Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Claim
`22. A device
`comprising:
`
`Exemplary Infringement Evidence1
`To the extent the preamble is limiting, the ’619 accused products satisfy this limitation. As shown below by the exemplary evidence, the ’619 accused
`products are devices comprising a radio, a processor, and memory.
`
`When Apple or its customers and/or users turn on and use the ’619 accused products, or when the ’619 accused products are tested, the claimed apparatus
`is used and directly infringed. Technical and/or user documentation is generally provided with the ’619 accused products themselves, available on
`Apple’s website, provided at Apple conferences and trade shows, or otherwise provided directly or indirectly to the user that instruct, describe, educate,
`encourage, and/or explain how to operate ’619 accused products in an infringing manner, as shown for example by the exemplary documentation cited in
`this chart. By way of example, Apple’s user manuals and documentation instruct, promote, and encourage the use of the accused products’ capability in
`an infringing manner, including setting up the Apple Watch. See, e.g., https://support.apple.com/en-us/HT204505. The claimed apparatus is used when the
`’619 accused products are activated as part of design and development activities (e.g. interoperability, compliance, certification, reliability and quality
`control testing), and/or otherwise operated by Apple or other users of the ’619 accused products. In addition, Apple makes, sells, offers for sale, and/or
`imports into the United States the claimed apparatus. Apple is liable, directly and indirectly, including for inducement, for infringement of the asserted
`apparatus claims.
`
`22.1 a radio;
`
`The ’619 accused products satisfy this limitation. As shown by the exemplary evidence below, the ’619 accused products include a radio. Appendix A,
`which is incorporated here by reference, provides further evidence and support that the ’619 accused products include a radio.
`
`1 These infringement contentions are prepared with publicly available information. SEVEN’s investigation is ongoing and discovery is in its preliminary stages. SEVEN hereby incorporates by reference the cover
`pleading to which this claim chart is attached. SEVEN reserves the right to amend or supplement these contentions after further investigation and discovery from SEVEN and non-parties. Such supplemental
`information may include, but is not limited to, source code, data sheets, design specifications, deposition testimony, testing information, reference designs, implementation and utilization information, and/or
`schematics. SEVEN also reserves the right to assert additional claims of the SEVEN patents-in-suit, accuse different products, or find alternative literal and/or equivalent infringing elements in Defendant’s products.
`Under the proper construction of the asserted claims and their claim terms, each limitation of the asserted claims is literally present in the accused products or acts accused of infringing the claim. Any and all
`elements found not to be literally infringed are infringed under the doctrine of equivalents because the differences between the claimed inventions and the accused instrumentalities, if any, are insubstantial. SEVEN
`further reserves the right to accuse different products, or find alternative literal and/or equivalent infringing elements in Defendant’s products, based on further investigation and discovery, the claim construction
`process before the Court, or other circumstances so meriting. In addition, Defendant has not yet advised SEVEN of any non-infringement arguments, as to this or any other claim limitation. If and when Defendant
`does so, SEVEN will address such arguments, including by providing any appropriate additional discussion pertaining to the application of the doctrine of equivalents with respect to Defendant’s argument
`concerning non-infringement.
`
`1
`
`APPLE 1011
`
`1
`
`
`
`Claim
`22. A device
`comprising:
`
`Exemplary Infringement Evidence1
`To the extent the preamble is limiting, the ’619 accused products satisfy this limitation. As shown below by the exemplary evidence, the ’619 accused
`products are devices comprising a radio, a processor, and memory.
`
`When Apple or its customers and/or users turn on and use the ’619 accused products, or when the ’619 accused products are tested, the claimed apparatus
`is used and directly infringed. Technical and/or user documentation is generally provided with the ’619 accused products themselves, available on
`Apple’s website, provided at Apple conferences and trade shows, or otherwise provided directly or indirectly to the user that instruct, describe, educate,
`encourage, and/or explain how to operate ’619 accused products in an infringing manner, as shown for example by the exemplary documentation cited in
`this chart. By way of example, Apple’s user manuals and documentation instruct, promote, and encourage the use of the accused products’ capability in
`an infringing manner, including setting up the Apple Watch. See, e.g., https://support.apple.com/en-us/HT204505. The claimed apparatus is used when the
`’619 accused products are activated as part of design and development activities (e.g. interoperability, compliance, certification, reliability and quality
`control testing), and/or otherwise operated by Apple or other users of the ’619 accused products. In addition, Apple makes, sells, offers for sale, and/or
`imports into the United States the claimed apparatus. Apple is liable, directly and indirectly, including for inducement, for infringement of the asserted
`apparatus claims.
`
`22.1 a radio;
`
`The ’619 accused products satisfy this limitation. As shown by the exemplary evidence below, the ’619 accused products include a radio. Appendix A,
`which is incorporated here by reference, provides further evidence and support that the ’619 accused products include a radio.
`
`1 These infringement contentions are prepared with publicly available information. SEVEN’s investigation is ongoing and discovery is in its preliminary stages. SEVEN hereby incorporates by reference the cover
`pleading to which this claim chart is attached. SEVEN reserves the right to amend or supplement these contentions after further investigation and discovery from SEVEN and non-parties. Such supplemental
`information may include, but is not limited to, source code, data sheets, design specifications, deposition testimony, testing information, reference designs, implementation and utilization information, and/or
`schematics. SEVEN also reserves the right to assert additional claims of the SEVEN patents-in-suit, accuse different products, or find alternative literal and/or equivalent infringing elements in Defendant’s products.
`Under the proper construction of the asserted claims and their claim terms, each limitation of the asserted claims is literally present in the accused products or acts accused of infringing the claim. Any and all
`elements found not to be literally infringed are infringed under the doctrine of equivalents because the differences between the claimed inventions and the accused instrumentalities, if any, are insubstantial. SEVEN
`further reserves the right to accuse different products, or find alternative literal and/or equivalent infringing elements in Defendant’s products, based on further investigation and discovery, the claim construction
`process before the Court, or other circumstances so meriting. In addition, Defendant has not yet advised SEVEN of any non-infringement arguments, as to this or any other claim limitation. If and when Defendant
`does so, SEVEN will address such arguments, including by providing any appropriate additional discussion pertaining to the application of the doctrine of equivalents with respect to Defendant’s argument
`concerning non-infringement.
`
`1
`
`APPLE 1011
`
`1
`
`
`
`Claim
`
`Exemplary Infringement Evidence1
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`https://www.apple.com/iphone-xr/specs/
`
`The ’619 accused products satisfy this limitation. As shown by the exemplary evidence below, the ’619 accused products include a processor and memory
`containing instructions executable by the processor. Appendix A, which is incorporated here by reference, provides further evidence and support that the
`’619 accused products include a processor and memory containing instructions executable by the processor.
`
`
`
`
`22.2 a processor and
`memory containing
`instructions
`executable by the
`processor whereby
`the device is operable
`to:
`
`https://www.apple.com/iphone-xr/specs/
`
`
`
`
`
`
`2
`
`2
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Claim
`
`22.3 optically receive
`information including
`a displayed service
`activation code from
`a remote device;
`
`Exemplary Infringement Evidence1
`https://www.apple.com/iphone-xr/specs/
`
`The ’619 accused products satisfy this limitation. The ’619 accused products include a processor and memory containing instructions executable by the
`processor whereby the device is operable to optically receive information including a displayed service activation code from a remote device. For
`example, the ’619 accused products optically receive a service activation code from a remote device, such as for example an Apple Watch, as shown by
`the exemplary documentation below.
`
`
`https://support.apple.com/en-us/HT204505
`
`
`
`
`3
`
`3
`
`
`
`Claim
`
`Exemplary Infringement Evidence1
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`The ’619 accused products satisfy this limitation. The ’619 accused products include a processor and memory containing instructions executable by the
`processor whereby the device is operable to register the remote device for access to a messaging account using the service activation code. The ’619
`accused products register, for example an Apple Watch, for access to for example text messages and/or email, as shown by the exemplary documentation
`below.
`
`
`22.4 register the
`remote device for
`access to a messaging
`account using the
`service activation
`code;
`
`https://support.apple.com/en-us/HT205783
`
`
`
`
`4
`
`4
`
`
`
`Claim
`
`Exemplary Infringement Evidence1
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`22.5 receive a
`message for the
`messaging account;
`
`https://support.apple.com/guide/watch/read-mail-apddca457a4f/watchos
`
`The ’619 accused products satisfy this limitation. The ’619 accused products include a processor and memory containing instructions executable by the
`processor whereby the device is operable to receive a message for the messaging account. For example, the ’619 accused products receive a message for
`the messaging account, as shown by the exemplary documentation below.
`
`
`
`
`https://support.apple.com/en-us/HT201287
`
`
`
`5
`
`5
`
`
`
`Claim
`
`Exemplary Infringement Evidence1
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`https://support.apple.com/en-us/HT205783
`
`
`https://support.apple.com/guide/watch/read-mail-apddca457a4f/watchos
`
`
`
`
`
`
`6
`
`6
`
`
`
`Claim
`
`Exemplary Infringement Evidence1
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`
`
`22.6 encrypt the
`message using an
`
`https://support.apple.com/guide/watch/manage-mail-apd29461a7b7/watchos
`
`The ’619 accused products satisfy this limitation. The ’619 accused products include a processor and memory containing instructions executable by the
`processor whereby the device is operable to encrypt the message using an encryption key and send the message to the remote device. For example, the
`
`
`
`7
`
`7
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Claim
`encryption key; and
`send the message to
`the remote device,
`
`Exemplary Infringement Evidence1
`’619 accused products encrypt the messages and send them to the remote device, such as for example an Apple Watch, as shown by the exemplary
`documentation below.
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`The ’619 accused products satisfy this limitation. For example, the device is authenticated to access the messaging account, as shown by the exemplary
`documentation below.
`
`
`
`
`22.7 wherein the
`device is
`authenticated to
`access the messaging
`account.
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`8
`
`8
`
`
`
`Claim
`
`Exemplary Infringement Evidence1
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`23. The device of
`
`https://support.apple.com/en-us/HT201320
`
`The ’619 accused products satisfy this limitation. For example, the information including the service activation code is received by the device in response
`
`
`
`9
`
`9
`
`
`
`Claim
`claim 22, wherein the
`information including
`the service activation
`code is received by
`the device in response
`to user input at the
`remote device.
`
`24. The device of
`claim 22, wherein the
`information including
`the service activation
`code is received by
`the device in an off-
`line communication.
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Exemplary Infringement Evidence1
`to user input at the remote device, as shown by the exemplary documentation below.
`
`
`
`https://www.theverge.com/2015/4/24/8489459/apple-watch-how-to-pair-setup-pay-bluetooth-contacts
`
`The ’619 accused products satisfy this limitation. For example, the information including the service activation code is received by the device in an off-
`line communication, as shown by the exemplary documentation below.
`
`
`
`
`10
`
`10
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Claim
`
`Exemplary Infringement Evidence1
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`
`https://www.theverge.com/2015/4/24/8489459/apple-watch-how-to-pair-setup-pay-bluetooth-contacts
`
`The ’619 accused products satisfy this limitation. For example, the off-line communication involves a local connection, as shown by the exemplary
`documentation below.
`
`
`25. The device of
`claim 24, wherein the
`off-line
`communication
`involves a local
`connection.
`
`
`
`11
`
`11
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Claim
`
`Exemplary Infringement Evidence1
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`26. The device of
`claim 24, wherein the
`off-line
`communication
`prevents
`eavesdropping of the
`service activation
`code.
`
`
`https://www.theverge.com/2015/4/24/8489459/apple-watch-how-to-pair-setup-pay-bluetooth-contacts
`
`The ’619 accused products satisfy this limitation. For example, the off-line communication prevents eavesdropping of the service activation code, as
`shown by the exemplary documentation below.
`
`
`
`
`12
`
`12
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Exemplary Infringement Evidence1
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`The ’619 accused products satisfy this limitation. For example, the authentication of the device relies on the authentication of the messaging account, as
`shown by the exemplary documentation below.
`
`
`Claim
`
`27. The device of
`claim 22, wherein the
`authentication of the
`device relies on the
`authentication of the
`messaging account.
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`13
`
`13
`
`
`
`Claim
`
`Exemplary Infringement Evidence1
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`28. The device of
`
`https://support.apple.com/en-us/HT201320
`
`The ’619 accused products satisfy this limitation. For example, the authentication of the messaging account includes a username and password, as shown
`
`
`
`14
`
`14
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Exemplary Infringement Evidence1
`by the exemplary documentation below.
`
`
`Claim
`claim 27, wherein the
`authentication of the
`messaging account
`includes a username
`and password.
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`15
`
`15
`
`
`
`Claim
`
`Exemplary Infringement Evidence1
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`32. The device of
`
`https://support.apple.com/en-us/HT201320
`
`The ’619 accused products satisfy this limitation. For example, the encryption key is closely related to the service activation code, as shown by the
`
`
`
`16
`
`16
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Exemplary Infringement Evidence1
`exemplary documentation below.
`
`
`Claim
`claim 22, wherein the
`encryption key is
`closely related to the
`service activation
`code.
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`The ’619 accused products satisfy this limitation. For example, the device is further operable to store an association between at least two of the encryption
`key, the messaging account, an identifier of the remote device, and the service activation code, as shown by the exemplary documentation below.
`
`
`
`
`33. The device of
`claim 22, wherein the
`device is further
`operable to: store an
`association between
`at least two of the
`encryption key, the
`
`17
`
`17
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Exemplary Infringement Evidence1
`
`Claim
`messaging account,
`an identifier of the
`remote device, and
`the service activation
`code.
`
`36. The device of
`claim 22, wherein a
`control message is
`received from the
`remote device upon
`user interaction with
`the message.
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`The ’619 accused products satisfy this limitation. For example, a control message is received from the remote device upon user interaction with the
`message, as shown by the exemplary documentation below.
`
`
`
`
`https://support.apple.com/guide/watch/read-mail-apddca457a4f/watchos
`
`
`
`18
`
`18
`
`
`
`Claim
`
`Exemplary Infringement Evidence1
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`
`
`19
`
`19
`
`
`
`Claim
`
`Exemplary Infringement Evidence1
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`
`
`
`https://support.apple.com/en-us/HT205783
`
`
`
`
`
`
`20
`
`20
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Claim
`37. A method for
`sharing a messaging
`account, the method
`comprising:
`
`Exemplary Infringement Evidence2
`To the extent the preamble is limiting, the ’619 accused products satisfy this limitation. As shown below by the exemplary evidence, the ’619 accused
`products practice a method for sharing a messaging account. For example, the ’619 accused products share a messaging account with the Apple Watch, as
`shown by the exemplary evidence below.
`
`When Apple or its customers and/or users turn on and use the ’619 accused products, or when the ’619 accused products are tested, the claimed method is
`performed. Technical and/or user documentation is generally provided with the ’619 accused products themselves, available on Apple’s website, provided
`at Apple conferences and trade shows, or otherwise provided directly or indirectly to the user that instruct, describe, educate, encourage, and/or explain
`how to operate ’619 accused products in an infringing manner, as shown for example by the exemplary documentation cited in this chart. By way of
`example, Apple’s user manuals and documentation instruct, promote, and encourage the use of the accused products’ capability in an infringing manner,
`including setting up the Apple Watch. See, e.g., https://support.apple.com/en-us/HT204505. The claimed method is performed when the ’619 accused
`products are activated as part of design and development activities (e.g. interoperability, compliance, certification, reliability and quality control testing),
`and/or otherwise operated by Apple or other users of the ’619 accused products. Apple is liable, directly and indirectly, including for inducement, for
`infringement of the asserted method claims.
`
`
`
`2 These infringement contentions are prepared with publicly available information. SEVEN’s investigation is ongoing and discovery is in its preliminary stages. SEVEN hereby incorporates by reference the cover
`pleading to which this claim chart is attached. SEVEN reserves the right to amend or supplement these contentions after further investigation and discovery from SEVEN and non-parties. Such supplemental
`information may include, but is not limited to, source code, data sheets, design specifications, deposition testimony, testing information, reference designs, implementation and utilization information, and/or
`schematics. SEVEN also reserves the right to assert additional claims of the SEVEN patents-in-suit, accuse different products, or find alternative literal and/or equivalent infringing elements in Defendant’s products.
`Under the proper construction of the asserted claims and their claim terms, each limitation of the asserted claims is literally present in the accused products or acts accused of infringing the claim. Any and all
`elements found not to be literally infringed are infringed under the doctrine of equivalents because the differences between the claimed inventions and the accused instrumentalities, if any, are insubstantial. SEVEN
`further reserves the right to accuse different products, or find alternative literal and/or equivalent infringing elements in Defendant’s products, based on further investigation and discovery, the claim construction
`process before the Court, or other circumstances so meriting. In addition, Defendant has not yet advised SEVEN of any non-infringement arguments, as to this or any other claim limitation. If and when Defendant
`does so, SEVEN will address such arguments, including by providing any appropriate additional discussion pertaining to the application of the doctrine of equivalents with respect to Defendant’s argument
`concerning non-infringement.
`
`21
`
`21
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`https://support.apple.com/en-us/HT205783
`
`
`
`
`https://support.apple.com/guide/watch/read-mail-apddca457a4f/watchos
`
`The ’619 accused products satisfy this limitation. The ’619 accused products authenticate a device for access to the messaging account. For example, the
`device is authenticated to access the messaging account, as shown by the exemplary documentation below.
`
`
`
`
`37.1 authenticating a
`device for access to
`the messaging
`account;
`
`22
`
`22
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`23
`
`23
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`37.2 optically
`
`https://support.apple.com/en-us/HT201320
`
`The ’619 accused products satisfy this limitation. The ’619 accused products optically receive information including a displayed service activation code
`
`
`
`24
`
`24
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Claim
`receiving information
`including a displayed
`service activation
`code from a remote
`device;
`
`Exemplary Infringement Evidence2
`from a remote device. For example, the ’619 accused products optically receive a service activation code from a remote device, such as for example an
`Apple Watch, as shown by the exemplary documentation below.
`
`
`https://support.apple.com/en-us/HT204505
`
`
`
`
`25
`
`25
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`The ’619 accused products satisfy this limitation. The ’619 accused products register the remote device for access to the messaging account using the
`service activation code. The ’619 accused products register, for example an Apple Watch, for access to for example text messages and/or email, as shown
`by the exemplary documentation below.
`
`
`37.3 registering the
`remote device for
`access to the
`messaging account
`using the service
`activation code;
`
`https://support.apple.com/en-us/HT205783
`
`
`
`
`26
`
`26
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`37.4 receiving a
`message for the
`messaging account;
`
`https://support.apple.com/guide/watch/read-mail-apddca457a4f/watchos
`
`The ’619 accused products satisfy this limitation. The ’619 accused products receive a message for the messaging account. For example, the ’619
`accused products receive a message for the messaging account, for example, text messages and/or email, as shown by the exemplary documentation
`below.
`
`
`
`
`https://support.apple.com/en-us/HT201287
`
`
`
`
`27
`
`27
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`https://support.apple.com/en-us/HT205783
`
`
`https://support.apple.com/guide/watch/read-mail-apddca457a4f/watchos
`
`
`
`
`
`
`28
`
`28
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`
`
`37.5 encrypting the
`message using an
`
`https://support.apple.com/guide/watch/manage-mail-apd29461a7b7/watchos
`
`The ’619 accused products satisfy this limitation. The ’619 accused products encrypt the message using an encryption key and send the message to the
`remote device. For example, the ’619 accused products encrypt the messages and send them to the remote device, such as for example an Apple Watch, as
`
`
`
`29
`
`29
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Claim
`encryption key; and
`sending the message
`to the remote device.
`
`Exemplary Infringement Evidence2
`shown by the exemplary documentation below.
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`The ’619 accused products satisfy this limitation. For example, the information including the service activation code is received by the device in response
`to user input at the remote device, as shown by the exemplary documentation below.
`
`
`
`
`38. The method of
`claim 37, wherein the
`information including
`the service activation
`code is received by
`the device in response
`to user input at the
`remote device.
`
`30
`
`30
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`
`https://www.theverge.com/2015/4/24/8489459/apple-watch-how-to-pair-setup-pay-bluetooth-contacts
`
`The ’619 accused products satisfy this limitation. For example, the information including the service activation code is received by the device in an off-
`line communication, as shown by the exemplary documentation below.
`
`
`39. The method of
`claim 38, wherein the
`information including
`the service activation
`code is received by
`the device in an off-
`line communication.
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`31
`
`31
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`40. The method of
`claim 39, wherein the
`off-line
`communication
`prevents
`eavesdropping of the
`service activation
`code.
`
`
`https://www.theverge.com/2015/4/24/8489459/apple-watch-how-to-pair-setup-pay-bluetooth-contacts
`
`The ’619 accused products satisfy this limitation. For example, the off-line communication prevents eavesdropping of the service activation code, as
`shown by the exemplary documentation below.
`
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`32
`
`32
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Exemplary Infringement Evidence2
`The ’619 accused products satisfy this limitation. For example, the authentication of the device relies on the authentication of the messaging system, as
`shown by the exemplary documentation below.
`
`
`Claim
`41. The method of
`claim 37, wherein the
`authentication of the
`device relies on the
`authentication of the
`messaging system.
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`33
`
`33
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`42. The method of
`
`https://support.apple.com/en-us/HT201320
`
`The ’619 accused products satisfy this limitation. For example, the authentication of the messaging system includes a username and password, as shown
`
`
`
`34
`
`34
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Exemplary Infringement Evidence2
`by the exemplary documentation below.
`
`
`Claim
`claim 41, wherein the
`authentication of the
`messaging system
`includes a username
`and password.
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`35
`
`35
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`46. The method of
`
`https://support.apple.com/en-us/HT201320
`
`The ’619 accused products satisfy this limitation. For example, the encryption key is closely related to the service activation code, as shown by the
`
`
`
`36
`
`36
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Exemplary Infringement Evidence2
`exemplary documentation below.
`
`
`Claim
`claim 37, wherein the
`encryption key is
`closely related to the
`service activation
`code.
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`The ’619 accused products satisfy this limitation. For example, a control message is received from the remote device upon user interaction with the
`message, as shown by the exemplary documentation below.
`
`
`
`
`50. The method of
`claim 37, wherein a
`control message is
`received from the
`remote device upon
`user interaction with
`the message.
`
`37
`
`37
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`https://support.apple.com/guide/watch/read-mail-apddca457a4f/watchos
`
`
`
`
`
`
`38
`
`38
`
`
`
`Claim
`
`Exemplary Infringement Evidence2
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`
`
`
`https://support.apple.com/en-us/HT205783
`
`
`
`
`
`
`39
`
`39
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Claim
`51. A non-transient
`computer-readable
`medium containing
`program instructions
`for causing a device
`to perform a method,
`the method
`comprising:
`
`
`51.1 optically
`receiving information
`including a displayed
`service activation
`code from a remote
`device;
`
`Exemplary Infringement Evidence3
`To the extent the preamble is limiting, the ’619 accused products satisfy this limitation. As shown below by the exemplary evidence, the ’619 accused
`products include a non-transient computer-readable medium containing program instructions for causing a device to perform a method.
`
`When Apple or its customers and/or users turn on and use the ’619 accused products, or when the ’619 accused products are tested, the claimed apparatus
`is used and directly infringed. Technical and/or user documentation is generally provided with the ’619 accused products themselves, available on
`Apple’s website, provided at Apple conferences and trade shows, or otherwise provided directly or indirectly to the user that instruct, describe, educate,
`encourage, and/or explain how to operate ’619 accused products in an infringing manner, as shown for example by the exemplary documentation cited in
`this chart. By way of example, Apple’s user manuals and documentation instruct, promote, and encourage the use of the accused products’ capability in
`an infringing manner, including setting up the Apple Watch. See, e.g., https://support.apple.com/en-us/HT204505. The claimed apparatus is used when the
`’619 accused products are activated as part of design and development activities (e.g. interoperability, compliance, certification, reliability and quality
`control testing), and/or otherwise operated by Apple or other users of the ’619 accused products. In addition, Apple makes, sells, offers for sale, and/or
`imports into the United States the claimed apparatus. Apple is liable, directly and indirectly, including for inducement, for infringement of the asserted
`apparatus claims.
`
`The ’619 accused products satisfy this limitation. The ’619 accused products optically receive information including a displayed service activation code
`from a remote device. For example, the ’619 accused products optically receive a service activation code from a remote device, such as for example an
`Apple Watch, as shown by the exemplary documentation below.
`
`
`
`3 These infringement contentions are prepared with publicly available information. SEVEN’s investigation is ongoing and discovery is in its preliminary stages. SEVEN hereby incorporates by reference the cover
`pleading to which this claim chart is attached. SEVEN reserves the right to amend or supplement these contentions after further investigation and discovery from SEVEN and non-parties. Such supplemental
`information may include, but is not limited to, source code, data sheets, design specifications, deposition testimony, testing information, reference designs, implementation and utilization information, and/or
`schematics. SEVEN also reserves the right to assert additional claims of the SEVEN patents-in-suit, accuse different products, or find alternative literal and/or equivalent infringing elements in Defendant’s products.
`Under the proper construction of the asserted claims and their claim terms, each limitation of the asserted claims is literally present in the accused products or acts accused of infringing the claim. Any and all
`elements found not to be literally infringed are infringed under the doctrine of equivalents because the differences between the claimed inventions and the accused instrumentalities, if any, are insubstantial. SEVEN
`further reserves the right to accuse different products, or find alternative literal and/or equivalent infringing elements in Defendant’s products, based on further investigation and discovery, the claim construction
`process before the Court, or other circumstances so meriting. In addition, Defendant has not yet advised SEVEN of any non-infringement arguments, as to this or any other claim limitation. If and when Defendant
`does so, SEVEN will address such arguments, including by providing any appropriate additional discussion pertaining to the application of the doctrine of equivalents with respect to Defendant’s argument
`concerning non-infringement.
`
`40
`
`40
`
`
`
`Claim
`
`Exemplary Infringement Evidence3
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`https://support.apple.com/en-us/HT204505
`
`
`
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`41
`
`41
`
`
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`Claim
`
`51.2 registering the
`remote device for
`access to a messaging
`account using the
`service activation
`code;
`
`Exemplary Infringement Evidence3
`
`The ’619 accused products satisfy this limitation. The ’619 accused products register the remote device for access to a messaging account using the
`service activation code. The ’619 accused products register, for example an Apple Watch, for access to for example text messages and/or email, as shown
`by the exemplary documentation below.
`
`
`https://support.apple.com/en-us/HT205783
`
`
`
`
`51.3 receiving a
`message for the
`messaging account;
`
`https://support.apple.com/guide/watch/read-mail-apddca457a4f/watchos
`
`The ’619 accused products satisfy this limitation. The ’619 accused products receive a message for the messaging account. For example, the ’619
`accused products receive a message for the messaging account, as shown by the exemplary documentation below.
`
`
`
`
`42
`
`42
`
`
`
`Claim
`
`Exemplary Infringement Evidence3
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`https://support.apple.com/en-us/HT201287
`
`
`
`
`https://support.apple.com/en-us/HT205783
`
`
`
`
`43
`
`43
`
`
`
`Claim
`
`Exemplary Infringement Evidence3
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`https://support.apple.com/guide/watch/read-mail-apddca457a4f/watchos
`
`
`
`
`https://www.apple.com/business/site/docs/iOS_Security_Guide.pdf
`
`
`
`
`44
`
`44
`
`
`
`Claim
`
`Exemplary Infringement Evidence3
`
`Exhibit K - Infringement of U.S. Patent No. 10,027,619
`
`https://support.apple.com/guide/watch/manage-mail-apd29461a7b7/watchos
`
`The ’619 accused products satisfy this limitation. The ’619 accused products encrypt the message using an encryption key and send the message to the
`remote device. For e
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