IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLORADO
`
`REALTIME ADAPTIVE STREAMING, LLC
`
`Plaintiff,
`
`v.
`
`SLING TV L.L.C.,
`SLING MEDIA L.L.C.,
`DISH NETWORK L.L.C.,
`DISH TECHNOLOGIES L.L.C., AND
`ARRIS GROUP, INC.,
`
`Defendants.
`
`CIVIL ACTION NO. 1:17-CV-02097
`
`PATENT CASE
`JURY TRIAL DEMANDED
`
`INVALIDITY CONTENTIONS PURSUANT TO LOCAL PATENT RULES 8 AND 9 OF
`DEFENDANTS SLING TV L.L.C., SLING MEDIA L.L.C., DISH NETWORK L.L.C.,
`DISH TECHNOLOGIES L.L.C., AND ARRIS GROUP, INC.
`
`

`

`TABLE OF CONTENTS
`
`I. RESERVATIONS ................................................................................................................. 4 
`A. GENERAL RESERVATIONS .................................................................................................... 4 
`B. ONGOING DISCOVERY .......................................................................................................... 5 
`C. CLAIM CONSTRUCTION ........................................................................................................ 7 
`D. REALTIME’S INFRINGEMENT CONTENTIONS ......................................................................... 8 
`E. THE INTRINSIC RECORD ....................................................................................................... 9 
`F. REBUTTAL EVIDENCE ........................................................................................................ 10 
`G. CONTEXTUAL EVIDENCE .................................................................................................... 10 
`H.
`INVALIDITY UNDER SECTION 102(F) PRIOR ART ............................................................... 11 
`I.
`PRIORITY AND EFFECTIVE FILING DATE ............................................................................ 11 
`J. NO PATENTABLE WEIGHT .................................................................................................. 21 
`K.
`INEQUITABLE CONDUCT .................................................................................................... 21 
`II.
`IDENTIFICATION OF PRIOR ART .............................................................................. 21 
`A. PRIOR ART UNDER 35 U.S.C. § 102 THAT ANTICIPATES THE ASSERTED CLAIMS OF THE ’535
`PATENT .............................................................................................................................. 23 
`1.
`Prior Art Patents, Patent Applications, and Patent Publications .............................. 24 
`2.
`Prior Art Publications .............................................................................................. 26 
`3.
`Prior Art Systems ..................................................................................................... 27 
`B. PRIOR ART UNDER 35 U.S.C. § 102 THAT ANTICIPATES THE ASSERTED CLAIMS OF THE ’610
`PATENT .............................................................................................................................. 28 
`1.
`Prior art Patents, Patent Applications, and Patent Publications ............................... 28 
`2.
`Prior Art Publications .............................................................................................. 28 
`3.
`Prior Art Systems ..................................................................................................... 29 
`C. PRIOR ART UNDER 35 U.S.C. § 103 THAT RENDERS OBVIOUS THE ASSERTED CLAIMS OF
`THE ASSERTED PATENTS .................................................................................................... 30 
`1.
`’535 Patent Obviousness Combinations .................................................................. 30 
`2.
`’610 Patent Obviousness Combinations .................................................................. 32 
`3. Motivation for Combining Identified Prior Art ....................................................... 34 
`III. INVALIDITY UNDER 35 U.S.C. § 112 ............................................................................ 41 
`A. LACK OF ENABLEMENT AND WRITTEN DESCRIPTION UNDER 35 U.S.C. § 112 ¶ (A/1) ....... 42 
`1.
`The ’535 Patent ........................................................................................................ 44 
`2.
`The ’610 Patent ........................................................................................................ 45 
`INDEFINITENESS UNDER 35 U.S.C. § 112 ¶ (B/2) ............................................................... 46 
`1.
`The ’535 Patent ........................................................................................................ 46 
`
`B.
`
`ii
`
`

`

`The ’610 Patent ........................................................................................................ 47 
`2.
`IV. INVALIDITY DUE TO OBVIOUSNESS-TYPE DOUBLE PATENTING .................. 48 
`V.
`INVALIDITY UNDER 35 U.S.C. § 101 ............................................................................ 49 
`VI. ACCOMPANYING DOCUMENT PRODUCTION ....................................................... 50 
`A. DISH DEFENDANTS’ TECHNICAL DOCUMENT PRODUCTION ............................................. 50 
`B. ARRIS DEFENDANT’S TECHNICAL DOCUMENT PRODUCTION ........................................... 50 
`
`iii
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`

`

`Pursuant to Local Patent Rules 8 and 9 of the United States District Court for the District
`
`of Colorado (D.C.COLO.LPtR 8 and 9) and the Court’s Scheduling Order (Dkt. No. 75),
`
`Defendants Sling TV L.L.C., Sling Media L.L.C., Dish Network L.L.C., and Dish Technologies
`
`L.L.C., (“DISH”) ARRIS Group, Inc. (“ARRIS”) (collectively, “Defendants”) provide Plaintiff
`
`Realtime Adaptive Streaming, LLC (“Plaintiff” or “Realtime”) with notice of their invalidity
`
`contentions with respect to those claims that Plaintiff asserts against them in Plaintiff’s April 4,
`
`2018 Preliminary Disclosure of Asserted Claims and Infringement Contentions pursuant to
`
`D.C.COLO.LPtR 4 and 5, which are claims 1-6, 8-12, 14-17, 19, 21, 22, and 24 of U.S. Patent No.
`
`8,934,535 (“’535 Patent”) and claims 1, 2, 6, 8-14, 16, and 18 of U.S. Patent No. 8,867,610 (“’610
`
`Patent”) (collectively and respectively, “Asserted Patents” and the “Asserted Claims”).
`
`I.
`
`RESERVATIONS
`
`A.
`
`General Reservations
`
`Defendants rely on and incorporate by reference, as if originally set forth herein, all
`
`invalidity or unenforceability positions, and all associated prior art and claim charts, asserted
`
`against Realtime or Realtime Data, LLC, (“Realtime Data”) in any reexamination or inter partes
`
`review proceeding or original prosecution of the Asserted Patents, or by any present or former
`
`defendants in any of Realtime’s or Realtime Data’s lawsuits, or by potential or actual licensees to
`
`the Asserted Patents. Moreover, Defendants reserve the right, to the extent permitted by the Court
`
`and the applicable statutes and rules, to supplement these Contentions based on prior art currently
`
`known to Realtime and prior art identified or provided to Realtime or Realtime Data by any
`
`defendant or any third parties.
`
`Defendants reserve the right to amend or supplement these disclosures and the subsequent
`
`document production should Plaintiff: 1) provide any information that it failed to provide in its
`
`D.C.COLO.LPtR 4 and 5; 2) amend its D.C.COLO.LPtR 4 and 5 disclosures in any way; or 3)
`
`
`
`
`
`4
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`

`

`attempt to rely upon any information at trial, in a hearing or during a deposition which it failed to
`
`provide in its D.C.COLO.LPtR 4 and 5 disclosures.
`
`Defendants provide the information below, as well as the accompanying production of
`
`documents, for the sole purpose of complying with D.C.COLO.LPtR 8 and 9. The information
`
`provided shall not be deemed an admission regarding the scope of any claims or the proper
`
`construction of those claims or any terms contained therein. Nothing contained in these Invalidity
`
`Contentions should be understood or deemed to be an express or implied admission or contention
`
`with respect to the proper construction of any terms in the asserted claim, or with respect to the
`
`alleged infringement of that claim.
`
`B.
`
`Ongoing Discovery
`
`Moreover, because only limited discovery has occurred and because Defendants continue
`
`their search for and conduct their analysis of relevant prior art, Defendants reserve the right to
`
`revise, amend, and/or supplement the information provided herein, including identifying, charting,
`
`and relying on additional references, should Defendants’ further search and analysis yield
`
`additional information or references, consistent with the Local Patent Rules and the Federal Rules
`
`of Civil Procedure.
`
`Defendants’ Invalidity Contentions are based upon information reasonably available to it
`
`as of the date of these contentions. Because discovery is ongoing, Defendants expressly reserve
`
`the right to clarify, alter, amend, modify, or supplement these Invalidity Contentions, to identify
`
`additional prior art, and to rely on additional information, tangible things, and testimony obtained
`
`during discovery, including discovery obtained from third parties. For example, prior art not
`
`included in these contentions whether or not known to Defendants at this time, may become
`
`relevant depending on the positions Realtime asserts and the claim constructions the Court adopts.
`
`
`
`
`
`5
`
`

`

`Discovery is in its infancy and is ongoing, and Defendants’ prior art investigation and third-
`
`party discovery is therefore not yet complete. Defendants reserve the right to present additional
`
`items of prior art under 35 U.S.C. §§ 102(a), (b), (e), and/or (g), and/or 103 located during the
`
`course of discovery or further investigation. For example, Defendants may issue subpoenas to
`
`third parties believed to have knowledge, documentation, and/or corroborating evidence
`
`concerning some of the prior art listed herein and/or additional prior art. These third parties include
`
`without limitation the authors, inventors, or assignees of the references listed in these disclosures.
`
`For example, for any given company’s commercial products, Defendants anticipate that additional
`
`documentation relating to these products will be discovered, and Defendants reserve the right to
`
`rely on such documentation to further support these Invalidity Contentions. In addition,
`
`Defendants reserve the right to assert invalidity under 35 U.S.C. § 102(c), (d), or (f) to the extent
`
`that discovery or further investigation yield information forming the basis for such invalidity.
`
`Similarly, Defendants have not had the opportunity to take any depositions of the patent
`
`applicants named on the face the Asserted Patents or other persons having relevant information.
`
`Defendants reserve the right to revise, amend or supplement these contentions pursuant to Federal
`
`Rule of Civil Procedure 26(e) and the Local Rules to the extent appropriate in light of further
`
`investigation and discovery regarding the defenses, the review and analysis of expert witnesses, or
`
`supplemental contentions by Realtime.
`
`Defendants accordingly reserve the right to modify these Invalidity Contentions by adding
`
`or withdrawing prior art and/or modifying any of the referenced claim charts in light of the Court’s
`
`claim construction ruling, any amended or supplemental infringement contentions by Realtime,
`
`any party admissions or admissions by any named inventor concerning the scope of the claims or
`
`teachings of the prior art, or any positions taken by Realtime in this or related litigation,
`
`
`
`
`
`6
`
`

`

`reexamination, inter partes review, or other proceeding, or to avoid unfair prejudice from
`
`Realtime’s failure to timely comply with its disclosure obligations. Furthermore, additional
`
`obviousness combinations of the references identified in these disclosures are possible, and
`
`Defendants reserve the right to use any such combination(s) in these actions. In particular,
`
`Defendants are currently unaware of the extent, if any, to which Realtime will contend that
`
`limitations of the claims at issue are not disclosed in the art identified by Defendants as
`
`anticipatory, and the extent to which Realtime will contend that elements not disclosed in the
`
`specifications of the Asserted Patents and related applications would have been known to persons
`
`of ordinary skill in the art at the relevant time. To the extent that an issue arises with any such
`
`limitations, Defendants reserve the right to identify other references that would have made such
`
`limitations obvious in view of the relevant disclosures.
`
`C.
`
`Claim Construction
`
`Defendants reserve the right to revise their ultimate contentions concerning the invalidity
`
`of the Asserted Claims, which may change depending upon any findings as to the priority date of
`
`those claims and/or positions that Realtime or expert witness(es) may take concerning
`
`infringement and/or invalidity issues. Defendants do not waive the right to contest any claim
`
`constructions or to take positions during claim construction proceedings that have yet to occur that
`
`may be inconsistent with the invalidity contentions herein. Consequently, Defendants also reserve
`
`the right to amend or supplement these Invalidity Contentions in the event that the claims are
`
`construed differently at some point in the future, in accordance with D.C.COLO.LPtR 16.
`
`
`
`Defendants do not adopt Realtime’s positions on the scope or construction of the claims.
`
`In certain instances, however, Defendants have applied the claims to the prior art in view of
`
`Realtime’s allegations, admissions, or positions for purposes of these contentions only. As such,
`
`Defendants’ Invalidity Contentions are not adoptions or admissions by Defendants as to the
`
`
`
`
`
`7
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`

`

`accuracy of Realtime’s allegations, admissions, or positions. Accordingly, these contentions are
`
`made in the alternative, are not necessarily intended to be consistent with each other or with other
`
`contentions, and should not be otherwise construed.
`
`Defendants expressly reserve the right to take positions with respect to future claim
`
`construction or infringement issues that are inconsistent with, or even contradictory to, the claim
`
`construction or infringement positions expressed or implied in the Invalidity Contentions set forth
`
`herein.
`
`D.
`
`Realtime’s Infringement Contentions
`
`Realtime’s disclosures under D.C.COLO.LPtR 4 and 5 are deficient in numerous respects.
`
`For example, Realtime has repeatedly failed to specifically identify where each limitation of each
`
`claim is found within each Accused Instrumentality as required by D.C.COLO.LPtR 4(b)(2) and
`
`has taken either unintelligible or contradictory positions regarding how the Accused
`
`Instrumentalities allegedly practice the Asserted Claims. Realtime’s failure to comply with
`
`D.C.COLO.LPtR 4 has prejudiced Defendants’ ability to prepare these Invalidity Contentions by
`
`forcing them to speculate as to Realtime’s actual position on Defendants’ alleged infringement.
`
`Therefore, these Invalidity Contentions are based in whole or in part on the present understanding
`
`of the Asserted Claims and Realtime’s apparent positions as to the scope of the Asserted Claims
`
`as applied in its D.C.COLO.LPtR 4 disclosures. Defendants further reserve the right to modify or
`
`add additional contentions in light of Realtime’s failure to provide infringement contentions that
`
`comply with the level of disclosure required by the Local Patent Rules. Defendants specifically
`
`reserve the right to modify, amend, or supplement their contentions as Realtime modifies, amends,
`
`or supplements its disclosures under the Local Patent Rules and/or produces documents in
`
`discovery.
`
`
`
`
`
`8
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`

`

`Additionally, Realtime has presented no substantive contentions for indirect infringement,
`
`i.e., active inducement or contributory infringement. Realtime has not, for example, provided
`
`detailed contentions that identify how Defendants allegedly induce direct infringement of the
`
`Asserted Patents by a third party, or how Defendants allegedly contribute to the infringement of
`
`the Asserted Patents by a third party.1 Nor has Realtime provided detailed contentions regarding
`
`any alleged infringement by multiple parties pursuant to 35 U.S.C. § 271(a) (i.e., joint
`
`infringement). Nor has Realtime provided detailed contentions of any alleged infringement under
`
`the doctrine of equivalents. If Realtime is permitted to provide this and other information relating
`
`to alleged indirect or joint infringement or infringement pursuant to the doctrine of equivalents,
`
`Defendants will amend and supplement these Invalidity Contentions as appropriate.
`
`E.
`
`The Intrinsic Record
`
`Defendants further reserve the right to rely upon applicable industry standards and prior
`
`art cited in the specifications and file histories of the Asserted Patents, and any related U.S. and
`
`foreign patent applications as invalidating references or to show the state of the art. Defendants
`
`further reserve the right to rely on the patent applicants’ admissions concerning the scope of the
`
`prior art relevant to the asserted patents found in, inter alia: the specifications; the patent
`
`prosecution history for the asserted patent and any related patents and/or patent applications or
`
`reexaminations; any deposition testimony of the named patent applicants on the asserted patent;
`
`and the papers filed and any evidence submitted by Realtime in connection with this litigation.
`
`
`
`
`
`
` 1
`
` Realtime’s D.C.COLO.LPtR 4 Disclosures also allege indirect infringement by DISH, but these
`contentions are not supported by the allegations in Realtime’s Second Amended Complaint (Dkt.
`No. 32).
`
`
`
`
`
`9
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`

`

`F.
`
`Rebuttal Evidence
`
`Prior art not included in these Invalidity Contentions, whether known or not known to
`
`Defendants, may become relevant. In particular, Defendants are currently unaware of the extent,
`
`if any, to which Realtime will contend that limitations of the asserted claims of the Asserted Patents
`
`are not disclosed in the prior art identified herein. To the extent that such an issue arises,
`
`Defendants reserve the right to identify other references that would render obvious the allegedly
`
`missing limitation(s) or the disclosed device or method.
`
`G.
`
`Contextual Evidence
`
`Defendants’ claim charts cite particular teachings and disclosures of the prior art as applied
`
`to the limitation of each of the asserted claims. However, persons having ordinary skill in the art
`
`generally may view an item of prior art in the context of his or her experience and training, other
`
`publications, literature, products, and understanding. As such, the cited portions are only
`
`exemplary, and Defendants reserve the right to rely on uncited portions of the prior art references
`
`and on other publications and expert testimony as aids in understanding and interpreting the cited
`
`portions, as providing context thereto, and as additional evidence that the prior art discloses a claim
`
`limitation or the claimed subject matter as a whole. Defendants further reserve the right to rely on
`
`uncited portions of the prior art references, other publications, and testimony, including expert
`
`testimony, to establish bases for combinations of certain cited references that render the asserted
`
`claims obvious. The references discussed in the claim charts may disclose the elements of the
`
`asserted claims explicitly and/or inherently, and/or they may be relied upon to show the state of
`
`the art in the relevant time frame. The suggested obviousness combinations are provided in the
`
`alternative to anticipation contentions and are not to be construed to suggest that any reference
`
`included in the combinations is not by itself anticipatory.
`
`
`
`
`
`
`
`10
`
`

`

`H.
`
`Invalidity Under Section 102(f) Prior Art
`
`Defendants reserve the right to assert that the asserted claims of the Asserted Patents are
`
`invalid under 35 U.S.C. § 102(f) in the event Defendants obtain evidence that James J. Fallon
`
`and/or Steven J. McErlain, the applicants named on the Asserted Patents, did not themselves
`
`“invent” the subject matter claimed. Should Defendants obtain such evidence, it will provide the
`
`name of the person(s) from whom and the circumstances under which the claimed subject matter
`
`or any part of it was derived.
`
`I.
`
`Priority and Effective Filing Date
`
`Realtime has failed to identify with particularity any alleged priority date for ’535 or ’610
`
`Patents. These contentions are based on the alleged priority date of February 13, 2001 as
`
`represented by Realtime on the face of the ’535 and ’610 Patents. With respect to the Asserted
`
`Patents, Defendants contend that Realtime will be unable to demonstrate that the Asserted Claims
`
`are entitled to claim a priority date or effective filing date earlier than the actual filing date of the
`
`applications that issued as those patents. No ancestor application provides a disclosure sufficient
`
`under 35 U.S.C. § 112 to support such claim as required by section 119(e) or 120. See Section III
`
`below.
`
`Realtime’s priority claims are also defective for having included and claimed subject
`
`matter which is not adequately supported by a pre-AIA application filing. These defects may
`
`preclude Realtime from establishing priority to the original application, as claimed. If Realtime
`
`cannot establish a priority date of all of the claims of the Asserted Patents before the actual filing
`
`date, then its Asserted Claims are governed by the first-to-file provisions of the AIA. Should it be
`
`the case that the ’535 and ’610 Patents are not entitled to the priority claims made by these patents,
`
`then Defendants assert in the alternative that some or all of the accused products Realtime has
`
`identified as infringing under its improper infringement interpretation of one or both of the ’535
`
`
`
`
`
`11
`
`

`

`and ’610 Patents and/or some or all of the functionalities contained, referenced, or otherwise
`
`included in the accused products may serve as prior art to the extent that they predate the filing
`
`dates of the ’535 and ’610 Patents. The actions and associated products accused by Realtime are
`
`listed in the table below. Likewise, asserted in the alternative if the patents are not entitled to their
`
`listed priority claims, the listed patents, applications, and application publications within the
`
`alleged chain of priority for each of the ’535 and ’610 Patents may serve (or as a matter of law,
`
`serve) as invalidating prior art for anticipation and/or obviousness under 35 U.S.C. §§ 102 and/or
`
`103, to the extent those patents, applications, or application publications provide an enabling
`
`disclosure of and/or written description support for the claims of the ’535 and ’610 Patents as is
`
`apparently Realtime’s position through averments made to the patent office during prosecution of
`
`the ’535 and ’610 Patents. Finally, if the patents are not entitled to their listed priority claims,
`
`Defendants reserve the right to revise, amend, and/or supplement the information provided herein,
`
`including identifying, charting, and relying on additional references consistent with the Local
`
`Patent Rules and the Federal Rules of Civil Procedure.
`
`Action
`Realtime v. Sling TV,
`L.L.C., Sling Media,
`L.L.C., Dish
`Technologies, L.L.C.,
`Dish Network L.L.C.,
`and Arris Group,
`
`Accused Products2
`Sling’s and Dish Network’s products and services that perform
`compression (H.264), such as, e.g., Sling TV App “A LA CARTE
`TV”, Sling Orange, Sling Blue TV, Orange + Sling Blue services,
`Slingbox set-top boxes including, but not limited to, e.g., Slingbox 500,
`Slingbox M2, Slingbox M1, Slingbox 350, Slingbox 700u, Slingbox
`PRO-HD, Slingbox SOLO, Sling Adapter, Hooper3, Hopper with
`
`
`
`
` 2
`
` Many of the accused products rely on the H.264 standard, otherwise known as MPEG-4 Part 10,
`Advanced Video Coding (“MPEG-4 AVC”). H.264 is a block-oriented motion-compensation-
`based video compression standard that was developed by the ITU-T Video Coding Experts Group
`(“VCEG”) together with the ISO/IEC JTC1 Moving Picture Experts Group (“MPEG”). The final
`drafting work on the first version of the H.264 standard was completed in May 2003, which
`predates the filing dates of the Asserted Patents. The May 2003 draft of the H.264 standard is
`available here: https://www.itu.int/rec/T-REC-H.264-200305-S/en.
`
`
`
`
`
`12
`
`

`

`Action
`Inc., 17-cv-02097 (D.
`Colo.)
`
`Realtime v. Polycom,
`Inc., 17-cv-02692 (D.
`Colo.)
`
`Accused Products2
`Sling, HopperGO, DISH Anywhere app, 4K Joey, Wired Joey,
`Wireless Joey, Super Joey, ViP 722, ViP 722k, DISH TV services,
`SlingStudio CameraLink, SlingStudio Hub, SlingStudio Capture app,
`and all versions and variations thereof.
`Polycom RealPresence Experience High Definition (RPX HD 200 &
`400 Series) including the Polycom RPX HD 204M, RPX HD 208M,
`RPX HD 210M, RPX HD 218M, RPX HD 408M, RPX HD 418M,
`RPX HD 428M; the Polycom HDX Series including the Polycom HDX
`9000, Polycom HDX 8000, Polycom HDX 7000, Polycom HDX 6000,
`Polycom HDX 4000, Polycom HDX 4500, Polycom HDX 4002,
`Polycom HDX 4001, Polycom HDX Packaged Solutions, Polycom
`HDX Executive Collection, Polycom HDX Media Center, Polycom
`EagleEye Director, Polycom Eagle Eye IV, Polycom Touch Control
`interface, Polycom VisualBoard Technology; the Polycom Open
`Telepresence Experience (OTX) including the Polycom OTX 100 and
`Polycom OTX 300; the Polycom RealPresence Series including the
`Polycom RealPresence Desktop, Polycom RealPresence Mobile for
`Android, Polycom RealPresence Medialign, Polycom RealPresence
`Immersive Studio, Polycom RealPresence Immersive Studio Flex,
`Polycom RealPresence Clarity, Polycom RealPresence Group 310,
`Polycom RealPresence Group 500, Polycom RealPresence Group 700;
`the Polycom RMX Media Platforms including the Polycom RMX v7.0
`with MPMx modules, Polycom RMX 1000 platform, Polycom RMX
`1500 platform, Polycom RMX 2000 platform and Polycom RMX 4000
`platform; the Polycom ATX Series including the Polycom ATX 300;
`the Polycom TPX Series including the Polycom TPX HD 306M (3-
`screens); the Polycom QDX Series including the Polycom QDX 6000;
`the Polycom CX Series including the Polycom CX5000 and Polycom
`CX7000; the Polycom VVX Series including the Polycom VVX
`1500D; the Polycom load balancers e.g. the Polycom DMA 7000; the
`Polycom desktop video infrastructure or servers e.g. the Polycom
`CMA 4000 and Polycom CMA 5000; the Polycom firewall traversal
`infrastructure including the Polycom VBP ST and E models including
`the Polycom VBP 200 E, Polycom VBP 200EW, Polycom VBP 4300
`Series (including the Polycom VBP 4350E and Polycom VBP 4350E-
`3), the Polycom 5300 Series (including the Polycom 5300E, Polycom
`5300ST, Polycom VBP T5300-E10, Polycom VBP T3500-E25,
`Polycom VBP T5300-ST10 and Polycom VBP T5300-ST25), the
`Polycom 6400 Series (including the Polycom 6400E, Polycom
`6400ST, Polycom VBP 6400-E85 and Polycom VBP 6400-ST85); and
`other Polycom infrastructure e.g. the Polycom RSS 2000 and Polycom
`RSS 4000, the Polycom VVX Business Media Phones and the
`Polycom VVX Camera, the Polycom Trio Family of conference
`
`
`
`
`
`13
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`

`

`Action
`
`Realtime v. Apple
`Inc., 17-cv-02869
`(D. Colo.)
`Realtime v. Amazon.
`com, Inc. et al, 17-
`cv-00549 (E.D.
`Tex..)
`Realtime v. Cisco
`Systems, Inc., 17-cv-
`00591 (E.D. Tex.)
`
`Accused Products2
`phones including the Polycom Trio 8500 and Polycom Trio 8800, and
`all versions and variations thereof.
`Apple’s streaming products/services (e.g., Apple’s Internet Services),
`such as, e.g., iTunes Store, Apple Music, and all versions and
`variations thereof.
`Amazon’s streaming products/services, such as, e.g., Amazon Video,
`and all versions and variations thereof.
`
`Cisco’s streaming and web conferencing products/services, such as,
`e.g., Cisco WebEx products including Cisco Meeting Center and Cisco
`WebEx Event Center, as well as Cisco Video Surveillance IP Camera
`products including the Cisco Video Surveillance 3520 IP Camera; the
`Cisco Video Surveillance 3535 IP Camera; the Cisco Video
`Surveillance 3620 IP Camera; the Cisco Video Surveillance 3630 IP
`Camera; the Cisco Video Surveillance 6020 IP Camera; the Cisco
`Video Surveillance 6030 IP Camera; the Cisco Video Surveillance
`6620 IP Camera; the Cisco Video Surveillance 6630 IP Camera; the
`Cisco Video Surveillance 7030E IP Camera; the Cisco Video
`Surveillance 7530PD IP Camera; the Cisco Video Surveillance 6000
`Series IP Cameras including the Cisco Video Surveillance 6000P IP
`Camera, the Cisco Video Surveillance 6400E IP Camera, and the Cisco
`Video Surveillance 6500PD IP Camera; the Cisco Video Surveillance
`3050 IP Camera; the Cisco Video Surveillance 7070 IP Camera; Cisco
`Video Surveillance 2800 Series Standard Definition PTZ IP Cameras
`(also known as the Cisco Video Surveillance 2800 Series IP Cameras)
`including the Cisco Video Surveillance 2830 IP Camera and the Cisco
`Video Surveillance 2835 IP Camera; Cisco Video Surveillance 6900
`Series High Definition PTZ IP Cameras (also known as the Cisco
`Video Surveillance 6900 Series IP Cameras) including the Cisco Video
`Surveillance 6930 IP Camera; the Cisco Video Surveillance 8-Port
`Encoder; the Cisco Video Surveillance 4-Port Encoder; Cisco Meraki
`MV Security Cameras including the Cisco Meraki MV21 Security
`Camera and the Cisco Meraki MV71 Security Camera; the Cisco
`Video Surveillance Manager software platform including the Cisco
`Connected Safety and Security Unified Computer System (UCS)
`platform including Cisco Connected Safety and Security UCS M4,
`C220, C240, B-Series, C-Series, E-Series, Express, the Cisco Physical
`Security Multiservices Platform (MSP) for Video Surveillance, Cisco
`Video Surveillance Manager (VSM) 7, including the Cisco VSM for
`Cisco UCS B and C Series Servers, the Cisco VSM for Cisco UCS E-
`Series Servers, the Cisco VSM for Cisco UCS Express, the Cisco
`Video Surveillance Operations Manager, the Cisco Video Surveillance
`
`
`
`
`
`14
`
`

`

`Action
`
`Realtime v. Samsung
`Electronics Co. Ltd.
`and Samsung
`Electronics America,
`Inc., 18-cv-00113
`(E.D. Tex.)
`
`Accused Products2
`Media Server, the Cisco Video Surveillance Safety and Security
`Desktop, and the Cisco Video Surveillance Manager Express; the
`Cisco Video Analytics software including the Cisco Base Video
`Analytics Package (further including the Security Base package or
`Security Package and the Counting Base package), the Cisco Advanced
`Video Analytics Package (further including the Counting Advanced
`package), the Cisco Flow Violation Analysis Package and the Cisco
`Crowd Monitoring Analytic Package, Cisco Telepresence Peripherals
`including the Cisco TelePresence ISDN Link, the Cisco TelePresence
`SpeakerTrack 60 Camera, the Cisco TelePresence Precision 60
`Camera, the Cisco TelePresence Precision 40 Camera, the Cisco
`TelePresence Precision 12X Camera and the Cisco TelePresence
`Touch devices, and all versions and variations thereof.
`Samsung UHD TV models including, e.g., Samsung 65" Class
`MU8000 4K UHD TV (UN65MU8000FXZA), 55" Class The Frame
`4K UHD TV (UN55LS003AFXZA), 55" Class MU6290 4K UHD TV
`(UN55MU6290FXZA), 55" Class MU7500 Curved 4K UHD TV
`(UN55MU7500FXZA), 55" Class MU7000 4K UHD TV
`(UN55MU7000FXZA), 55" Class MU6500 Curved 4K UHD TV
`(UN55MU6500FXZA), 55" Class MU6490 Curved 4K UHD TV
`(UN55MU6490FXZA), 55" Class MU6300 4K UHD TV
`(UN55MU6300FXZA), 55" Class MU6290 4K UHD TV
`(UN55MU6290FXZA), 58" Class MU6100 4K UHD TV
`(UN58MU6100FXZA); Samsung QLED TV models, including, e.g.,
`Samsung 55" Class Q7F QLED 4K TV (QN55Q7FAMFXZA), 55"
`Class Q7C Curved QLED 4K TV (QN55Q7CAMFXZA), 55" Class
`Q8C Curved QLED 4K TV (QN55Q8CAMFXZA), 65" Class Q9F
`QLED 4K TV (QN65Q9FAMFXZA), 55" Class Q6F Special Edition
`QLED 4K TV (QN55Q6FAMFXZA); Samsung EXYNOS Application
`Processors, including, e.g., Samsung Exynos 3 Dual (3250), Exynos 5
`Hexa (5260), Exynos 5 Octa (5422), Exynos 9 Series (9810), Exynos 9
`Series (8895), Exynos 8 Octa (8890), Exnynos 7 Series (7885), Exynos
`7 Series (7880), Exynos 5 Series (7872), Exynos 7 Octa (7420),
`Exynos 7 Octa (7870), Exynos 7 Octa (7580), Exynos 7 Quad (7570),
`Exynos 7 Dual (7270), Exynos 7 Octa (5433), Exynos 5 Octa (5430),
`Exynos 5 Octa (5422), Exynos 5 Octa (5420), Exynos 5 Octa (5410),
`Exynos 5 Hexa (5260), Exynos 5 Dual (5250), Exynos 4 Quad (4412),
`Exynos 4 Dual (4212), Exynos 4 Dual (4210), Exynos 3 Quad (3470),
`Exynos 3 Single (3110); Samsung Gear Watches including, e.g.,
`Samsung Gear S, Gear S2, Gear S3, Gear 2, Gear Fit, Gear Fit 2, Gear
`Fit 2 Pro,