`
`
`
`Exhibit A-1: Infringement of U.S. Patent validity of U.S. Patent No. 7,589,642
`via the Roku TV, Roku Ultra, Roku Premiere, Roku Premiere+, Roku StreamingStick, Roku StreamingStick+, Roku 4, and any variations
`of the same that include device power and volume control functionality discussed herein
`(“Roku Streaming Products with Device Control”)
`
`
`These infringement contentions are provided based on information obtained to date and may not be exhaustive. UEI’s investigation of Roku’s
`infringement is ongoing. UEI reserves the right to seek to supplement and/or amend these disclosures to identify additional asserted claims, accused
`instrumentalities, and/or to further identify where each element of each asserted claim is found in each accused instrumentality, including on the basis
`of discovery obtained from Roku and from third-parties during the course of this litigation.
`
`The accused instrumentalities and associated documents discussed and/or cited herein are representative in all material aspects for all other accused
`instrumentalities identified in this chart. Based on information presently available to UEI, each of the Roku Streaming Products with Device Control
`is understood to operate in the same manner with respect to the contentions provided in this chart, unless otherwise noted. Roku has not yet produced
`discovery in this action, and UEI reserves the right to amend its contentions as to these products should Roku provide information showing any
`relevant differences among the products or any additional products containing the same functionality.
`
`
`US Pat. No. 7,589,642
`
`Roku Streaming Products with Device Control
`
`1. A method comprising:
`
`The Roku Streaming Products with Device Control perform when a user chooses to “Set up a remote
`for TV control.”
`
`Set up a remote for TV control:
`
`Infringement of U.S. Patent No. 7,589,642 via the Roku Streaming Products with Device Control
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`Roku EX1029
`U.S. Patent No. 7,589,642
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`US Pat. No. 7,589,642
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`Roku Streaming Products with Device Control
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`
`Additionally, at least the products comprising Roku streaming players will perform the claimed
`method when the user completes the “Control your TV” portion of the devices’ initial setup:
`
`
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`US Pat. No. 7,589,642
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`Roku Streaming Products with Device Control
`
`
`(images taken from https://support.roku.com/article/115013019828-how-do-i-set-up-my-roku-
`enhanced-remote-to-control-my-tv-, UEI_001310).
`
`See also https://support.roku.com/article/360004786894-why-is-my-roku-enhanced-remote-not-
`controlling-volume-and-power-on-my-tv-, UEI_001327 (providing instructions for setting up the
`Roku Enhanced Remote).
`
`
`
`The Roku Streaming Products with Device Control receive a keystroke indicator signal from the
`Roku remote control, wherein the keystroke indicator signal indicates a key on the Roku remote that
`the user has pressed.
`
` A
`
` user of a Roku Streaming Product presses one of the keys on the Roku remote:
`
`(a) receiving a keystroke indicator
`signal from a remote control device,
`wherein the keystroke indicator
`signal indicates a key on said remote
`control device that a user has
`selected;
`
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`(b) generating a key code within a
`key code generator device using the
`keystroke indictor signal;
`
`(c) modulating said key code onto a
`carrier signal, thereby generating a
`key code signal; and
`
`(d) transmitting said key code signal
`from said key code generator device
`to said remote control device.
`
`
`
`The Roku Streaming Products will respond (or not respond) based on which button is pressed on the
`remote control due to a signal received from the remote, which is a keystroke indicator signal.
`
`The Roku Streaming Products with Device Control are key code generators that generate a key code
`using the keystroke indicator signal.
`
`An example of a generated key code is the code that corresponds to a function of an external device,
`such as volume or power. This process occurs during set-up and regular operation of the Roku
`Streaming Products.
`
`Roku informs its customers that the Roku players narrow the list of “remote codes” during remote
`setup and program the “correct code” to the remote. (See, e.g.,
`https://support.roku.com/article/360004786894-why-is-my-roku-enhanced-remote-not-controlling-
`volume-and-power-on-my-tv-, UEI_001327 at 28).
`
`The Roku Streaming Products with Device Control can modulate key codes onto a carrier signal to
`communicate with the Roku remote. The Roku Streaming Products with Device Control
`communicate with the Roku remotes by modulating data onto wireless signals, e.g., Wi-Fi or Wi-Fi
`Direct. For example, the Roku Streaming Products with Device Control program Roku remotes with
`remote codes for TVs. (See, e.g., https://support.roku.com/article/360004786894-why-is-my-roku-
`enhanced-remote-not-controlling-volume-and-power-on-my-tv-, UEI_001327 at 28). This
`programming is conducted via sending data over a carrier signal, e.g., a wireless connection.
`
`The Roku Streaming Products with Device Control transmit said key code signal to the Roku remote.
`
`The Roku Streaming Products with Device Control program Roku remotes with remote codes for
`external devices, such as TVs. (See, e.g., https://support.roku.com/article/360004786894-why-is-my-
`roku-enhanced-remote-not-controlling-volume-and-power-on-my-tv-, UEI_001327 at 28). This
`
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`programming is conducted via sending data over a carrier signal, e.g., a wireless connection via Wi-
`Fi or Wi-Fi Direct.
`
`
`
`
`
`3. The method of claim 1, wherein
`said key code consists of a binary
`number.
`
`The key codes discussed in claim 1 consist of a binary number. The Roku Streaming Devices with
`Device Control control external devices, such as a TV, via either IR or CEC (relayed through the
`Roku device). Both IR and CEC data comprise a binary number.
`
`
`
`
`
`4. The method of claim 1, wherein
`said key code comprises a binary
`number and timing information, and
`wherein said timing information
`defines how said binary number is
`modulated in (c) onto said carrier
`signal.
`
`The key code discussed in claim 1 comprises a binary number and timing information, and wherein
`said timing information defines how said binary number is modulated in (c) onto said carrier signal.
`
`The Roku Streaming Devices with Device Control control the TV via either IR or CEC (relayed
`through the Roku device). Both IR and CEC data comprise a binary number, which represents the
`data. Both IR and CEC also require timing information in order to send the data.
`
`
`
`
`
`6. The method of claim 1, wherein
`said carrier signal is in a radio
`frequency band, wherein said key
`code signal is received by said
`remote control device, and wherein
`said method further comprises:
`
`The carrier signal discussed with respect to claim 1 is in a radio frequency band, wherein said key
`code signal is received by said the Roku remote paired with the Roku Streaming Product with Device
`Control.
`
`The Roku Streaming Products with Device Control have a remote containing a receiver to receive
`wireless signals from a Roku device via Wi-Fi or Wi-Fi Direct. See, e.g.,
`https://support.roku.com/article/360004786894-why-is-my-roku-enhanced-remote-not-controlling-
`volume-and-power-on-my-tv-, UEI_001327 (“Some Roku Enhanced Remotes incorporate both
`wireless and infrared (IR) technologies to seamlessly control both your Roku streaming player and
`your TV.”).
`
`Roku devices send key codes to the Roku Streaming Products with Device Control during at least the
`remote setup process. See, e.g., https://support.roku.com/article/115013019828-how-do-i-set-up-my-
`roku-enhanced-remote-to-control-my-tv-, UEI_001310; see also
`https://support.roku.com/article/360004786894-why-is-my-roku-enhanced-remote-not-controlling-
`volume-and-power-on-my-tv-, UEI_001327.
`
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`
`Wireless signals fall within a radio frequency band (3 KHz and 300 GHz, see, e.g.,
`https://www.rfpage.com/what-are-radio-frequency-bands-and-its-uses/).
`
`The following image, taken from a remote included with a Roku Ultra product, is representative of
`the remotes included with the Roku Streaming Products with Device Control, which allow for
`wireless communication. The photo shows that the remote includes an Ozmo2000 radio, baseband,
`and microcontroller System-on-Chip (SoC).
`
`
`
`
`
`(e) modulating said key code onto a
`second carrier signal, thereby
`
`When being used to control a TV, the Roku Streaming Products with Device Control performs the
`further step of modulating said key code onto a second carrier signal, thereby generating a second
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`generating a second key code signal,
`said modulating being performed on
`said remote control device wherein
`said second carrier signal is in an
`infrared frequency band; and
`
`
`key code signal, said modulating being performed on said remote control device wherein said second
`carrier signal is in an infrared frequency band.
`
`The Roku Streaming Products with Device Control have a transmitter that transmits signals in the
`infrared frequency band to transmit signals to TVs. See, e.g.,
`https://support.roku.com/article/360004786894-why-is-my-roku-enhanced-remote-not-controlling-
`volume-and-power-on-my-tv-, UEI_001327 (“Some Roku Enhanced Remotes incorporate both
`wireless and infrared (IR) technologies to seamlessly control both your Roku streaming player and
`your TV.”); see also https://support.roku.com/article/115012968247-can-i-control-my-tv-with-the-
`remote-for-my-roku-streaming-player-, UEI_001307 (“Some Roku enhanced remotes incorporate
`both wireless and infrared (IR) technologies to seamlessly control your Roku streaming player and
`aspects of your TV. Once you set up your Roku player and Roku enhanced remote, you can control
`volume and power on/off for select TV brands and models.”).
`
`Infrared signals fall within an infrared frequency band.
`
`The following image, taken from a remote included with a Roku Ultra product, is representative of
`the remotes included with the Roku Streaming Products with Device Control, which have an IR
`transmitter:
`
`
`
`
`
`(f) transmitting said second key code
`signal from said remote control
`device to an electronic consumer
`device.
`
`When being used to control an external device (such as a TV), the Roku Streaming Products with
`Device Control perform the further step of transmitting said second key code signal to an electronic
`consumer device (such as a TV).
`
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`US Pat. No. 7,589,642
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`Roku Streaming Products with Device Control
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`See, e.g., https://support.roku.com/article/360004786894-why-is-my-roku-enhanced-remote-not-
`controlling-volume-and-power-on-my-tv-, UEI_001327 (“Some Roku Enhanced Remotes
`incorporate both wireless and infrared (IR) technologies to seamlessly control both your Roku
`streaming player and your TV.”); see also https://support.roku.com/article/115012968247-can-i-
`control-my-tv-with-the-remote-for-my-roku-streaming-player-, UEI_001307 (“Some Roku enhanced
`remotes incorporate both wireless and infrared (IR) technologies to seamlessly control your Roku
`streaming player and aspects of your TV. Once you set up your Roku player and Roku enhanced
`remote, you can control volume and power on/off for select TV brands and models.”).
`
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