EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`Pursuant to P.R. 3-1(c) and the Joint Stipulation Regarding Amending Infringement and Invalidity Contention (-356 case, Dkt. 138; -357
`case, Dkt. 137), Plaintiff provides the chart below identifying specifically where each element of each asserted claim of the ’154 Patent is found
`within Defendant’s exemplary consumer air mattress system product, a Gen 3 Arco air controller with a model S9 bed or representation thereof.
`Specifically, Plaintiff provides the following supplementation, which includes prior disclosures and supplementations provided to Defendants on
`September 7, November 16, and November 26, 2018; (2) adds to and/or clarifies contentions, where appropriate; and (3) adds variable names, written
`descriptions/summaries of Plaintiff’s infringement position in light of the identified variables, and narrowed line number ranges where
`able/appropriate. These disclosures incorporate by reference the Representative Product Chart, served herewith. Further, these disclosures are made
`in light of foreseeable claim construction positions, are not to be construed as an acceptance or endorsement of any particular construction, and may
`be amended pursuant to P.R. 3-6(a)(1). Plaintiff reserves the right to amend this chart after Defendant meaningfully responds to discovery requests by
`making a fulsome document production, including by producing documents that disclose all of Defendant’s products and by providing all of
`Defendants’ products for inspection. Plaintiff further reserves the right to amend this chart after Defendant allows for a sufficient inspection of all
`relevant Source Code, pursuant to a stipulations between the parties.
`
`CLAIM LANGUAGE
`
`(1pre) A method for
`adjusting pressure within
`an air bed including an air
`chamber and a pump
`having a pump housing
`comprising:
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices a
`method of adjusting pressure within an air bed including an air chamber and a pump having a pump housing.
`
`For example, ANM air bed includes a controller for adjusting pressure.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`
`ANM air bed includes an air chamber and a pump having a pump housing.
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Air Controller
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`3
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Pump
`
`Pump Housing
`
`(Photograph of Gen 3 Arco Air Controller)
`
`
`
`In addition, ANM website sends the user to “Instant Comfort” for consumer sleep systems.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`All of the AMN air beds include a Pump & Control System. For example, the S9 mattress includes a Pump & Control
`System.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`5
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`The S9 assembly instructions also show how the control system connects to the air bed.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`6
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`See, e.g., American National Manufacturing, http://www.americannationalmfg.com/index.html# (last visited August
`21, 2018).
`
`See, e.g., Instant Comfort, http://www.instantcomfort.com/ (last visited August 21, 2018).
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`7
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`See, e.g., S9, http://www.instantcomfort.com/s9.html (last visited August 21, 2018).
`
`See, e.g., S9 Assembly Instructions,
`http://www.instantcomfort.com/uploads/8/0/0/1/80015572/b.q9s9assemblyinstructions.pdf (last visited August 21,
`2018).
`
`Further, this limitation implicates the electronics, software, firmware, and/or source code of the Accused Products.
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate how this claim limitation is met.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`8
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`This limitation may further implicate the electronics, software, firmware, and/or source code of the Accused Products.
`Source Code for the Accused Products may further show how this claim limitation is met. To resolve a dispute
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`9
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`regarding Plaintiff’s Notice of Inspection for Source Code, the parties have agreed that Plaintiff shall be allowed to
`inspect remaining Source Code for the Accused Products on mutually agreeable date(s), after which Plaintiff shall
`supplement its infringement contentions, pursuant to an agreed-upon timeline and without opposition, using the
`information learned during the inspection.
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the
`method of receiving a selection for a desired pressure setpoint for the air chamber.
`
`(1a) receiving a selection
`for a desired pressure
`setpoint for the air
`chamber
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`For example, the hand control receives a user selection of the desired pressure when the user presses up/down on the
`hand control. Furthermore, the user input creates a signal that is received by the one or more processors in
`conjunction with the source code.
`
`The S9 assembly Instructions step 9 also shows selecting the desired pressure by pressing up/down on the controller.
`Additionally, one or more processors in conjunction with the source code will receive a selection for a desired pressure
`setpoint for the air chamber.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`11
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`12
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`See, e.g., S9 Assembly Instructions,
`http://www.instantcomfort.com/uploads/8/0/0/1/80015572/b.q9s9assemblyinstructions.pdf (last visited August 21,
`2018).
`
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate how the Accused Products receive a selection
`for a desired pressure setpoint for the air chamber.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`13
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`14
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`15
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`
`This limitation may further implicate the electronics, software, firmware, and/or source code of the Accused Products.
`Source Code for the Accused Products may further show how this claim limitation is met. To resolve a dispute
`regarding Plaintiff’s Notice of Inspection for Source Code, the parties have agreed that Plaintiff shall be allowed to
`inspect remaining Source Code for the Accused Products on mutually agreeable date(s), after which Plaintiff shall
`supplement its infringement contentions, pursuant to an agreed-upon timeline and without opposition, using the
`information learned during the inspection.
`
`(1b) calculating a
`pressure target for the
`pump housing, wherein
`the pressure target for the
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the
`method of calculating a pressure target for the pump housing, wherein the pressure target for the pump housing is
`calculated based upon the desired pressure setpoint for the air chamber and a pressure adjustment factor.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`16
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`pump housing is
`calculated based upon the
`desired pressure setpoint
`for the air chamber and a
`pressure adjustment factor
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`For example, one or more processors in conjunction with the source code calculating a pressure target for the pump
`housing. The one or more processors in conjunction with the source code may calculate a pressure target, wherein the
`pressure target for the pump housing is based upon the desired pressure setpoint for the air chamber and a pressure
`adjustment factor.
`
`See, e.g., S9, http://www.instantcomfort.com/s9.html (last visited August 21, 2018).
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`17
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`See, e.g., S9 Assembly Instructions,
`http://www.instantcomfort.com/uploads/8/0/0/1/80015572/b.q9s9assemblyinstructions.pdf (last visited August 21,
`2018).
`
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate how the Accused Products calculate a pressure
`target for the pump housing, wherein the pressure target for the pump housing is calculated based upon the desired
`pressure setpoint for the air chamber and a pressure adjustment factor.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`18
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`19
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`
`This limitation may further implicate the electronics, software, firmware, and/or source code of the Accused Products.
`Source Code for the Accused Products may further show how this claim limitation is met. To resolve a dispute
`regarding Plaintiff’s Notice of Inspection for Source Code, the parties have agreed that Plaintiff shall be allowed to
`inspect remaining Source Code for the Accused Products on mutually agreeable date(s), after which Plaintiff shall
`supplement its infringement contentions, pursuant to an agreed-upon timeline and without opposition, using the
`information learned during the inspection.
`
`(1c) adjusting pressure
`within the air chamber
`until a pressure sensed
`within the pump housing
`is substantially equal to
`the pressure target
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the
`method of adjusting pressure within the air chamber until a pressure sensed within the pump housing is substantially
`equal to the pressure target.
`For example, one or more processors in conjunction with the source code may adjust pressure within the air chamber
`until a pressure sensed within the pump housing is substantially equal to the pressure target. The one or more
`processors in conjunction with the source code further activates the pump/exhaust valve to adjust the pressure via
`inflation or deflation.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`20
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`The pressure from the air bladder is sensed within the pump housing.
`
`Pump
`
`Pump Housing
`
`(Photograph of Gen 3 Arco Air Controller)
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`21
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Pressure
`Transducer
`
`Port in fluid
`communication with the
`pressure transducer and
`air chamber
`
`Tubing fluidly coupling the port to an
`air chamber
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`22
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`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Circuit Board
`of Processor
`
`Pressure
`Transducer
`
`
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`23
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`See, e.g., S9, http://www.instantcomfort.com/s9.html (last visited August 21, 2018).
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`24
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`See, e.g., S9 Assembly Instructions,
`http://www.instantcomfort.com/uploads/8/0/0/1/80015572/b.q9s9assemblyinstructions.pdf (last visited August 21,
`2018).
`
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate how the Accused Products adjust pressure
`within the air chamber until a pressure sensed within the pump housing is substantially equal to the pressure target.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`25
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`27
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`28
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`
`This limitation may further implicate the electronics, software, firmware, and/or source code of the Accused Products.
`Source Code for the Accused Products may further show how this claim limitation is met. To resolve a dispute
`regarding Plaintiff’s Notice of Inspection for Source Code, the parties have agreed that Plaintiff shall be allowed to
`inspect remaining Source Code for the Accused Products on mutually agreeable date(s), after which Plaintiff shall
`supplement its infringement contentions, pursuant to an agreed-upon timeline and without opposition, using the
`information learned during the inspection.
`
`(1d) determining an
`actual chamber pressure
`within the air chamber
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the
`method of determining an actual chamber pressure within the air chamber.
`
`For example, one or more processors in conjunction with the source code and a pressure transducer, which is operably
`coupled to the processor and fluidly connected to the air chamber, determine a chamber pressure within the air
`chamber.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`29
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Pump
`
`Pump Housing
`
`(Photograph of Gen 3 Arco Air Controller)
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`30
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Pressure
`Transducer
`
`Port in fluid
`communication with the
`pressure transducer and
`air chamber
`
`Tubing fluidly coupling the port to an
`air chamber
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`31
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Circuit Board
`of Processor
`
`Pressure
`Transducer
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`32
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`See, e.g., S9, http://www.instantcomfort.com/s9.html (last visited August 21, 2018).
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`33
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`See, e.g., S9 Assembly Instructions,
`http://www.instantcomfort.com/uploads/8/0/0/1/80015572/b.q9s9assemblyinstructions.pdf (last visited August 21,
`2018).
`
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate how the Accused Products determine an actual
`chamber pressure within the air chamber.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`34
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`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`35
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 35
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`36
`
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`EXHIBIT 2048
`IPR2019-00500
`Page 36
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`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`
`This limitation may further implicate the electronics, software, firmware, and/or source code of the Accused Products.
`Source Code for the Accused Products may further show how this claim limitation is met. To resolve a dispute
`regarding Plaintiff’s Notice of Inspection for Source Code, the parties have agreed that Plaintiff shall be allowed to
`inspect remaining Source Code for the Accused Products on mutually agreeable date(s), after which Plaintiff shall
`supplement its infringement contentions, pursuant to an agreed-upon timeline and without opposition, using the
`information learned during the inspection.
`
`(1e) comparing the actual
`chamber pressure to the
`desired pressure setpoint
`to determine an
`adjustment factor error;
`and
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the
`method of comparing the actual chamber pressure to the desired pressure setpoint to determine an adjustment factor
`error.
`
`For example, the one or more processors in conjunction with the source code compare the determined actual chamber
`pressure within the air chamber to the desired pressure setpoint. The one or more processors in conjunction with the
`source code further determine an adjustment factor error.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`37
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`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 37
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`See, e.g., S9, http://www.instantcomfort.com/s9.html (last visited August 21, 2018).
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`38
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 38
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`See, e.g., S9 Assembly Instructions,
`http://www.instantcomfort.com/uploads/8/0/0/1/80015572/b.q9s9assemblyinstructions.pdf (last visited August 21,
`2018).
`
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate how the Accused Products compare the actual
`chamber pressure to the desired pressure setpoint to determine an adjustment factor error.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`39
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 39
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`40
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 40
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`This limitation may further implicate the electronics, software, firmware, and/or source code of the Accused Products.
`Source Code for the Accused Products may further show how this claim limitation is met. To resolve a dispute
`regarding Plaintiff’s Notice of Inspection for Source Code, the parties have agreed that Plaintiff shall be allowed to
`inspect remaining Source Code for the Accused Products on mutually agreeable date(s), after which Plaintiff shall
`supplement its infringement contentions, pursuant to an agreed-upon timeline and without opposition, using the
`information learned during the inspection.
`
`(1f) modifying the
`pressure adjustment factor
`based upon the
`adjustment factor error.
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the
`method of modifying the pressure adjustment factor based upon the adjustment factor error.
`
`For example, the one or more processors in conjunction with the source code modifies the pressure adjustment factor
`based upon the adjustment factor error.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`41
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`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 41
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`See, e.g., S9, http://www.instantcomfort.com/s9.html (last visited August 21, 2018).
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`42
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 42
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`See, e.g., S9 Assembly Instructions,
`http://www.instantcomfort.com/uploads/8/0/0/1/80015572/b.q9s9assemblyinstructions.pdf (last visited August 21,
`2018).
`
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate how the Accused Products modify the pressure
`adjustment factor based upon the adjustment factor error.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`43
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 43
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`44
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 44
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`This limitation may further implicate the electronics, software, firmware, and/or source code of the Accused Products.
`Source Code for the Accused Products may further show how this claim limitation is met. To resolve a dispute
`regarding Plaintiff’s Notice of Inspection for Source Code, the parties have agreed that Plaintiff shall be allowed to
`inspect remaining Source Code for the Accused Products on mutually agreeable date(s), after which Plaintiff shall
`supplement its infringement contentions, pursuant to an agreed-upon timeline and without opposition, using the
`information learned during the inspection.
`
`2. The method of claim 1,
`wherein the pressure
`sensed within the pump
`housing is sensed
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the
`method of claim 1, wherein the pressure sensed within the pump housing is sensed simultaneously while adjusting
`pressure within the air chamber.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`45
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`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 45
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`simultaneously while
`adjusting pressure within
`the air chamber.
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`For example, the pressure transducer senses the pressure at substantially the same time the one or more processors in
`conjunction with the source code adjust pressure within the air chamber. The pressure transducer is operably coupled
`to a port defining an opening into the pump housing and therefore configured to sense the pressure within the pump
`housing.
`
`Pressure
`Transducer
`
`
`
`
`
`Port in fluid
`communication with the
`pressure transducer and
`air chamber
`
`Tubing fluidly coupling the port to an
`air chamber
`
`
`
`46
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 46
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Air Controller
`
`
`
`
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`47
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 47
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`See, e.g., S9, http://www.instantcomfort.com/s9.html (last visited August 21, 2018).
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`48
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 48
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`See, e.g., S9 Assembly Instructions,
`http://www.instantcomfort.com/uploads/8/0/0/1/80015572/b.q9s9assemblyinstructions.pdf (last visited August 21,
`2018).
`
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate how in the Accused Products the pressure
`sensed within the pump housing is sensed simultaneously while adjusting pressure within the air chamber.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`49
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 49
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`50
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 50
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`51
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 51
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`52
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 52
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`This limitation may further implicate the electronics, software, firmware, and/or source code of the Accused Products.
`Source Code for the Accused Products may further show how this claim limitation is met. To resolve a dispute
`regarding Plaintiff’s Notice of Inspection for Source Code, the parties have agreed that Plaintiff shall be allowed to
`inspect remaining Source Code for the Accused Products on mutually agreeable date(s), after which Plaintiff shall
`supplement its infringement contentions, pursuant to an agreed-upon timeline and without opposition, using the
`information learned during the inspection.
`
`3. The method of claim 1,
`wherein pressure is
`sensed with a pressure
`transducer.
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the
`method of claim 1, wherein pressure is sensed with a pressure transducer.
`
`For example, ANM bed includes a pressure transducer, which senses the pressure.
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`53
`
`Sleep Number Corp.
`EXHIBIT 2048
`IPR2019-00500
`Page 53
`
`

`

`EXHIBIT B1: U.S. PATENT NO. 9,737,154 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Circuit Board
`of