U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Infringement Contentions
`
`As shown in the exemplar, representative images below, the ADAT air controller reads on this claim
`limitation because it has an improved valve enclosure assembly for use with an air inflatable mattress
`having at least one air bladder inflated by compressed air, a pump fluidly coupled to the at least one air
`bladder for providing compressed air thereto, and a processor for providing commands to the improved
`valve enclosure assembly during an inflate/deflate cycle, the improved valve enclosure assembly being
`fluidly coupled intermediate the pump and the at least one air bladder for controlling the inflation of the
`at least one air bladder:
`
`Claim Element
`
`Claim 12
`[12.P] An improved valve enclosure
`assembly for use with an air inflatable
`mattress having at least one air bladder
`inflated by compressed air, a pump
`fluidly coupled to the at least one air
`bladder for providing compressed air
`thereto, and a processor for providing
`commands to the improved valve
`enclosure assembly during an
`inflate/deflate cycle, the improved valve
`enclosure assembly being fluidly
`coupled intermediate the pump and the
`at least one air bladder for controlling
`the inflation of the at least one air
`bladder, comprising:
`
`1
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 1
`
`
`
`Infringement Contentions
`
`As shown in the exemplar, representative images below, the ADAT air controller reads on this claim
`limitation because it has an improved valve enclosure assembly for use with an air inflatable mattress
`having at least one air bladder inflated by compressed air, a pump fluidly coupled to the at least one air
`bladder for providing compressed air thereto, and a processor for providing commands to the improved
`valve enclosure assembly during an inflate/deflate cycle, the improved valve enclosure assembly being
`fluidly coupled intermediate the pump and the at least one air bladder for controlling the inflation of the
`at least one air bladder:
`
`Claim Element
`
`Claim 12
`[12.P] An improved valve enclosure
`assembly for use with an air inflatable
`mattress having at least one air bladder
`inflated by compressed air, a pump
`fluidly coupled to the at least one air
`bladder for providing compressed air
`thereto, and a processor for providing
`commands to the improved valve
`enclosure assembly during an
`inflate/deflate cycle, the improved valve
`enclosure assembly being fluidly
`coupled intermediate the pump and the
`at least one air bladder for controlling
`the inflation of the at least one air
`bladder, comprising:
`
`1
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 1
`
`
`
`U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Claim Element
`
`[12.1] an enclosure defining a
`substantially fluidly sealed air chamber
`and having at least one air inlet to the
`air chamber being fluidly coupled to the
`pump, a plurality of guides and stops
`being disposed within the enclosure for
`correctly positioning components within
`the enclosure;
`
`Infringement Contentions
`
`As shown in the exemplar, representative images below, the ADAT air controller reads on this claim
`limitation because it has an enclosure defining a substantially fluidly sealed air chamber and having at
`least one air inlet to the air chamber being fluidly coupled to the pump, a plurality of guides and stops
`being disposed within the enclosure for correctly positioning components within the enclosure:
`
`Air inlet from pump
`into air chamber of
`enclosure
`
`Enclosure
`
`2
`
`v
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 2
`
`
`
`U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Claim Element
`
`Infringement Contentions
`
`Guides and Stops
`
`Air chamber
`
`3
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 3
`
`
`
`U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Claim Element
`
`[12.2] at least one valve operably
`coupled to the enclosure being in
`selective fluid communication with the
`air chamber and being in fluid
`communication with the at least one air
`bladder for selectively fluidly coupling
`the air chamber to at least one air
`bladder; and
`
`Infringement Contentions
`
`As shown in the exemplar, representative image below, the ADAT air controller reads on this claim
`limitation because it has at least one valve operably coupled to the enclosure being in selective fluid
`communication with the air chamber and being in fluid communication with the at least one air bladder
`for selectively fluidly coupling the air chamber to at least one air bladder:
`
`Tubing to Air
`Bladder
`
`Air chamber of
`Enclosure
`
`Valve
`
`4
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 4
`
`
`
`U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Claim Element
`
`[12.3] pressure monitor means being
`operably coupled to the processor and
`being in fluid communication with the
`at least one valve for monitoring the
`pressure in the at least one bladder.
`
`Infringement Contentions
`
`As shown in the exemplar, representative images below, the ADAT air controller reads on this claim
`limitation because it has pressure monitor means being operably coupled to the processor and being in
`fluid communication with the at least one valve for monitoring the pressure in the at least one bladder:
`
`Pressure
`Monitor
`Means
`
`5
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 5
`
`
`
`U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Claim Element
`
`Infringement Contentions
`
`Pressure Monitor
`Means
`
`6
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 6
`
`
`
`U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Infringement Contentions
`
`As shown in the exemplar, representative images below, the ADAT air controller reads on this claim
`limitation because it has an improved valve enclosure assembly for use with an air inflatable mattress
`having at least one air bladder inflated by compressed air, a pump fluidly coupled to the at least one air
`bladder for providing compressed air thereto, and a processor for providing commands to the improved
`valve enclosure assembly during an inflate/deflate cycle, the improved valve enclosure assembly being
`fluidly coupled intermediate the pump and the at least one air bladder for controlling the inflation of the
`at least one air bladder:
`
`Claim Element
`
`Claim 16
`[16.P] An improved valve enclosure
`assembly for use with an air inflatable
`mattress having at least one air bladder
`inflated by compressed air, a pump
`fluidly coupled to the at least one air
`bladder for providing compressed air
`thereto, and a processor for providing
`commands to the improved valve
`enclosure assembly during an
`inflate/deflate cycle, the improved valve
`enclosure assembly being fluidly
`coupled intermediate the pump and the
`at least one air bladder for controlling
`the inflation of the at least one air
`bladder, comprising:
`
`7
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 7
`
`
`
`U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Claim Element
`
`Infringement Contentions
`
`[16.1] an enclosure defining a
`substantially fluidly sealed air chamber
`and having at least one air inlet to the
`air chamber being fluidly coupled to the
`pump, the enclosure being formed of an
`enclosure portion and a rear cover
`portion, a flexible seal being
`compressively interposed between the
`enclosure portion and a rear cover
`portion to effect a substantially fluid
`tight seal therebetween;
`
`As shown in the exemplar, representative images below, the ADAT air controller reads on this claim
`limitation because it has an enclosure defining a substantially fluidly sealed air chamber and having at
`least one air inlet to the air chamber being fluidly coupled to the pump, the enclosure being formed of an
`enclosure portion and a rear cover portion, a flexible seal being compressively interposed between the
`enclosure portion and a rear cover portion to effect a substantially fluid tight seal therebetween:
`:
`
`Air inlet from pump
`into air chamber of
`enclosure
`
`Enclosure
`
`8
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 8
`
`
`
`U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Claim Element
`
`Infringement Contentions
`
`9
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 9
`
`
`
`U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Claim Element
`
`[16.2] at least one valve operably
`coupled to the enclosure being in
`selective fluid communication with the
`air chamber and being in fluid
`communication with the at least one air
`bladder for selectively fluidly coupling
`the air chamber to at least one air
`bladder; and
`
`Infringement Contentions
`
`As shown in the exemplar, representative image below, the ADAT air controller reads on this claim
`limitation because it has at least one valve operably coupled to the enclosure being in selective fluid
`communication with the air chamber and being in fluid communication with the at least one air bladder
`for selectively fluidly coupling the air chamber to at least one air bladder:
`
`Tubing to Air
`Bladder
`
`Air chamber of
`Enclosure
`
`Valve
`
`10
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 10
`
`
`
`U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Claim Element
`
`[16.3] pressure monitor means being
`operably coupled to the processor and
`being in fluid communication with the
`at least one valve for monitoring the
`pressure in the at least one bladder.
`
`Infringement Contentions
`
`As shown in the exemplar, representative images below, the ADAT air controller reads on this claim
`limitation because it has pressure monitor means being operably coupled to the processor and being in
`fluid communication with the at least one valve for monitoring the pressure in the at least one bladder:
`
`Pressure
`Monitor
`Means
`
`11
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 11
`
`
`
`U.S. PATENT NO. 5,904,172 VERSUS SLEEP NUMBER’S ADAT AIR CONTROLLER
`
`Claim Element
`
`Infringement Contentions
`
`Pressure Monitor
`Means
`
`12
`
`Sleep Number Corp.
`EXHIBIT 2028
`IPR2019-00500
`Page 12
`
`
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