IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`UNILOC 2017 LLC and UNILOC USA, INC.,
`
`Plaintiffs,
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Civil Action No. 2:18-CV-00552-JRG-RSP
`
`DEFENDANT’S INITIAL INVALIDITY CONTENTIONS
`AND P.R. 3-3 AND 3-4 DISCLOSURES
`
`74627033.1
`
`Google v. Uniloc, IPR2020-000756
`Uniloc's Exhibit 2001
`
`

`

`TABLE OF CONTENTS
`
`I. 
`
`PRELIMINARY MATTERS.................................................................................................. 1 
`A.  Asserted Claims .................................................................................................................. 1 
`B.  Uniloc’s Infringement Contentions ..................................................................................... 1 
`C.  Ongoing Discovery and Claim Construction ...................................................................... 4 
`D.  Prior Art Identification and Citation ................................................................................... 5 
`E.  Reservation of Rights .......................................................................................................... 7 
`II.  P.R. 3-3 DISCLOSURES AND CONTENTIONS ................................................................. 8 
`A.  P.R. 3-3(a) Disclosures: Identification of Items of Prior Art That Anticipate or Render
`Obvious Asserted Claims of the Asserted Patent ....................................................................... 8 
`1. 
`Prior Art Patents and Published Patent Applications ................................................... 9 
`2. 
`Prior Art Non-Patent Publications .............................................................................. 10 
`3. 
`Prior Art Systems ....................................................................................................... 23 
`B.  P.R. 3-3(b) Disclosures: Each Item of Prior Art that Anticipates and/or Renders Obvious
`the Asserted Claims in the Asserted Patent, and Obviousness Combinations and Motivations24 
`1. 
`Exemplary Prior Art Combinations ............................................................................ 24 
`2.  Motivations to Combine ............................................................................................. 26 
`3. 
`Additional References ................................................................................................ 37 
`C.  P.R. 3-3(c) Disclosures: Charts Identifying Where in Each Item of Prior Art Each
`Element of the Asserted Claim is Found .................................................................................. 37 
`1. 
`Prior Art Patents and Published Patent Applications Charted .................................... 38 
`2. 
`Prior Art Non-Patent Publications Charted ................................................................ 38 
`3. 
`Prior Art Systems Charted .......................................................................................... 39 
`D.  P.R. 3-3(d) Disclosures: Invalidity Under 35 U.S.C. § 112 .............................................. 40 
`III.  P.R. 3-4 DISCLOSURES AND CONTENTIONS ............................................................... 42 
`A.  P.R. 3-4(a) Disclosures ..................................................................................................... 42 
`B.  P.R. 3-4(b) Disclosures ..................................................................................................... 43 
`
`
`
`
`
`
`- ii -
`
`

`

`I.
`
`PRELIMINARY MATTERS
`
`Pursuant to P.R. 3-3 and 3-4 and the Docket Control Order (ECF No. 37), Defendant
`
`Google LLC (“Google” or “Defendant”) hereby discloses its P.R. 3-3 and 3-4 disclosures
`
`(“Invalidity Contentions”) in view of Plaintiff Uniloc 2017 LLC’s (“Uniloc”) P.R. 3-1 Disclosure
`
`of Asserted Claims and Infringement Contentions (“Infringement Contentions”). Google contends
`
`that each of Uniloc’s Asserted Claims (as defined below) is invalid under at least 35 U.S.C. §§
`
`102, 103, and/or 112.
`
`A.
`
`Asserted Claims
`
`U.S. Patent No. 9,564,952 (the “’952 Patent” or the “Asserted Patent”) “relates generally
`
`to technology for near field authentication of users and their computing devices.” (’952 at 1:12-
`
`13). Uniloc’s Infringement Contentions allege infringement of claims 9-12 of the Asserted Patent
`
`by Google (collectively, the “Asserted Claims”).
`
`B.
`
`Uniloc’s Infringement Contentions
`
`Google bases these Invalidity Contentions on its current understanding of the Asserted
`
`Claims in view of Uniloc’s Infringement Contentions, which are deficient in many respects.
`
`Specifically, Uniloc failed to meet its burden under at least P.R. 3-1 subparagraphs (c) and (d).
`
`First, Uniloc’s single claim chart fails to identify “where each element of each asserted
`
`claim is found within each Accused Instrumentality,” as required by P.R. 3.1(c) (emphasis added).
`
`Significantly, Uniloc’s infringement contentions purport to include previously unidentified
`
`products, including OnHub routers, in the definition of “Accused Instrumentalities” merely by
`
`naming them in the header of that single claim chart. (Uniloc Inf. Cont. at 1.) Uniloc, however,
`
`fails to provide analysis for any of these newly named products in that chart, or even discuss those
`
`products anywhere else in its infringement contentions. The only products arguably discussed in
`
`that chart are Google Nearby Messages API and Google Chromecast Guest Mode. This Court has
`
`
`
`
`
`

`

`found that, where a plaintiff seeks to chart merely an exemplary product, it must also explain in its
`
`contentions why the charted products are representative of the uncharted products. See, e.g.,
`
`Alacritech Inc. v. Centurylink, Inc., 2:16-cv-00693-JRG-RSP, 2017 WL 3007464 (E.D. Tex. July
`
`14, 2017). Google objects to Uniloc’s attempt to accuse other products without explaining how
`
`they are equivalent to Google Nearby Messages API or Google Chromecast Guest Mode—the
`
`only products arguably charted. Absent such explanation, those products are not properly accused
`
`in this case.
`
`Moreover, Uniloc fails to map even Google Nearby Messages API or Google Chromecast
`
`Guest Mode to particular limitations in claim 9. For example, claim element 9a requires “scanning
`
`a plurality of predetermined frequencies for a free frequency,” but Uniloc was unable to cite any
`
`support that Google Nearby meet that limitation. Instead, Uniloc relies on nothing more than
`
`speculation to allege that Google Nearby “should scan the allotted (or predetermined) ultrasonic
`
`frequencies” and “should follow the same procedure” allegedly disclosed in a Google patent.
`
`(Uniloc Inf. Cont. Chart at 7-9.) The same is true for element 9b, which requires “selecting the
`
`free frequency from the plurality of predetermined frequencies.” (Id. at 9-11.)
`
`Similarly, Uniloc fails to identify any “user-configurable data” included in the message
`
`transmitted by Google Nearby Messages API, and Google cannot identify how Uniloc contends
`
`element 9g is met. Uniloc identifies the PIN as non-user-configurable data for Chromecast Guest
`
`Mode, but relies on only unsupported speculation that the “K value might be different for different
`
`implementations” and thus “may be called user-configurable data.” (Uniloc Inf. Cont. Chart at
`
`21.)
`
`Uniloc also failed to provide separate charts identifying where it contends the additional
`
`element(s) of dependent claim 12 are found in the Accused Instrumentalities. Instead, it simply
`
`
`
`2
`
`

`

`states without explanation: “Refer to Claim 9d and 11.” (See Uniloc Inf. Cont. Chart at 37.) For
`
`at least these reasons, Uniloc’s infringement contentions fail to comply with the local rules.
`
`Additionally, in its claim chart, Uniloc relies upon “live testing” of a “Google Chromecast
`
`Device” in two scenarios, during which audio sound waves were purportedly recorded and later
`
`analyzed using “an application,” but Uniloc fails to provide any further details regarding the
`
`parameters of these tests and does not attach any documentation of such testing. (See Uniloc Inf.
`
`Cont. Chart at 31-33.) Figures 31-32 of the chart, which purport to be screenshots from this testing,
`
`cite to an unidentified “Exhibit,” but none of the exhibits attached appear to include those figures.
`
`Second, Uniloc does not identify whether it claims each element is present literally or under
`
`the doctrine of equivalents in each Accused Instrumentality, as required by P.R. 3-1(d). Instead,
`
`Uniloc makes the blanket assertion that “[a]ny claim element not literally present in the Accused
`
`Instrumentalities as set forth in the claims charts is found in those Instrumentalities under the
`
`doctrine of equivalents because any differences between such claim element and the Accused
`
`Instrumentalities are insubstantial and/or the Accused Instrumentalities perform substantially the
`
`same function, in substantially the same way to achieve substantially the same result as the
`
`corresponding claim element(s).” (Uniloc Inf. Cont. at 3.) This boilerplate language does not
`
`meet the notice requirement of P.R. 3-1(d). See Eolas Techs. Inc. v. Amazon.com, Inc., 2016 WL
`
`7666160, at *3 (E.D. Tex. December 5, 2016) (striking DOE contentions as insufficient under P.R.
`
`3-1(d) based on similar blanket statements).
`
`The foregoing deficiencies in Uniloc’s Infringement Contentions have unduly burdened
`
`Google and frustrated its ability to understand how Uniloc is applying the claims, and thus its
`
`ability to identify all potential bases for invalidity in these contentions. In light of these
`
`deficiencies, Google reserves all rights to challenge the reasonableness and sufficiency of Uniloc’s
`
`
`
`3
`
`

`

`Infringement Contentions. Google already raised these deficiencies in a letter dated August 5,
`
`2019, but Uniloc has yet to provide any substantive response. Google further reserves the right to
`
`seek leave to amend or supplement and to amend or supplement these Invalidity Contentions,
`
`including by disclosing additional prior art or earlier versions and/or additional evidence of the
`
`prior art disclosed herein.
`
`C.
`
`Ongoing Discovery and Claim Construction
`
`Google also bases these Invalidity Contentions on Google’s current knowledge and
`
`understanding of the Asserted Claims and review of prior art items as of the date of these Invalidity
`
`Contentions. This case is still at an early stage, and Google’s Invalidity Contentions are made
`
`without the benefit of discovery regarding the parties’ claim construction contentions, any expert
`
`discovery, or any third-party discovery. Google is diligently seeking discovery from third parties
`
`to demonstrate the inventions were known or used by others under 35 U.S.C. § 102(a), in public
`
`use and/or on-sale under 35 U.S.C. § 102(b), and/or earlier invention of the claimed inventions
`
`under 35 U.S.C. § 102(g). Accordingly, these Invalidity Contentions are provided without
`
`prejudice to Google’s right to revise, amend, correct, supplement, modify, or clarify these
`
`Invalidity Contentions. Google also reserves the right to complete its investigation and discovery
`
`of the facts, to produce subsequently discovered information, and to introduce such subsequently
`
`discovered information at the time of any hearing or trial in this action.
`
`Additionally, the Court has not yet construed the Asserted Claims. Google maps the prior
`
`art references to the Asserted Claims based on Uniloc’s apparent constructions, to the extent
`
`understood, of the Asserted Claims as advanced in Uniloc’s Infringement Contentions. However,
`
`nothing stated in these Invalidity Contentions or accompanying claim charts should be treated as
`
`an admission or suggestion that Uniloc’s apparent claim constructions are correct, or that any claim
`
`terms of the Asserted Claims are not invalid under 35 U.S.C. § 112 for being indefinite, failing to
`
`
`
`4
`
`

`

`satisfy the written description requirement, or failing to satisfy the enablement requirement. In
`
`fact, Defendants specifically deny that Uniloc’s apparent claim constructions are proper.
`
`Depending on the Court’s construction of the Asserted Claims of the Asserted Patent,
`
`and/or positions that Uniloc or its expert witness(es) may take concerning claim interpretation,
`
`infringement, and/or invalidity issues, the asserted prior art references may be of greater or lesser
`
`relevance. Given this uncertainty, the charts may reflect alternative applications of the prior art
`
`against the Asserted Claims. Thus, no chart or position taken by Google should be construed as
`
`an admission or a waiver of any particular construction of any claim term. Google also reserves
`
`the right to challenge any of the claim terms under 35 U.S.C. § 112, including, as discussed further
`
`in Section II.D below, by arguing that they are indefinite, not supported by the written description,
`
`and/or not enabled.
`
`D.
`
`Prior Art Identification and Citation
`
`The accompanying invalidity claim charts cite to particular teachings and disclosures of
`
`the prior art references as applied to features of the Asserted Claims. However, persons having
`
`ordinary skill in the art may view an item of prior art generally in the context of other publications,
`
`literature, products, and understanding. Accordingly, the cited portions are only exemplary and
`
`are intended to put Uniloc on notice of the basis for Google’s contentions. Google has endeavored
`
`to identify the most relevant portions of the references, but the references may contain additional
`
`support for particular claim limitations. Google reserves the right to rely on uncited portions of
`
`the prior art references, other documents, and/or operational systems, as well as fact and expert
`
`testimony, to provide context or to aid in understanding the cited portions of the references and
`
`interpreting the teachings of the prior art and to establish bases for combinations of certain cited
`
`references that render the Asserted Claims obvious. Google reserves the right to rely on any prior
`
`art system referenced, embodied, or described in any of the prior art references identified herein,
`
`
`
`5
`
`

`

`or which embodies any of the prior art references identified herein. Moreover, Google reserves
`
`the right to rely on inventor admissions concerning the scope of the prior art relevant to the
`
`Asserted Patent found in, inter alia, the prosecution histories of the Asserted Patent and related
`
`patents and/or patent applications, any testimony or declarations of the named inventor concerning
`
`the Asserted Patent or related patents, and any papers or evidence submitted by Uniloc in
`
`connection with this litigation, any other pending or future litigation brought by Uniloc involving
`
`the Asserted Patent or related patents, or inter partes review proceedings involving the Asserted
`
`Patent or related patents. Google also may establish what was known to a person having ordinary
`
`skill in the art through treatises, published industry standards, other publications, products, and/or
`
`testimony.
`
`Google’s identification in the prior art of claim elements recited in the preamble of any
`
`claims is not intended to indicate that any such preamble is limiting or not limiting. All such
`
`disclosures are made only to the extent the preamble is determined to be limiting.
`
`Where the invalidity claim charts cite to a particular figure in a reference, the citation
`
`should be understood to encompass the caption of the figure and other text relating to and/or
`
`describing the figure. Similarly, where the invalidity claim charts cite to particular text referring
`
`to a figure, the citation should be understood to include the figure and related figures as well.
`
`The prior art references listed herein and in the accompanying claim charts may disclose
`
`the elements of the Asserted Claims explicitly and/or inherently. The prior art references are also
`
`relevant for their showing of the state of the art and reasons and motivations for making
`
`improvements, additions, and combinations. The suggested obviousness combinations are
`
`provided in the alternative to Google’s anticipation contentions and are not to be construed to
`
`suggest that any reference is not itself anticipatory.
`
`
`
`6
`
`

`

`Further, the combinations of prior art references contained herein demonstrating the
`
`obviousness of the Asserted Patent under 35 U.S.C. § 103 are merely exemplary and are not
`
`intended to be exhaustive. All such combinations are intended to include and be in view of the
`
`knowledge of a person of ordinary skill in the art. Additional obviousness combinations of the
`
`identified prior art references are possible, and Google reserves the right to use any such
`
`combination(s) in this action. In particular, Google is currently unaware of the extent, if any, to
`
`which Uniloc will contend that limitations of any particular claim(s) are not disclosed in the art
`
`that Google has identified as anticipatory. To the extent that Uniloc does so, Google reserves the
`
`right to identify other evidence or references that anticipate or render obvious the particular
`
`claim(s).
`
`Nothing in these Invalidity Contentions should be treated as an admission that any of
`
`Google’s accused instrumentalities meet any limitation of the Asserted Claims. Google denies
`
`infringing the Asserted Claims. To the extent that any prior art references identified by Google
`
`contain a claim element that is the same as or similar to an element in an Accused Instrumentality,
`
`based on a claim construction inferred from Uniloc’s Infringement Contentions, inclusion of that
`
`reference in Google’s Invalidity Contentions is not a waiver by Google of any claim construction
`
`or non-infringement position, nor is it an admission or suggestion by Google that any accused
`
`instrumentality satisfies the limitations of the Asserted Claims under a proper construction of those
`
`claims.
`
`E.
`
`Reservation of Rights
`
`Google reserves all rights to further supplement or modify these Invalidity Contentions,
`
`including the prior art disclosed and stated grounds of invalidity, in accordance with the Court’s
`
`Orders, the Local and Patent Rules of the Eastern District of Texas, and/or the Federal Rules of
`
`Civil Procedure as this action progresses and additional information is obtained. In addition,
`
`
`
`7
`
`

`

`Google reserves the right to prove invalidity of the Asserted Claims on bases other than those
`
`required to be disclosed in these disclosures and contentions pursuant to P.R. 3-3.
`
`Subject to the foregoing statements and qualifications, Google provides the following:
`
`II.
`
`P.R. 3-3 DISCLOSURES AND CONTENTIONS
`A.
`
`P.R. 3-3(a) Disclosures: Identification of Items of Prior Art That Anticipate or
`Render Obvious Asserted Claims of the Asserted Patent
`
`Subject to Google’s reservation of rights, the following prior art patents, printed
`
`publications, and systems, alone and/or in combination, anticipate and/or render obvious the
`
`Asserted Claims of the Asserted Patent, and/or provide evidence and background regarding the
`
`level of skill and knowledge in the art.
`
`Discovery, however, is ongoing, and Google’s prior art investigation and third party
`
`discovery are therefore not yet complete. Google reserves the right to present additional items of
`
`prior art under 35 U.S.C. § 102(a), (b), (e), (f) and/or (g), and/or § 103 located during the course
`
`of discovery or further investigation. For example, Google expects to issue and has issued
`
`subpoenas to third parties believed to have knowledge, documentation, and/or corroborating
`
`evidence concerning some of the prior art listed in this and the following sections and/or additional
`
`prior art. These third parties include, without limitation, the authors, inventors, or assignees of the
`
`references listed in these disclosures. In addition, Google reserves the right to assert invalidity
`
`under 35 U.S.C. § 102(c) or (d) to the extent that discovery or further investigation yields
`
`information forming the basis for such invalidity.
`
`Google also contends that the Asserted Claims are invalid in view of public knowledge and
`
`uses and/or offers for sale or sales of products and services that are under 35 U.S.C. § 102(a) and/or
`
`35 U.S.C. § 102(b) and/or prior inventions made in this country by other inventors who had not
`
`abandoned, suppressed, or concealed them under 35 U.S.C. § 102(g), and that anticipate or render
`
`
`
`8
`
`

`

`obvious the Asserted Claims. Google reserves the right to rely upon any system, public knowledge
`
`or use embodying or otherwise incorporating any of the prior art disclosed below, alone or in
`
`combination. Google further reserves the right to rely upon any other documents or references
`
`describing any such system, knowledge, or use. By way of example, and without limitation,
`
`Google reserves the right to rely upon any system implementing the standards, requirements
`
`documents, or specifications disclosed herein, and reserves the right to rely upon the standards and
`
`other documents describing the system to establish the operation of the system.
`
`1.
`
`Prior Art Patents and Published Patent Applications
`
`Patent No.
`
`US 5,197,093
`US 5,490,216
`US 6,205,334
`US 8,514,662
`US 8,532,644
`US 8,837,257
`US 8,862,156
`US 8,909,184
`US 9,183,552
`US 9,159,066
`US 9,264,151
`US 9,564,952
`US 9,595,043
`US 10,255,614
`US 2008/0279047
`
`Country
`of Origin
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`
`Issue/Publication
`Date1
`March 23, 1993
`February 6, 1996
`March 20, 2001
`August 20, 2013
`September 10, 2013
`September 16, 2014
`October 14, 2014
`December 9, 2014
`November 10, 2015
`October 13, 2015
`February 16, 2016
`February 7, 2017
`March 14, 2017
`April 9, 2019
`November 13, 2008
`
`1 As indicated, the “date” provided is the date required to be identified by Patent Rule 3-3(a). For
`example, for patents, “date” refers to date of issue. For publications, “date” refers to the date of
`publication. Nothing in the date column is intended to be a limitation on the availability of the
`particular patent, reference, product, or knowledge as “prior art.”
`
`9
`
`

`

`Patent No.
`
`US 2009/0171851
`US 2010/0053169
`US 2011/0029359
`US 2011/0258121
`US 2012/0051187
`US 2012/0134238
`US 2013/0065524
`US 2013/0078988
`US 2013/0079058
`US 2013/0288723
`US 2014/0051352
`US 2014/0153491
`US 2014/0369169
`US 2015/0008756
`WO 97/31437
`WO 2012/136112
`
`Country
`of Origin
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`U.S.
`P.R.C.
`
`Issue/Publication
`Date1
`July 2, 2009
`March 4, 2010
`February 3, 2011
`October 20, 2011
`March 1, 2012
`May 31, 2012
`March 14, 2013
`March 28, 2013
`March 28, 2013
`October 31, 2013
`February 20, 2014
`June 5, 2014
`December 18, 2014
`January 8, 2015
`August 28, 1997
`October 11, 2012
`
`2.
`
`Prior Art Non-Patent Publications
`
`Title
`2-clickAuth – Optical Challenge-
`Response Authentication
`
`Acoustic Communication System
`Using Mobile Terminal
`Microphones
`
`Publication Date
`2010
`
`2006
`
`Author/ Publisher
`Anna Vapen, David
`Byers, Nahid
`Shahmehri, IEEE
`Computer Soc`iety,
`2010 Int’l Conference
`on Availability,
`Reliability and Security,
`pp. 79-86
`Hosei Matsuoka,
`Yusuke Nakashima and
`Takeshi Yoshimura,
`NTT DoCoMo Tech. J,
`vol. 8, no. 2, pp. 2–12
`
`10
`
`

`

`Title
`Acoustic Data Transmission Based
`on Modulated Complex Lapped
`Transform
`
`Acoustic Modems for Ubiquitous
`Computing
`
`Acoustic Ruler [Online]
`
`Aerial Acoustic Communications
`
`An Overview of the IEEE
`802.15.4a Standard
`
`Audio Networking: The Forgotten
`Wireless Technology
`
`BeepBeep: A High Accuracy
`Acoustic Ranging System using
`COTS Mobile Devices
`
`Bringing Cell-Phone Location-
`Sensing Indoors
`
`Publication Date
`January 2010
`
`July-September
`2003
`
`2011
`
`2001
`
`January 2010
`
`July-September
`2005
`
`2007
`
`August 31, 2010
`
`Author/ Publisher
`Hwan Sik Yun, Kiho
`Cho, and Nam Soo Kim
`in the IEEE Signal
`Processing Letters, vol.
`17, no. 1, pp. 67-70
`Cristina Videira Lopes
`and Pedro M.Q. Aguiar,
`Pervasive Computing,
`vol. 2, no. 3, pp. 62-71
`Available at
`https://iqtainment.wordp
`ress.com/acoustic-ruler/
`Cristina Videira Lopes,
`Pedro M.Q. Aguiar,
`Proc. IEEE WASPAA,
`pp. 219–222
`Eirini Karapistoli,
`Fotini-Niovi Pavlidou,
`Ioannis Gragopoulos
`and Ioannis Tsetsinas,
`IEEE Communications
`Magazine, pp. 47-53
`Anil Madhavapeddy,
`David Scott, Alastair
`Tse and Richard Sharp,
`Pervasive Computing,
`pp. 55-60
`Chunyi Peng, Guobin
`Shen, Yongguang
`Zhang, Yanlin Li, Kun
`Tan, Proc. ACM
`SenSys, pp. 1–14
`Tom Simonite, available
`at
`https://www.technologyr
`eview.com/s/420582/bri
`nging-cell-phone-
`location-sensing-
`indoors/
`
`11
`
`

`

`Title
`Designing an Ultrasonic Modem
`for Robotic Communication，
`ARL-TR-4754
`Digital Acoustic Image
`Transmission System for Deep-
`Sea Research Submersible
`Dhwani: Secure Peer-to-Peer
`Acoustic NFC
`
`Efficient Multiple-Access
`Communications Using Mult-User
`Chirp Modulation Signals
`
`HTML5 Geolocation
`IEEE Standard for Information
`technology - Telecommunications
`and information exchange between
`systems - Local and metropolitan
`area networks - Specific
`requirements; IEEE 802.15.4a,
`Part 15.4: Low-Rate Wireless
`Personal Area Networks
`(WPANs); Amendment 1: Add
`Alternate PHYs
`IEEE Standard for Local and
`metropolitan area networks—
`Part 15.4: Low-Rate Wireless
`Personal Area Networks (LR-
`WPANs); IEEE Std 802.15.4™
`The Impulse Economy;
`Understanding Mobile Shoppers
`and What Makes Them Buy
`(Excerpts about Shopkick)
`Indoor Pseudo-ranging of Mobile
`Devices using Ultrasonic Chirps
`
`Author/ Publisher
`Justin Shumaker in
`Army Research Lab
`
`Publication Date
`March 2009
`
`1992
`
`2013
`
`Michiya Suzuki,
`Takashi Sasaki and
`Toshio Tsuchiya
`Rajalakshmi
`Nandakumar, Krishna
`Chintalapudi, Venkata
`N. Padmanabhan, Proc.
`ACM SIGCOMM, pp.
`63–74
`Said E. El-Khamy,
`Shawki E. Shaaban,
`Essam A. Thabet, Proc.
`IEEE ISSSTA, vol. 3,
`pp. 1209–1213.
`Anthony T. Holdener III May 2011
`IEEE Computer Society 2007
`
`1996
`
`IEEE Computer Society 2011
`
`Gary Schwartz, Atria
`Books, pp. 43, 116-117
`
`October 2011
`
`Patrick Lazik, Anthony
`Rowe, Proc. ACM
`SenSys
`
`2012
`
`12
`
`

`

`Publication Date
`2011
`
`February 10, 2012
`
`October 26, 2011
`
`April 19, 2011
`February 1998
`
`July 1974
`
`2011
`
`2007
`
`Title
`Intelligent Mobile User Interface
`
`Interview: Jonathan Glanz, CEO
`Sonic Notify Explains the
`Inaudible Frequency Technology
`and How It Served the New York
`Fashion Week
`
`Author/ Publisher
`Jussi Maaniitty, Masters
`Thesis at University of
`Tampere
`Otilia Otlacan, available
`at
`ttps://otilia.pro/...athan-
`glanz-ceo-sonic-notify-
`explains-the-inaudible-
`frequency-technology-
`and-how-it-served-the-
`new-york-fashion-week/
`Sonic Press Release,
`PRWeb
`
`Introducing the Sonic Live
`platform, Powered by the Sonic
`Notify Technology
`Introduction to NFC; Version 1.0 Nokia
`ITU-T Recommendation V.34:
`ITU
`SERIES V: DATA
`COMMUNICATION OVER THE
`TELEPHONE NETWORK -
`Interfaces and voiceband modems;
`A modem operating at data
`signalling rates of up to 33 600
`bit/s for use on the
`generalswitched telephone
`network and on leased point-to-
`point 2-wire telephone-type
`circuits
`Linear FM Signal Formats for
`Beacon and Communication
`Systems
`
`Location-Based Marketing for
`Dummies
`Microchip PIC18F1220/1320
`18/20/28-Pin High-Performance,
`Enhanced Flash MCUs with 10-bit
`A/D,DS30009605G
`
`Charles E. Cook, IEEE
`Transactions on
`Aerospace and
`Electronic Systems, vol.
`AES-10, no. 4, pp. 471-
`478
`Aaron Strout and Mike
`Schneider
`Microchip
`
`13
`
`

`

`Title
`minimodem - general-purpose
`software audio FSK modem for
`GNU_Linux systems (MKV file)
`Minimodem Audio FSK Modem
`Archive.Org Snapshot
`Mobile Computing Systems and
`Applications
`
`Mobile Token-Based
`Authentication on Budget
`
`Mobile Token-Based
`Authentication on Budget
`presentation
`Naratte’s Zoosh Does NFC
`Without the NFC Part
`
`Naratte’s Zoosh enables NFC with
`just a speaker and microphone
`
`Near Field Communication (NFC)
`Technology and Measurements
`White Paper; 1MA182_5e
`Near Ultrasonic Directional Data
`Transfer for Modern Smartphones
`
`New Zoosh technology provides
`NFC capabilities without the chip
`
`Author/ Publisher
`Kamal Mostafa
`
`Publication Date
`July 5, 2011
`
`Kamal Mostafa, Whence October 28, 2012
`
`July – September
`2011
`
`2011
`
`March 1, 2011
`
`June 20, 2011
`
`June 19, 2011
`
`June 2011
`
`September 17-21,
`2011
`
`June 22, 2011
`
`Nicholas Shekin and
`Jaewoo Chung,
`Pervasive Computing,
`pp. 80-83
`Hristo Bojinov and Dan
`Boneh of Stanford
`University
`Stanford Computer
`Security Lab
`
`Harry McCracken,
`available at
`https://www.technologiz
`er.com/2011/06/20/narat
`tes-zoosh-does-nfc-
`with...
`Devindra Hardawar,
`available at
`https://venturebeat.com/
`2011/06/19/narattes-
`zoosh-enables-nfc-with-
`just-a-speaker-and-
`microphone/
`Roland Minihold, Rohde
`& Schwarz
`
`Will Archer Arentz and
`Udana Bandara of
`Rakuten Institute of
`Technology
`Bob Yirka, available at
`https://phys.org/news/20
`11-06-zoosh-
`technology-nfc-
`capabilitieschip.
`
`14
`
`
`
`

`

`Title
`
`On Covert Acoustical Mesh
`Networks in Air
`
`On the Utility of Chirp
`Modulation for Digital Signaling
`
`Optimum Detection and Signal
`Selection for Partially Coherent
`Binary Communication
`
`Sensor-Assisted Mobile Phone
`Localization
`Seven Technologies Behind
`Mobile Payments
`
`Shopkick Press Release: shopkick
`App Now Available on the App
`Store
`Shopkick Press Release: Big News
`for Small Businesses: shopkick
`and Citi Onboard First 1,000 Local
`Stores In 10 Cities For Free
`Shopkick Brings In-Store Mobile
`Coupons To Android Phones
`
`Shopkick FAQs | Thanks for
`asking!
`
`Author/ Publisher
`html
`Michael Hanspach and
`Michael Goetz, J. of
`Commun., vol. 8, no. 11
`Albert J. Berni and
`William D. Gregg, IEEE
`Transactions on
`Communications, vol.
`21, no. 6, pp. 748-751
`Andrew Viterbi, IEEE
`Trans. Inform. Theory,
`vol. 11, no. 2, pp. 239–
`246
`Ionut Constandache of
`Duke University
`John Adams, available
`at
`https://www.americanba
`nker.com/news/seven-
`technologies-behind-
`mobile-payments
`Shopkick
`
`Publication Date
`
`2013
`
`June 1973
`
`1965
`
`2011
`
`August 1, 2011
`
`August 17, 2010
`
`Shopkick
`
`June 21, 2011
`
`November 18, 2010
`
`December 2010
`
`Leena Rao, available at
`https://web.archive.org/
`web/20101221235445/h
`ttp://techcrunch.com/20
`10/11/18/shopkick-
`brings-in-store-mobile-
`coupons-to-android-
`phones/
`Shopkick, available at
`https://web.archive.org/
`
`15
`
`

`

`Title
`Did Shopkick Just Change The
`Check-In Game? You Be The
`Judge [Video]
`
`Shopkick Kicks Off Automatic
`Checkins at Retail Locations
`
`Shopkick Teams With Best Buy to
`End Fake Retail Check-Ins
`
`Short-Range Ultrasonic
`Communications in Air Using
`Quadrature Modulation
`
`Software Acoustic Modems for
`Short Range Mote-based
`Underwater Sensor Networks
`
`Simultaneous measurement of
`impulse response and distortion
`with a swept-sine technique
`Demo: Sonic Notify
`
`SoundLink Underwater Acoustic
`Modems High Speed, Power
`Efficient, Highly Robust
`Stepping Up Smartphone
`Checkouts
`
`Author/ Publisher
`MG Siegler, available at
`https://web.archive.org/
`web/20101229021754/h
`ttp://techcrunch.com/20
`10/08/03/shopkick/
`Jolie O’Dell, available
`at
`https://mashable.com/20
`10/08/03/shopkick/
`MG Siegler, available at
`https://web.archive.org/
`web/20110104153515/h
`ttp://techcrunch.com/20
`10/08/03/shopkick-best-
`buy
`Chuan Li, David A.
`Hutchins, and Roger J.
`Green in IEEE
`Transactions on
`Ultrasonics,
`Ferroelectrics, and
`Frequency Control, vol.
`56, no. 10, October 2009
`Raja Jurdak, Cristina
`Videira Lopes, Pierre
`Baldi of California
`Institute for
`Telecommunicateions
`and Information
`Technology Calit2
`Angelo Farina, Proc.
`Audio Engineering
`Society Convention
`Sonic, available at
`https://www.wtn.net/con
`tent/demo-sonic-notify
`LinkQuest Inc.
`
`Publication Date
`August 3, 2010
`
`August 3, 2010
`
`August 3, 2010
`
`October 2009
`
`2006
`
`2000
`
`October 25, 2011
`
`June 15, 2009
`
`Don Clark, available at
`https://www.wsj.com/art
`
`June 20, 2011
`
`16
`
`

`

`Title
`
`Teledyne Benthos Acoustic
`Modems
`
`Things That Talk
`
`Things that talk: Using sound for
`device-to-device and device-to-
`human communication
`
`TIA Standard: Interface Between
`Data Terminal Equipment and
`Data Circuit – Terminating
`Equipment Employing Serial
`Binary Data Interchange
`Ultrasonic Digital Communication
`System for a Steel Wall Multipath
`Channel: Methods and Results
`
`Underwater Acoustic
`Communication Channels:
`Propa