EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC 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 has included a chart below identifying specifically where each element of each asserted claim of the ‘172 Patent is found
`within Defendant’s air mattress systems that utilize the Platinum 5000 and Platinum 6000 air controllers. Because the Platinum 6000 is representative
`of the Platinum 5000, both products are generally depicted using a Platinum 6000 product below. 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 Sizewise’s Accused Products. Specifically,
`the Platinum 5000 or Platinum 6000 Air Controllers (herein collectively “Platinum 5000/6000”)
`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 Platinum 5000/6000 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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`EXHIBIT 2073
`IPR2019-00514
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`
`
`INFRINGEMENT CONTENTIONS
`
`Part of the
`Valve Enclosure
`Assembly
`
`Pump,
`providing
`compressed air
`
`
`
`(Photograph representative of Platinum 5000/6000)
`
`The valve enclosure assembly of the Platinum 5000/6000 is used with an air inflatable mattress having
`at least one air bladder inflated by compressed air. For example, the Platinum 6000 is used with an air
`inflatable mattress, as seen below. The Platinum 5000 is also used with an air inflatable mattress (not
`depicted).
`
`2
`
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Controller
`containing the Valve
`Enclosure Assembly
`
`
`
`Air Inflatable
`Mattress
`
`(Photograph representative of Platinum 5000/6000)
`
`3
`
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`EXHIBIT 2073
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Inflatable
`Mattress
`
`(Photograph representative of Platinum 5000/6000)
`
`Air Controller
`containing the Valve
`Enclosure Assembly
`
`
`
`4
`
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Bladders of
`the Air Inflatable
`Mattress
`
`Air Inflatable
`Mattress
`
`
`
`(Photograph representative of Platinum 5000/6000)
`
`In the Platinum 5000/6000 air controllers, the pump is fluidly coupled to the at least one air bladder
`for providing compressed air thereto. In the Platinum 5000/6000 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 valve enclosure assembly via tubing. The valve enclosure assembly is then
`similarly fluidly coupled to the at least one air bladder with tubing that connects to a manifold of the
`valve enclosure assembly. The pump provides compressed air to the at least one air bladder via the
`tubing between the pump and the valve enclosure assembly and the tubing between the valve
`enclosure assembly and the air bladder.
`
`5
`
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`
`
`INFRINGEMENT CONTENTIONS
`
`Manifold of the
`Valve Enclosure
`Assembly
`Enclosure of the
`Valve Enclosure
`Assembly
`
`Tubing Fluidly Coupling
`the Pump to the Valve
`Enclosure Assembly
`
`Pump
`
`
`(Photograph representative of Platinum 5000/6000)
`
`As seen in the photographs below, tubing connects to the manifold of the valve enclsoure assembly.
`The tubing fluidly couples the air bladder(s) to the valve enclosure assembly.
`
`
`
`6
`
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Manifold of the
`Valve Enclosure
`Assembly
`
`(Photograph of Platinum 5000) (Photograph of Platinum 6000)
`
`As shown below, tubing connects to the manifold of the valve enclosure assembly of the Platinum
`5000/6000.
`
`
`
`
`7
`
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Mattress
`comprised of at least
`one air Bladder
`
`Tubing Fluidly
`Coupling the
`Valve Enclosure
`Assembly to an
`Air Bladder
`
`Platinum 6000 Air
`Controller
`(representative of the
`Platinum 5000)
`
`(Photograph of Platinum 6000)
`
`As shown in the example above of a Platinum air controller being used with an inflatable air matress,
`the tubes fluidly couple the valve enclosure assembly 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 to the valve enclosure assembly.
`
`In the Platinum 5000/6000 air controllers, a processor provides commands to the improved valve
`enclosure assembly during an inflate/deflate cycle:
`
`
`
`8
`
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`EXHIBIT 2073
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`
`
`INFRINGEMENT CONTENTIONS
`
`Enclosure of
`Valve Enclosure
`Assembly
`
`Printed Circuit Board for
`Processor, which provides
`commands to the valve
`enclosure assembly
`during an inflate/deflate
`cycle
`
`
`
`
`(Photograph representative of Platinum 5000/6000)
`
`The Platinum and Medisphere source code further demonstrates that the Accused Products include a
`processor for providing commands to the improved valve enclosure assembly during an inflate/deflate
`cycle.
`
`
`9
`
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`Sleep Number Corp.
`EXHIBIT 2073
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`10
`
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`EXHIBIT 2073
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`11
`
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`12
`
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`
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`EXHIBIT 2073
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`13
`
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`EXHIBIT 2073
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`

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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`14
`
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`EXHIBIT 2073
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC 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
`information learned during the inspection.
`
`
`15
`
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`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,”
`the Platinum 5000/6000 air controllers meet this claim limitation. As seen in the photograph below,
`the Platinum 5000/6000 use a similar valve enclosure assembly comprised of an enclosure portion and
`a rear cover portion.
`
`
`
`(Photograph representative of Platinum 5000/6000)
`
`The enclosure portion and rear-cover portion constitute the walls of an internal, pressurized air
`chamber enclosing a valve, as seen in the interior of the enclosure below. As also seen, part of an
`internal pressurized chamber is shown enclosing a valve. Specifically, the enclosure includes a valve
`port having a valve seat and which is configured to or capable of receiving a portion of the solenoid.
`
`16
`
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`EXHIBIT 2073
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`The interactions between the valve seat and the a portion of the solenoid create the valve.
`
`Internal,
`pressurized
`chamber
`
`Valve Port
`
`Valve Seat
`
`
`(Photograph representative of Platinum 5000/6000)
`
`
`17
`
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`
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`EXHIBIT 2073
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Solenoid
`
`Plunger of
`Solenoid
`
`[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
`
`
`
`(Photograph representative of Platinum 5000/6000)
`
`Under the plain and ordinary meaning of the claim terms in light of the specification, the Platinum
`5000/6000 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 Platinum 5000/6000 air controllers 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.
`
`18
`
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`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`
`
`INFRINGEMENT CONTENTIONS
`
`Enclosure, Defining a
`Substantially Fluidly
`Sealed Air Chamber
`(internal)
`
`Air Inlet to
`Substantially Fluidly
`Sealed Air Chamber
`
`Tubing that
`fluidly couples
`the pump to
`the air
`chamber via
`the air inlet
`
`Pump
`
`
`(Photograph representative of Platinum 5000/6000)
`
`As seen above and further seen below, the tubing is secured in place at both the pump and the air inlet
`in order to fluidly couple the two, in the Platinum 5000/6000 air controllers.
`
`
`
`19
`
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`Sleep Number Corp.
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`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Enclosure, which defines a
`Substantially Fluidly
`Sealed Air Chamber
`
`Air Inlet to
`Substantially Fluidly
`Sealed Air Chamber
`
`Tubing that
`fluidly couples
`the pump to the
`air chamber via
`the air inlet
`
`Pump
`
`
`(Photograph representative of Platinum 5000/6000)
`
`
`
`
`
`
`20
`
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`The Platinum 5000/6000 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
`
`Substantially fluidly
`sealing the air chamber
`
`
`(Photograph representative of Platinum 5000/6000)
`
`When the Platinum 5000/6000 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
`
`21
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`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC 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 Platinum 5000/6000 air controller include a plurality of guides and stops disposed within the
`enclosure for correctly positioning components within the enclosure. Guides within the enclosure
`correctly position the solenoid components within the enclosure. Also, within the enclosure, a raised
`fitting, valve seat, ledge and/or a rubber O-ring stop the components at the correct position within the
`enclosure; specifically the solenoid is stopped in the correct position.
`
`Enclosure
`
`Stops
`
`Guides
`
`
`(Photograph representative of Platinum 5000/6000)
`
`22
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`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
`bottom of the enclosure to limit the travel of internal components,” the Platinum 5000/6000 air
`controllers meet this claim limitation.
`
`The enclosure of the Platinum 5000/6000 air controllers include guides formed on the inner surface of
`the bottom of the enclosure that are used to laterally position solenoid components. The enclosure of
`the Platinum 5000/6000 air controllers further includes a raised fitting, valve seat, ledge and/or a
`rubber O-ring structure formed on the inner surface of the bottom of the enclosure to limit travel of
`components. The enclosure further includes a plastic structure formed on the inner surface of the
`bottom of the enclosure to limit travel of components.
`
`
`
`
`
`23
`
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`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`(Photograph representative of Platinum 5000/6000)
`
`
`
`24
`
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`[2.2] pressure monitor means being
`operably coupled to the processor and
`being in fluid communication with the at
`least one bladder for continuously
`monitoring the pressure in the at least one
`bladder.
`
`
`INFRINGEMENT CONTENTIONS
`
`The “pressure monitor means” is a means-plus-function limitation subject to pre-AIA 35 U.S.C. §
`112, ¶ 6. The function is continuously monitoring the pressure in the at least one bladder. The
`structure is a port fluidly coupled to the interior of the valve enclosure assembly that is designed to
`receive a tube, a pressure sensor, and a tube connected to the port and to the pressure sensor, and
`equivalents thereof. Under this construction, and where the other claim terms are given their plan and
`ordinary meaning in light of the specification, the Platinum 5000/6000 air controllers include a
`pressure monitor means being operably coupled to the processor and being in fluid communication
`with the at least one bladder for continuously monitoring the pressure in the at least one bladder.
`
`The Platinum 5000/6000 air controllers have a valve enclosure assembly with tubes to convey
`pressure information from a tap or port on the enclosure to substantially similar pressure sensors on a
`printed circuit board.
`
`Specifically, the Platinum 5000/6000 air controllers include an enclosure having a pressure
`monitoring port, which is capable of being in fluid communication with an air chamber located within
`an interior of the enclosure. As seen in the photograph below, a tube is connected to the pressure
`monitoring port. The tube is also connected to a pressure sensor. In addition, as discussed above, the
`pressure in the one or more air bladders is conveyed to the valve enclosure assembly via the tubing
`that fluidly couples the enclosure to the air bladder(s). Accordingly, the bladder pressure is conveyed
`to the pressure sensor from the enclosure via the tubing connected to the pressure monitoring port and
`pressure sensor. The pressure sensor is operatively coupled to a processor. The processor is configured
`to monitor the pressure detected by the pressure sensor.
`
`
`25
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Pressure Monitoring Port
`in fluid communication
`with the interior of the
`enclosure of the valve
`enclosure assembly
`
`Circuit Board
`of Processor
`
`Pressure Sensor
`
`
`
`(Photograph representative of Platinum 5000/6000)
`
`
`Tube, connected to
`the pressure sensor
`and pressure
`monitoring port
`
`
`
`26
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`The pressure monitor means is capable of being in fluid communication with the at least one bladder
`and configured to or capable of continuously monitoring the pressure in the at least one bladder.
`Because, as explained above, tubing connects the pressure sensor(s) to the pressure monitoring port(s)
`on the enclosure, the pressure sensor is in fluid communication with the enclosure. In addition, as seen
`below, because the tubing that attaches to the ports to the air bladder(s) fluidly couples the enclosure
`to the air bladder(s), the valve enclosure assembly is in fluid communication with the air bladder(s).
`Accordingly, the pressure sensor is in or capable of being in fluid communication with the air
`bladder(s) and the pressure sensor and the processor are therefore configured to or capable of
`continuously monitoring the pressure in the air bladder(s).
`
`
`
`Tube, connected to the pressure
`sensor and pressure monitoring port
`
`Pressure Monitoring Port
`in fluid communication
`with the interior of the
`enclosure of the valve
`enclosure assembly
`
`Ports to Air Bladder
`
`
`(Photographs representative of Platinum 5000/6000)
`
`
`
`27
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`Sleep Number Corp.
`EXHIBIT 2073
`IPR2019-00514
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`

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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`The Platinum and Medisphere source code further demonstrate that the Accused Products’ processors
`are configured to monitor and do continuously monitor, or are capable of continuously monitoring, the
`pressure detected by the pressure sensor(s).
`
`28
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`Sleep Number Corp.
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`

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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`29
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`Sleep Number Corp.
`EXHIBIT 2073
`IPR2019-00514
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`

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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`30
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`EXHIBIT 2073
`IPR2019-00514
`Page 30
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`

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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`31
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`

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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC 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
`
`32
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`Sleep Number Corp.
`EXHIBIT 2073
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`Page 32
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`Claim 6
`[6.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
`
`information learned during the inspection.
`
`The preamble of claim 6 is limiting and under the plain and ordinary meaning of these claim terms in
`light of the specification, each claim limitation is met by Sizewise’s Accused Products. Specifically,
`the Platinum 5000 or Platinum 6000 Air Controllers (herein collectively “Platinum 5000/6000”)
`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 Platinum 5000/6000 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:
`
`
`33
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Part of the
`Valve Enclosure
`Assembly
`
`Pump,
`providing
`compressed air
`
`
`
`(Photograph representative of Platinum 5000/6000)
`
`The valve enclosure assembly of the Platinum 5000/6000 is used with an air inflatable mattress having
`at least one air bladder inflated by compressed air. For example, the Platinum 6000 is used with an air
`inflatable mattress, as seen below. The Platinum 5000 is also used with an air inflatable mattress (not
`depicted).
`
`34
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`Sleep Number Corp.
`EXHIBIT 2073
`IPR2019-00514
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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Controller
`containing the Valve
`Enclosure Assembly
`
`
`
`Air Inflatable
`Mattress
`
`(Photograph representative of Platinum 5000/6000)
`
`35
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`Sleep Number Corp.
`EXHIBIT 2073
`IPR2019-00514
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Inflatable
`Mattress
`
`(Photograph representative of Platinum 5000/6000)
`
`Air Controller
`containing the Valve
`Enclosure Assembly
`
`
`
`36
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`Sleep Number Corp.
`EXHIBIT 2073
`IPR2019-00514
`Page 36
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`

`

`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Bladders of
`the Air Inflatable
`Mattress
`
`Air Inflatable
`Mattress
`
`
`
`(Photograph representative of Platinum 5000/6000)
`
`In the Platinum 5000/6000 air controllers, the pump is fluidly coupled to the at least one air bladder
`for providing compressed air thereto. In the Platinum 5000/6000 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 valve enclosure assembly via tubing. The valve enclosure assembly is then
`similarly fluidly coupled to the at least one air bladder with tubing that connects to a manifold of the
`valve enclosure assembly. The pump provides compressed air to the at least one air bladder via the
`tubing between the pump and the valve enclosure assembly and the tubing between the valve
`enclosure assembly and the air bladder.
`
`37
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`EXHIBIT 2073
`IPR2019-00514
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`

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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`
`
`INFRINGEMENT CONTENTIONS
`
`Manifold of the
`Valve Enclosure
`Assembly
`Enclosure of the
`Valve Enclosure
`Assembly
`
`Tubing Fluidly Coupling
`the Pump to the Valve
`Enclosure Assembly
`
`Pump
`
`
`(Photograph representative of Platinum 5000/6000)
`
`As seen in the photographs below, tubing connects to the manifold of the valve enclsoure assembly.
`The tubing fluidly couples the air bladder(s) to the valve enclosure assembly.
`
`
`
`38
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`Sleep Number Corp.
`EXHIBIT 2073
`IPR2019-00514
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`

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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Manifold of the
`Valve Enclosure
`Assembly
`
`(Photograph of Platinum 5000) (Photograph of Platinum 6000)
`
`As shown below, tubing connects to the manifold of the valve enclosure assembly of the Platinum
`5000/6000.
`
`
`
`
`39
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`Sleep Number Corp.
`EXHIBIT 2073
`IPR2019-00514
`Page 39
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`

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`EXHIBIT A2 - U.S. PATENT NO. 5,904,172 VERSUS SIZEWISE RENTALS, LLC ACCUSED PRODUCTS
`
`CLAIM ELEMENT
`
`
`INFRINGEMENT CONTENTIONS
`
`Air Mattress
`comprised of at least
`one air Bladder
`
`Tubing Fluidly
`Coupling the
`Valve Enclosure
`Assembly to an
`Air Bladder
`
`Platinum 6000 Air
`Controller
`(representative of the
`Platinum 5000)
`
`(Photograph of Platinum 6000)
`
`As shown in the example above of a Platinum air controller being used with an inflatable air matress,
`the tubes fluidly couple the valve enclosure assembly 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 to the valve enclosure assembly.
`
`In the Platinum 5000/6000 air controllers, a processor provides commands to the improved valve
`enclosure assembly during an inflate/deflate cycle:
`
`
`
`40
`