that runs on the Google Pixel 2 uses
`
`the measurement from a 3-axis accelerometer included in the device.
`
`72. The AndroidTM operating system that runs on the Google Pixel 2 uses
`
`the measurement from a 3-axis gyroscope included in the device.
`
`73. The AndroidTM operating system that runs on the Google Pixel 2 uses
`
`the measurement from a 3-axis accelerometer and the measurement from a 3-axis
`
`gyroscope to calculate an attitude of the device.
`
`
`
`0021
`
`
`
`
`
`PCB.
`
`74. The Google Pixel XL includes a display screen.
`
`75. The Google Pixel XL includes a housing.
`
`76. The Google Pixel XL includes a 3-axis accelerometer.
`
`77. The Google Pixel XL includes a 3-axis gyroscope.
`
`78. The Google Pixel XL includes at least one PCB.
`
`79. The Google Pixel XL includes a 3-axis accelerometer attached to a
`
`80. The Google Pixel XL includes a 3-axis gyroscope attached to a PCB.
`
`81. The Google Pixel XL includes a 3-axis accelerometer that is capable
`
`of measuring accelerations.
`
`82. The Google Pixel XL includes a 3-axis gyroscope that is capable of
`
`measuring rotation rates.
`
`83. The Google Pixel XL runs an AndroidTM operating system.
`
`84. The Google Pixel XL includes a 3-axis accelerometer that is capable
`
`of measuring accelerations using a “Sensor Coordinate System” as described in the
`
`AndroidTM developer
`
`library. See https://developer.android.com/guide/topics
`
`/sensors/sensors_overview.html (describing “Sensor Coordinate System”).
`
`85. The Google Pixel XL includes a 3-axis gyroscope that is capable of
`
`measuring rotation rates using a “Sensor Coordinate System.”
`
`
`
`0022
`
`
`
`
`
`86. The Google Pixel XL includes a processor that is capable of
`
`processing data associated with measurement from a 3-axis accelerometer.
`
`87. The Google Pixel XL includes a processor that is capable of
`
`processing data associated with measurement from a 3-axis gyroscope.
`
`88. The AndroidTM operating system that runs on the Google Pixel XL
`
`uses the measurement from a 3-axis accelerometer included in the device.
`
`89. The AndroidTM operating system that runs on the Google Pixel XL
`
`uses the measurement from a 3-axis gyroscope included in the device.
`
`90. The AndroidTM operating system that runs on the Google Pixel XL
`
`uses the measurement from a 3-axis accelerometer and the measurement from a 3-
`
`axis gyroscope to calculate an attitude of the device.
`
`91. The Google Pixel 2 XL includes a display screen.
`
`92. The Google Pixel 2 XL includes a housing.
`
`93. The Google Pixel 2 XL includes a 3-axis accelerometer.
`
`94. The Google Pixel 2 XL includes a 3-axis gyroscope.
`
`95. The Google Pixel 2 XL includes at least one PCB.
`
`96. The Google Pixel 2 XL includes a 3-axis accelerometer attached to a
`
`97. The Google Pixel 2 XL includes a 3-axis gyroscope attached to a
`
`PCB.
`
`PCB.
`
`
`
`0023
`
`
`
`
`
`98. The Google Pixel 2 XL includes a 3-axis accelerometer that is capable
`
`of measuring accelerations.
`
`99. The Google Pixel 2 XL includes a 3-axis gyroscope that is capable of
`
`measuring rotation rates.
`
`100. The Google Pixel 2 XL runs an AndroidTM operating system.
`
`101. The Google Pixel 2 XL includes a 3-axis accelerometer that is capable
`
`of measuring accelerations using a “Sensor Coordinate System” as described in the
`
`AndroidTM developer
`
`library. See https://developer.android.com/guide/topics
`
`/sensors/sensors_overview.html (describing “Sensor Coordinate System”).
`
`102. The Google Pixel 2 XL includes a 3-axis gyroscope that is capable of
`
`measuring rotation rates using a “Sensor Coordinate System.”
`
`103. The Google Pixel 2 XL includes a processor that is capable of
`
`processing data associated with measurement from a 3-axis accelerometer.
`
`104. The Google Pixel 2 XL includes a processor that is capable of
`
`processing data associated with measurement from a 3-axis gyroscope.
`
`105. The Andr