EXHIBIT A1 - U.S. PATENT NO. 5,904,172 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 ‘172 Patent is found
`within Defendant’s consumer and/or medical air mattress systems that utilize the Gen 3 Arco, Gen 3 Koge, and Gen X air controllers. 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 stipulations between the parties.
`
`
`CLAIM ELEMENT
`
`Claim 2
`[2.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:
`
`
`INFRINGEMENT CONTENTIONS
`
`The preamble of claim 2 is limiting and under the plain and ordinary meaning of these claim terms in
`light of the specification, each claim limitation is met by ANM’s Accused Products. Specifically, the
`Gen 3 Arco, Gen X, and Gen 3 Koge air controllers include 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.
`
`
`The Accused Products having a Gen 3 Arco air controller include an improved valve enclosure
`assembly for use with an air inflatable mattress having at least one air bladder inflated by compressed
`air:
`
`
`1
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`Sleep Number Corp.
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Enclosure of
`Valve Enclosure
`Assembly
`
`
`
`(Photograph of Gen 3 Arco)
`
`The Accused Products having a Gen X air controller include an improved valve enclosure assembly
`for use with an air inflatable mattress having at least one air bladder inflated by compressed air:
`
`
`2
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Enclosure of
`Valve Enclosure
`Assembly
`
`
`(Photograph of Gen X)
`
`The Accused Products having a Gen 3 Koge air controller include an improved valve enclosure
`assembly for use with an air inflatable mattress having at least one air bladder inflated by compressed
`air:
`
`3
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Enclosure of
`Valve Enclosure
`Assembly
`
`(Photograph of Gen 3 Koge)
`
`The valve enclosure assemblies of the Gen 3 Arco, Gen X, and Gen 3 Koge are used with an air
`inflatable mattress having at least one air bladder inflated by compressed air. Non-limiting examples
`of said use is shown in the photographs below.
`
`
`
`
`4
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Inflatable
`Mattress
`
`
`
`Air Controller
`containing the Valve
`Enclosure Assembly
`
`
`
`
`
`
`
`
`
`5
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Bladder of Air
`Inflatable Mattress,
`which is inflatable
`by compressed air
`
`Air Inflatable
`Mattress
`
`
`
`Air Controller
`containing the Valve
`Enclosure Assembly
`
`
`
`
`
`
`
`
`
`
`
`
`6
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Bladder of Air
`Inflatable Mattress,
`inflated by
`compressed air
`
`Air Bladder of Air
`Inflatable Mattress,
`deflated
`
`Air Bladder of Air
`Inflatable Mattress,
`which is inflatable
`by compressed air
`
`
`
`
`
`7
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Inflatable
`Mattress
`
`Bladders of Air
`Inflatable Mattress,
`which are inflatable
`by compressed air
`
`Air Controller
`containing the Valve
`Enclosure Assembly
`
`
`
`(Photograph of medical air mattress system)
`
`In the Gen 3 Arco, Gen X, and Gen 3 Koge air controllers, the pump is fluidly coupled to the at least
`one air bladder for providing compressed air thereto. In the Gen 3 Arco, Gen X, and Gen 3 Koge air
`controllers, the improved valve enclosure assembly is fluidly coupled intermediate the pump and the
`at least one air bladder for controlling the inflation of the at least one air bladder. As shown in the
`photographs below, the pump is fluidly coupled to the enclosure of the valve enclosure assembly via
`tubing. The enclosure of the valve enclosure assembly is then similarly fluidly coupled to the at least
`one air bladder with tubing. The pump provides compressed air to the at least one air bladder via the
`tubing between the pump and the enclosure of the valve enclosure assembly and the tubing between
`the valve enclosure assembly and the air bladder.
`
`8
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`Gen 3 Arco:
`
`
`INFRINGEMENT CONTENTIONS
`
`Pump
`
`Tubing Fluidly Coupling
`the Pump to the Valve
`Enclosure Assembly
`
`Enclosure of
`Valve Enclosure
`Assembly
`
`Tubing Fluidly
`Coupling the Enclosure
`of Valve Enclosure
`Assembly to an Air
`Bladder
`
`
`
`
`(Photograph of Gen 3 Arco)
`
`
`
`
`
`9
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`Gen X:
`
`
`INFRINGEMENT CONTENTIONS
`
`Pump
`
`Tubing Fluidly Coupling the
`Pump to the Enclosure of the
`Valve Enclosure Assembly
`
`Enclosure of
`Valve Enclosure
`Assembly
`
`Fluidly Couples the
`Enclosure of Valve
`Enclosure Assembly to
`an Air Bladder
`
`
`(Photograph of Gen X)
`
`
`
`
`
`
`10
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Gen 3 Koge:
`Tubing Fluidly Coupling
`the Pump to the
`Enclosure of Valve
`Enclosure Assembly
`
`Pump
`
`Enclosure of
`Valve Enclosure
`Assembly
`
`
`
`Tubing Fluidly
`Coupling the
`Enclosure of Valve
`
`Enclosure Assembly
`
`to an Air Bladder
`
`(Photograph of Gen 3 Koge)
`
`
`
`11
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`As shown in the example of a Gen 3 air controller being used with an inflatable air matress, the two
`tubes that fluidly couple to the valve enclosure assembly fluidly couple to the air bladders of the
`inflatable air matress. Because the pump is fluidly coupled to the air bladder, the air bladders inflate
`using the compressed air from the pump.
`
`Air Bladders of Air
`Inflatable Mattress,
`which are inflated
`using compressed air
`
`Tubing Fluidly
`Coupling the Valve
`Enclosure Assembly
`to an Air Bladder
`
`
`
`Air Controller
`containing the Valve
`Enclosure Assembly
`
`
`
`
`
`
`In the Gen 3 Arco, Gen X, and Gen 3 Koge air controllers, a processor provides commands to the
`improved valve enclosure assembly during an inflate/deflate cycle:
`
`
`12
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`Gen 3 Arco:
`
`
`INFRINGEMENT CONTENTIONS
`
`Printed Circuit Board for
`Processor, which provides
`commands to the
`improved valve enclosure
`assembly during an
`inflate/deflate cycle
`
`Enclosure of
`Valve Enclosure
`Assembly
`
`
`(Photograph of Gen 3 Arco)
`
`
`
`
`
`
`
`13
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`Gen X:
`
`
`INFRINGEMENT CONTENTIONS
`
`Printed Circuit Board for
`Processor, which provides
`commands to the
`improved valve enclosure
`assembly during an
`inflate/deflate cycle
`
`Enclosure of
`Valve Enclosure
`Assembly
`
`
`(Photograph of Gen X)
`
`
`
`
`
`
`14
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`Gen 3 Koge:
`
`
`INFRINGEMENT CONTENTIONS
`
`Printed Circuit Board for
`Processor, which provides
`commands to the
`improved valve enclosure
`assembly during an
`inflate/deflate cycle
`
`Enclosure of
`Valve Enclosure
`Assembly
`
`
`(Photograph of Gen 3 Koge)
`
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate that the Gen 3 Accused
`Products include a processor for providing commands to the improved valve enclosure assembly
`during an inflate/deflate cycle.
`
`
`
`
`
`15
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`16
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`17
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`18
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`
`This limitation may further implicate other electronics, software, firmware, and/or source code of the
`Accused Products. Additional 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
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`information learned during the inspection.
`
`Even under Defendants’ construction from the ITC proceeding, where a “valve enclosure assembly”
`means “an enclosure and a rear cover defining an internal, pressurized air chamber enclosing a valve,”
`ANM’s Gen 3 or Gen X air controllers meet this claim limitation.
`
`As seen in the photographs below, the enclosure of the Gen 3 Arco’s valve enclosure assembly is
`comprised of an enclosure and a rear cover.
`Rear Cover of the Valve
`Enclosure Assembly
`
`Internal air
`chamber
`
`
`
`Enclosure of
`the Valve
`Enclosure
`Assembly
`
`
`(Photograph of the Gen 3 Arco)
`
`20
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`
`
`
`Furthermore, as seen in the photograph below showing a side perspective view of the Gen 3 Arco’s
`enclosure, the Gen 3 Arco the internal chamber is shown enclosing a valve.
`
`21
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Perspective view of the internal chamber enclosing a valve
`
`(Photograph of Gen 3 Arco)
`
`22
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`As seen in the photographs below, the enclosure of the Gen X’s valve enclosure assembly is
`comprised of an enclosure and a rear cover.
`Rear Cover of the Valve
`Enclosure Assembly
`
`Enclosure of
`the Valve
`Enclosure
`Assembly
`
`Internal air
`chamber
`
`
`(Photograph of the Gen 3 Arco)
`
`Furthermore, as seen in the photograph below showing a side perspective view of the Gen 3 Arco’s
`enclosure, the Gen 3 Arco the internal chamber is shown enclosing a valve.
`
`
`
`23
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Internal
`Chamber
`Enclosing a
`Valve
`
`(Photograph of Gen 3 Arco)
`
`
`
`
`
`24
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`As seen in the photographs below, the enclosure of the Gen 3 Koge’s valve enclosure assembly is
`comprised of an enclosure and a rear cover. The valve seal is contained within the enclosure, which
`shows how the enclosure and rear cover define an internal air chamber enclosing a valve.
`Rear Cover of the Valve
`Enclosure Assembly
`
`Internal air
`chamber
`enclosing a valve
`
`Enclosure of
`the Valve
`Enclosure
`Assembly
`
`(Photograph of the Gen 3 Koge)
`
`
`
`25
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`[2.1] 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; and
`
`
`INFRINGEMENT CONTENTIONS
`
`Under the plain and ordinary meaning of the claim terms in light of the specification, the Gen 3 Arco,
`Gen X, and Gen 3 Koge Air Controllers include 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.
`
`The Gen 3 Arco air controller includes an enclosure defining a substantially fluidly sealed air chamber
`that has at least one air inlet to the air chamber, which is fluidly coupled to the pump.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`26
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`Gen 3 Arco:
`
`
`INFRINGEMENT CONTENTIONS
`
`Pump
`
`Air Inlet to
`Substantially Fluidly
`Sealed Air Chamber
`
`Enclosure, Defining a
`Substantially Fluidly
`Sealed Air Chamber
`(internal)
`
`Fluidly couples
`the pump to
`the air
`chamber via
`the air inlet
`
`
`
`(Photograph of Gen 3 Arco)
`
`As seen in the photograph above, tubing connects the pump to the enclosure and to the air inlet to the
`air chamber of the enclosure. That is, the air inlet to the air chamber is fluidly coupled to the pump.
`
`
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Enclosure, which defines
`a Substantially Fluidly
`Sealed Air Chamber
`
`(Photograph of Gen 3 Arco)
`
`
`
`
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`(Photograph of Gen 3 Arco)
`
`
`As further seen from the photographs below, the enclosure defines an air chamber. The air chamber
`includes one or more O-rings, which assist in substantially fluidly sealing the air chamber.
`
`
`
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`O-ring, which assists in
`Substantially Fluidly
`Sealing the Air Chamber
`
`
`(Photograph of Gen 3 Arco’s enclosure (depicted with the rear-cover removed for illustrative
`purposes).)
`
`
`
`
`30
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`O-ring, which assists in
`substantially fluidly
`sealing the air chamber
`
`Part of the enclosure
`defining a substantially
`
`fluidly sealed air
`chamber
`
`
`
`(Photograph of Gen 3 Arco’s enclosure (depicted with solenoids removed).)
`
`
`
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 31
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`

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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`The Accused Products having a Gen X air controller include an enclosure defining a substantially
`fluidly sealed air chamber that has at least one air inlet to the air chamber, which is fluidly coupled to
`the pump.
` Gen X:
`
`Pump
`
`Air inlet to the
`substantially fluidly
`sealed air chamber
`
`Enclosure, Defining a
`Substantially Fluidly
`Sealed Air Chamber
`(internal)
`
`Fluidly couples
`the pump to
`the air
`chamber via
`the air inlet
`
`
`(Photograph of Gen X)
`
`
`
`32
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 32
`
`

`

`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`
`As seen in the photograph above, tubing connects the pump to the enclosure and to the air inlet to the
`air chamber of the enclosure. That is, the air inlet to the air chamber is fluidly coupled to the pump.
`
`
`Air Inlet to Substantially
`Fluidly Sealed Air
`Chamber of the
`Enclosure
`
`(Photograph of Gen X)
`
`
`
`
`
`33
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 33
`
`

`

`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`As further seen from the photographs below, the enclosure defines an air chamber. The air chamber
`includes one or more O-rings, which assist in substantially fluidly sealing the air chamber.
`
`O-ring, which assists in
`Substantially Fluidly
`Sealing the Air Chamber
`
`
`(Photograph of Gen X’s enclosure (depicted with the rear-cover and O-ring disassembled for
`illustrative purposes).)
`
`
`
`
`34
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 34
`
`

`

`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`O-ring, which assists in
`substantially fluidly
`sealing the air chamber
`
`Part of the Enclosure
`defining a substantially
`fluidly sealed air
`chamber
`
`
`(Photograph of Gen X’s enclosure (depicted with solenoids removed).)
`
`
`
`
`35
`
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 35
`
`

`

`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`The Accused Products having a Gen 3 Koge air controller include an enclosure defining a
`substantially fluidly sealed air chamber that has at least one air inlet to the air chamber, which is
`fluidly coupled to the pump.
`
`Gen 3 Koge:
`
`Air Inlet to
`Substantially Fluidly
`Sealed Air Chamber
`
`Fluidly couples the
`pump to the air
`chamber via the air
`inlet
`
`Pump
`
`Enclosure, Defining a
`Substantially Fluidly
`Sealed Air Chamber
`(internal)
`
`
`
`
`(Photograph of Gen 3 Koge)
`
`36
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 36
`
`

`

`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`As seen in the photograph above, tubing connects the pump to the enclosure and to the air inlet to the
`air chamber of the enclosure. That is, the air inlet to the air chamber is fluidly coupled to the pump.
`
`Enclosure, which defines
`a Substantially Fluidly
`Sealed Air Chamber
`
`(Photograph of Gen 3 Koge)
`
`
`
`
`
`
`37
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 37
`
`

`

`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`As further seen from the photographs below, the enclosure defines an air chamber. The air chamber
`includes one or more interlocking connectors, which assist in substantially fluidly sealing the air
`chamber.
`
`
`Interlocking connectors
`
`Enclosure defining
`Substantially Fluidly
`Sealing the Air Chamber
`
`(Photograph of Gen 3 Koge)
`
`
`
`38
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 38
`
`

`

`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Substantially Fluidly
`Sealed Air Chamber
`
`Enclosure
`
`
`(Photograph of Gen 3 Koge’s enclosure (depicted detached from other enclosure components).)
`
`When the Gen 3 and Gen X air controllers inflate the one or more air bladders, the pump, tubing that
`connects the pump to the air inlet, air chamber, and tubing connecting the air chamber to the one or
`more air bladders creates a substantially fluidly sealed environment substantially fluidly sealing the air
`chamber. That is, the enclosure contains several fluid tight seals and the tubing connecting the air
`bladders and pump to the enclosure creates a fluidly sealed environment such that the air chamber
`defined by the enclosure is substantially fluidly sealed. To the extent this limitation is not literally
`present the limitation is met under the doctrine of equivalents because the substantially fluidly sealed
`
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 39
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`

`

`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`environment performs substantially the same function as a substantially sealed air chamber in
`substantially the same way and to obtain the substantially same result. Accordingly, the air chamber
`defined by the enclosure meets the substantially fluidly sealed limitation.
`
`The Accused Products having a Gen 3 Arco air controller include a plurality of guides and stops
`disposed within the enclosure for correctly positioning components within the enclosure. Specifically,
`the enclosure of the Gen 3 Arco includes threaded guides or guide walls within the enclosure for
`correctly positioning solenoid components within the enclosure. The enclosure of the Gen 3 Arco
`further includes a raised valve seat, ledge, and/or O-ring to stop the component at the correct position
`within the enclosure.
`
`
`Enclosure
`
`Stops
`
`
`(Photograph of Gen 3 Arco)
`
`
`Guides
`
`
`
`40
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 40
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`

`

`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`The Accused Products having a Gen X air controller include a plurality of guides and stops disposed
`within the enclosure for correctly positioning solenoid components within the enclosure and a raised
`valve seat, ledge, and/or O-ring to stop the solenoid component(s) at the correct position within the
`enclosure.
`
`
`Enclosure
`
`Stops
`
`(Photograph of Gen X)
`
`
`
`Guides
`
`
`
`41
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 41
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`

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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`The Accused Products having a Gen 3 Koge air controller include a plurality of guides and stops
`disposed within the enclosure for correctly positioning components within the enclosure. Specifically,
`the enclosure of the Gen 3 Koge includes guiding walls within the enclosure for correctly positioning
`components within the enclosure. The solenoid component extends into the enclosure until it
`intersects with a stop, i.e., a raised fitting, valve seat, or ledge, etc. within the enclosure to create a
`seal.
`
`
`Solenoid
`Component
`
`Enclosure
`
`(Photograph of Gen 3 Koge)
`
`
`
`42
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 42
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`The guiding wall guide and raised ledge stop can be further seen in the photograph below of a cross
`section of the enclosure of the enclosure assembly.
`
`Stop
`
`Guide
`
`
`Even under Defendants’ constructions from the ITC proceeding, where a “guide” would be construed
`as “structures formed on the inner surface of the bottom of the enclosure to laterally position internal
`components,” and a “stop” would be construed as “structures formed on the inner surface of the
`
`
`
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`EXHIBIT 2072
`IPR2019-00514
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`bottom of the enclosure to limit the travel of internal components,” ANM’s Gen 3 or Gen X air
`controllers meet this claim limitation.
`
`The enclosure of the Gen 3 Arco includes threaded guides to laterally position internal solenoid
`components. The enclosure of the Gen 3 Arco further includes a raised valve seat, ledge, and/or O-
`ring to limit travel of solenoid components. The enclosure further includes a plastic structure formed
`on the inner surface of the bottom of the enclosure to limit travel of internal components.
`
`
`Guides in the
`enclosure
`
`
`
`Stops in the
`enclosure
`
`Bottom of the
`Enclosure
`
`
`
`(Photograph of Gen 3 Arco)
`
`The enclosure of the Gen X includes threaded guides to laterally position internal solenoid
`components. The enclosure of the Gen X further includes a raised valve seat, ledge, and/or O-ring to
`
`44
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`limit travel of solenoid components. The enclosure further includes a plastic structure formed on the
`inner surface of the bottom of the enclosure to limit travel of internal components.
`
`Enclosure
`
`Guides in the
`enclosure
`
`Bottom of the
`Enclosure
`
`
`
`Stops in the
`enclosure
`
`(Photograph of Gen X)
`
`
`
`
`
`
`45
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 45
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`

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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`The enclosure of the Gen 3 Koge includes guiding walls to laterally position solenoid components.
`The solenoid component extends into the enclosure until it is stopped by a stop configured to limit
`travel of the solenoid.
`
`Guiding wall structure
`formed on the bottom
`inner surface
`
`
`
`
`
`46
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 46
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`

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`EXHIBIT A1 - U.S. PATENT NO. 5,904,172 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`The guiding wall guide and stop can be further seen on an inner surface of the enclosure in the
`photograph below, a cross section of the enclosure of the enclosure assembly.
`
`Stop
`
`Guide
`
`Bottom of
`Enclosure
`
`
`
`
`
`
`
`47
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`Sleep Number Corp.
`EXHIBIT 2072
`IPR2019-00514
`Page 47
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