EXHIBIT C1: U.S. PATENT NO. 8,769,747 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 ’747 Patent is found
`within Defendant’s exemplary consumer air mattress system product, a Gen 3 Arco air controller with a model S9 bed. 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 LANGUAGE
`
`(1pre) A method for
`adjusting pressure
`within an air bed
`comprising:
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices a method for
`adjusting pressure within an air bed.
`
`For example, ANM air bed includes a controller for adjusting pressure.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`
`Pump
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
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`2
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`In addition, ANM website sends the user to “Instant Comfort” for consumer sleep systems.
`
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`All of the mattresses include a Pump & Control System. For example, the S9 mattress includes a Pump & Control System.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`The S9 assembly instructions also show the control system connects to the air bed.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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
`
`6
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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
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`7
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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.
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices a method
`providing or receiving an air bed, the air bed including an air chamber and a pump having a pump housing.
`
`(1a) providing or
`receiving an air bed,
`the air bed including
`an air chamber and a
`
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`pump having a
`pump housing
`
`For example, one or more processors in conjunction with source code provides or receives an air bed and the air bed includes
`an air chamber and a pump having a pump housing.
`
`
`
`
`
`
`
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`
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Air Controller
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`10
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`The S9 assembly Instructions steps 7 and 10 also show an air bed with an air chamber and a pump having a pump housing.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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).
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`12
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate how the Accused Products provide or receive an air
`bed, the air bed including an air chamber and a pump having a pump housing.
`
`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.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`13
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`(1b) selecting a
`desired pressure
`setpoint for the air
`chamber
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices a method for
`selecting a desired pressure setpoint for the air chamber.
`
`For example, a user selects the desired pressure when the user presses up/down on the hand control. The one or more
`processors in conjunction with the source code receive a signal based on the user input and select a desired pressure setpoint
`for the air chamber.
`
`The S9 assembly Instructions step 9 also shows selecting the desired pressure by pressing up/down on the controller.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`14
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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).
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`15
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate how the Accused Products select a desired pressure
`setpoint for the air chamber.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`16
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`17
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`18
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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) determining an
`initial pressure
`within the pump
`housing
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the method
`of determining an initial pressure within the pump housing.
`
`For example, the one or more processors in conjunction with source code determine an initial pressure within the pump
`housing. One or more pressure sensors/transducers are fluidly coupled to the pump housing. The processor is operably
`coupled to the one or more pressure sensors/transducers. The one or more processors in conjunction with the source code and
`pressure transducers and configured to read, sense, or determine the initial pressure.
`
`
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`
`
`
`Air Controller
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`20
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`21
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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
`
`
`
`22
`
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Pressure
`Transducer
`
`
`
`
`
`Circuit Board
`of Processor
`
`
`
`23
`
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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 initial pressure
`within the pump housing.
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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 C1: U.S. PATENT NO. 8,769,747 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 C1: U.S. PATENT NO. 8,769,747 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.
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the method
`of calculating a pressure target based upon the desired pressure setpoint and a pressure adjustment factor.
`
`The one or more processors in conjunction with the source code calculate a pressure target based upon the desired pressure
`setpoint and a pressure adjustment factor.
`
`(1d) calculating a
`pressure target based
`upon the desired
`pressure setpoint and
`a pressure
`adjustment factor
`
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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).
`
`Versions 1.8, 1.97, and 2.0 of ANM’s source code further demonstrate how the Accused Products calculate a pressure target
`based upon the desired pressure setpoint and a pressure adjustment factor.
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
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`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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.
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the method
`of calculating a pressure target based upon the desired pressure setpoint and a pressure adjustment factor, wherein an inflate
`pressure adjustment factor is used to calculate the pressure target when the initial pressure within the pump housing is less
`than the desired pressure setpoint.
`
`The one or more processors in conjunction with the source code calculate the pressure target using an inflate pressure
`adjustment factor when the initial pressure within the pump housing is less than the desired pressure setpoint.
`
`
`
`(1e) wherein an
`inflate pressure
`adjustment factor is
`used to calculate the
`pressure target when
`the initial pressure
`within the pump
`housing is less than
`the desired pressure
`setpoint, and
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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
`
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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 an inflate pressure
`adjustment factor is used to calculate the pressure target when the initial pressure within the pump housing is less than the
`desired pressure setpoint.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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 C1: U.S. PATENT NO. 8,769,747 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.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`35
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`

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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Each Accused Product fulfills the limitations set forth in this claim. Specifically, each Accused Product practices the method
`of calculating a pressure target based upon the desired pressure setpoint and a pressure adjustment factor, wherein an inflate
`pressure adjustment factor is used to calculate the pressure target when the initial pressure within the pump housing is less
`than the desired pressure setpoint, and wherein a deflate pressure adjustment factor is used to calculate the pressure target
`when the initial pressure within the pump housing is greater than the desired pressure setpoint
`
`The one or more processors in conjunction with source code calculate the pressure target using a deflate pressure adjustment
`factor when the initial pressure within the pump housing is greater than the desired pressure setpoint.
`
`CLAIM LANGUAGE
`
`(1f) wherein a
`deflate pressure
`adjustment factor is
`used to calculate the
`pressure target when
`the initial pressure
`within the pump
`housing is greater
`than the desired
`pressure setpoint
`
`
`
`
`
`36
`
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`Sleep Number Corp.
`EXHIBIT 2075
`IPR2019-00514
`Page 36
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`

`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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
`
`37
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`

`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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 a deflate pressure
`adjustment factor is used to calculate the pressure target when the initial pressure within the pump housing is greater than the
`desired pressure setpoint.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`38
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`

`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`39
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`

`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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.
`
`(1g) adjusting
`pressure within the
`air chamber until a
`sensed pressure
`within the pump
`housing is
`
`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 sensed pressure within the pump housing is equal to the calculated pressure
`target.
`
`For example, one or more processors in conjunction with the source code may adjust the pressure within the air chamber by
`activating an inflate/deflate cycle. The one or more processors in conjunction with the source code may adjust pressure within
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`40
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`EXHIBIT 2075
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`

`

`CLAIM LANGUAGE
`
`substantially equal
`to the calculated
`pressure target
`
`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`the air chamber until a pressure sensed within the manifold is within an acceptable pressure target error range of the manifold
`pressure target.
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`41
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`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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).
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`42
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`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 sensed pressure within the pump housing is substantially equal to the calculated pressure target.
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`43
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`Page 43
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`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`44
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`EXHIBIT 2075
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`

`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`45
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`EXHIBIT 2075
`IPR2019-00514
`Page 45
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`

`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`46
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`Sleep Number Corp.
`EXHIBIT 2075
`IPR2019-00514
`Page 46
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`

`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`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.
`
`(1h) 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
`
`47
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`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`
`
`
`
`
`
`
`
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`48
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`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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
`
`
`
`49
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
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`Sleep Number Corp.
`EXHIBIT 2075
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`Page 49
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`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`Pressure
`Transducer
`
`
`
`
`
`
`
`Circuit Board
`of Processor
`
`
`
`50
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`Sleep Number Corp.
`EXHIBIT 2075
`IPR2019-00514
`Page 50
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`

`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 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).
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`51
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`EXHIBIT 2075
`IPR2019-00514
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`

`

`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`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
`
`52
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`HIGHLY CONFIDENTIAL SOURCE CODE - OUTSIDE COUNSEL ONLY
`
`53
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`EXHIBIT 2075
`IPR2019-00514
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`EXHIBIT C1: U.S. PATENT NO. 8,769,747 VERSUS AMERICAN NATIONAL MANUFACTURING ACCUSED PRODUCTS
`
`CLAIM LANGUAGE
`
`INFRINGEMENT CONTENTIONS FOR ACCUSED PRODUCTS
`
`This limitation may further