`
`U.S. Patent No. 8,749,251 (“’251 Patent”) for Sony Products
`Exemplary Accused Products
`Sony products, including at least each of the laptop products listed in Sony’s Response to Neodron’s Interrogatory No. 1, infringe at
`least Claims 1, 2, 3, 5, 7, 8, 9, 16, 17, 18, and 20 of the ’251 Patent.
`
`Claim 1
`Claim 1
`
`[pre] An apparatus
`comprising:
`
`[a] a sensing element of
`a touch screen; and
`
`Sony products
`
`The preamble is not a limitation.
`
`Each Sony product comprises a sensing element of a touch screen.
`
`For example, the Xperia XZ3 includes a capacitive touch screen.
`
`See, e.g.:
`
`Page 1
`
`Petitioners Samsung and Sony Ex-1009, 0001
`
`
`
`Claim 1
`
`Sony products
`
`
`
`Photograph of Xperia XZ3 illustrating touch screen.
`
`See also, e.g., analysis and evidence of elements 1[c] and 1[d] below.
`
`
`
`[b] one or more
`computer-readable non-
`transitory storage media
`coupled to the sensing
`element and embodying
`logic that is operable
`
`Each Sony product includes one or more computer-readable non-transitory storage media coupled to the
`sensing element and embodying logic that is operable when executed to perform the claimed method.
`
`For example, the Xperia XZ3 includes one or more touch controllers or system processors with non-
`transitory storage (e.g. Flash, EEPROM, HDD, SDD, etc.) embodying logic executable to perform the
`
`Page 2
`
`Petitioners Samsung and Sony Ex-1009, 0002
`
`
`
`Claim 1
`
`Sony products
`
`when executed to:
`
`steps described below.
`
`
`
`[c] determine an amount
`of time that has elapsed
`since the sensing
`element last detected a
`change of capacitance
`indicative of a key touch
`on the touch screen; and
`
`[d] if the amount of time
`that has elapsed exceeds
`a predetermined time
`duration, then initiate a
`particular function of the
`apparatus.
`
`Each Sony product contains executable logic to determine an amount of time that has elapsed since the
`sensing element last detected a change of capacitance indicative of a key touch on the touch screen.
`
`For example, touching the Xperia XZ3’s touch screen and then removing the touch, thereby causing a
`change of capacitance, can cause the Xperia XZ3 to respond in various ways after a delay, indicating that
`the Xperia XZ3 determines the amount of time elapsed since the touch sensor detected a touch.
`
`See, e.g., analysis and evidence of element 1[d] below.
`
`Each Sony product contains executable logic to, if the amount of time that has elapsed exceeds a
`predetermined time duration, then initiate a particular function of the apparatus.
`
`For example, the capacitive touch sensor in the Xperia XZ3 enters a different sensing mode a
`predetermined amount of time after a user’s finger is removed from the touch screen. This change is
`readily observable using a standard oscilloscope measuring the capacitive drive signals a short distance
`above the Xperia XZ3’s touch screen. There is a distinct difference between the drive signal observed
`while a finger touch is in contact with the drive signal observed after removing that touch. This difference
`likely reflects a power-saving mode initiated after the touch is removed. The change occurs after a
`consistent time offset.
`
`See, e.g.:
`
`Page 3
`
`Petitioners Samsung and Sony Ex-1009, 0003
`
`
`
`Claim 1
`
`Sony products
`
`
`
`
`Photograph of Xperia XZ3 with touch present, showing the capacitive sensing drive signal while a touch is
`detected.
`
`Page 4
`
`Petitioners Samsung and Sony Ex-1009, 0004
`
`
`
`Claim 1
`
`Sony products
`
`
`
`
`Photograph of Xperia XZ3 after touch is removed, showing the different capacitive sensing drive signal
`present following a predetermined time duration after the touch is removed.
`
`Claim 2
`Claim 2
`
`The apparatus of claim
`1, wherein the
`particular function
`comprises deactivation
`of measurement of
`changes in capacitance
`
`Sony products
`
`Each Sony product comprises an apparatus of claim 1. See, e.g., analysis and evidence of claim 1 above.
`
`For example, in the Xperia XZ3, the particular function comprises deactivation of measurement of changes
`in capacitance by the sensing element. For example, the capacitive touch sensor in the Xperia XZ3 ceases
`measuring capacitance changes for a period of time. For another example, the capacitive touch sensor in the
`Xperia XZ3 has a particular function wherein it measures changes in capacitance only during certain times
`
`Page 5
`
`Petitioners Samsung and Sony Ex-1009, 0005
`
`
`
`
`
`Claim 2
`
`Sony products
`
`by the sensing element. and deactivates the measurement of capacitance during other times.
`
`See, e.g.:
`
`
`Photograph of Xperia XZ3 with touch present, showing the normal capacitive sensing drive signal indicative
`of measurement of changes in capacitance.
`
`Page 6
`
`Petitioners Samsung and Sony Ex-1009, 0006
`
`
`
`Claim 2
`
`Sony products
`
`
`
`
`Photograph of Xperia XZ3 after touch is removed, showing the deactivation of measurement of changes in
`capacitance.
`
`Claim 3
`Claim 3
`
`The apparatus of claim
`1, wherein the
`particular function
`comprises recalibration
`of measurement of
`changes in capacitance
`
`Sony products
`
`Each Sony product comprises an apparatus of claim 1. See, e.g., analysis and evidence of claim 1 above.
`
`For example, in the Xperia XZ3, the particular function comprises recalibration of measurement of changes
`in capacitance by the sensing element. For example, the capacitive touch sensor in the Xperia XZ3 uses a
`different drive signal when the particular function is initiated, which requires recalibrating the measurement
`of changes in capacitance.
`
`Page 7
`
`Petitioners Samsung and Sony Ex-1009, 0007
`
`
`
`Claim 3
`
`Sony products
`
`by the sensing element. See, e.g.:
`
`
`
`
`Photograph of Xperia XZ3 with touch present, showing the normal capacitive sensing drive signal
`indicative of measurement of changes in capacitance.
`
`Page 8
`
`Petitioners Samsung and Sony Ex-1009, 0008
`
`
`
`Claim 3
`
`Sony products
`
`
`
`
`Photograph of Xperia XZ3 after touch is removed, showing the different drive signal when the particular
`function is initiated, requiring recalibration of the measurement.
`
`Claim 5
`Claim 5
`
`The apparatus of claim 1, wherein the logic is further operable to
`calculate the predetermined time duration based on one of a
`plurality of delay multipliers determined by a polarity of a voltage
`pulse.
`
`Sony products
`
`Each Sony product comprises an apparatus of claim 1. See, e.g.,
`analysis and evidence of claim 1 above.
`
`For example, in the Xperia XZ3, the logic is further operable to
`calculate the predetermined time duration based on one of a
`plurality of delay multipliers determined by a polarity of a
`
`Page 9
`
`Petitioners Samsung and Sony Ex-1009, 0009
`
`
`
`Claim 5
`
`Claim 7
`Claim 7
`
`
`
`Sony products
`
`voltage pulse.
`
`Sony products
`
`The apparatus of claim 1, wherein
`sensing element comprises a control
`circuit.
`
`Each Sony product comprises an apparatus of claim 1. See, e.g., analysis and evidence of
`claim 1 above.
`
`For example, in the Xperia XZ3, the sensing element comprises a control circuit. For
`example, the sensing element comprises a touch integrated circuit (“touch IC” or “touch
`controller”).
`
`Claim 8
`Claim 8
`
`Sony products
`
`The apparatus of claim 7, wherein the sensing element
`further comprises a pattern of electrodes within the
`touch screen, the electrodes being coupled to the
`control circuit.
`
`Each Sony product comprises an apparatus of claim 7. See, e.g., analysis and
`evidence of claim 7 above.
`
`For example, in the Xperia XZ3, the sensing element further comprises a
`pattern of electrodes within the touch screen, the electrodes being coupled to
`the control circuit. For example, the Xperia XZ3 comprises touch electrodes
`coupled to the touch IC.
`
`Claim 9
`Claim 8
`
`Sony products
`
`The apparatus of claim 8, wherein the electrodes comprise
`indium tin oxide (ITO).
`
`Each Sony product comprises an apparatus of claim 8. See, e.g., analysis
`and evidence of claim 8 above.
`
`For example, in the Xperia XZ3, the electrodes comprise indium tin
`
`Page 10
`
`Petitioners Samsung and Sony Ex-1009, 0010
`
`
`
`Claim 8
`
`Claim 16
`Claim 16
`
`[pre] A computer-
`readable non-transitory
`storage media
`embodying logic that is
`operable when executed
`to:
`
`[a] monitor detection by
`a sensing element of a
`key touch on a touch
`screen, the sensing
`element being of a touch
`screen;
`
`
`
`Sony products
`
`oxide (ITO).
`
`Sony products
`
`Each Sony product comprises a computer-readable non-transitory storage media embodying logic that is
`operable when executed to perform the claimed operations.
`
`For example, the Xperia XZ3 includes one or more touch controllers or system processors with non-
`transitory storage (e.g. Flash, EEPROM, HDD, SDD, etc.) embodying logic executable to perform the
`steps described below.
`
`See also, e.g., analysis and evidence of elements 16[a]-16[c] below.
`
`Each Sony product includes logic to monitor detection by a sensing element of a key touch on a touch
`screen, the sensing element being of a touch screen.
`
`For example, the Xperia XZ3 monitors touches from its capacitive touch screen.
`
`See, e.g.:
`
`Page 11
`
`Petitioners Samsung and Sony Ex-1009, 0011
`
`
`
`Claim 16
`
`Sony products
`
`
`
`Photograph of Xperia XZ3 illustrating touch screen.
`
`See also, e.g., analysis and evidence of elements 16[b] and 16[c] below.
`
`
`
`[b] determine an amount
`of time that has elapsed
`since the sensing
`element last detected a
`change of capacitance
`indicative of a key touch
`
`Each Sony product includes logic to determine an amount of time that has elapsed since the sensing
`element last detected a change of capacitance indicative of a key touch on the touch screen.
`
`For example, touching the Xperia XZ3’s touch screen and then removing the touch, thereby causing a
`change of capacitance, can cause the Xperia XZ3 to respond in various ways after a delay, indicating that
`
`Page 12
`
`Petitioners Samsung and Sony Ex-1009, 0012
`
`
`
`
`
`Claim 16
`
`Sony products
`
`on the touch screen; and
`
`the Xperia XZ3 determines the amount of time elapsed since the touch sensor detected a touch.
`
`See, e.g., analysis and evidence of element 16[c] below.
`
`[c] if the amount of time
`that has elapsed exceeds
`a predetermined time
`duration, then initiate a
`particular function of an
`apparatus.
`
`Each Sony product includes logic to, if the amount of time that has elapsed exceeds a predetermined time
`duration, then initiate a particular function of an apparatus.
`
`For example, the capacitive touch sensor in the Xperia XZ3 enters a different sensing mode a
`predetermined amount of time after a user’s finger is removed from the touch screen. This change is
`readily observable using a standard oscilloscope measuring the capacitive drive signals a short distance
`above the Xperia XZ3’s touch screen. There is a distinct difference between the drive signal observed
`while a finger touch is in contact with the drive signal observed after removing that touch. This difference
`likely reflects a power-saving mode initiated after the touch is removed. The change occurs after a
`consistent time offset.
`
`See, e.g.:
`
`Page 13
`
`Petitioners Samsung and Sony Ex-1009, 0013
`
`
`
`Claim 16
`
`Sony products
`
`
`
`
`Photograph of Xperia XZ3 with touch present, showing the capacitive sensing drive signal while a touch is
`detected.
`
`Page 14
`
`Petitioners Samsung and Sony Ex-1009, 0014
`
`
`
`Claim 16
`
`Sony products
`
`
`
`
`Photograph of Xperia XZ3 after touch is removed, showing the different capacitive sensing drive signal
`present following a predetermined time duration after the touch is removed.
`
`Claim 17
`Claim 17
`
`The media of claim 16, wherein the particular function
`comprises deactivation of measurement of changes in
`capacitance by the sensing element.
`
`Sony products
`
`Each Sony product comprises a media of claim 16. See, e.g., analysis and
`evidence of claim 16 above.
`
`For example, in the Xperia XZ3, the particular function comprises
`deactivation of measurement of changes in capacitance by the sensing
`element. See, e.g., analysis and evidence of claim 2 above.
`
`Page 15
`
`Petitioners Samsung and Sony Ex-1009, 0015
`
`
`
`Claim 18
`Claim 18
`
`The media of claim 16, wherein the particular function
`comprises recalibration of measurement of changes in
`capacitance by the sensing element.
`
`
`
`Sony products
`
`Each Sony product comprises a media of claim 16. See, e.g., analysis and
`evidence of claim 16 above.
`
`For example, in the Xperia XZ3, the particular function comprises
`recalibration of measurement of changes in capacitance by the sensing
`element. See, e.g., analysis and evidence of claim 3 above.
`
`Claim 20
`Claim 20
`
`The media of claim 16, wherein the logic is further
`operable to calculate the predetermined time duration based
`on one of a plurality of delay multipliers determined by a
`polarity of a voltage pulse.
`
`Sony products
`
`Each Sony product comprises a media of claim 16. See, e.g., analysis
`and evidence of claim 16 above.
`
`For example, in the Xperia XZ3, the logic is further operable to
`calculate the predetermined time duration based on one of a plurality of
`delay multipliers determined by a polarity of a voltage pulse. See, e.g.,
`analysis and evidence of claim 5 above.
`
`
`
`Page 16
`
`Petitioners Samsung and Sony Ex-1009, 0016
`
`
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