IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`C.A. NO. 2:20-cv-00283-JRG
`
`JURY TRIAL DEMANDED
`
`C.A. NO. 2:20-cv-00284-JRG
`
`JURY TRIAL DEMANDED
`
`C.A. NO. 2:20-cv-00285-JRG
`
`JURY TRIAL DEMANDED
`
`§§§§§§§§§§§
`
`§§§§§§§§
`
`§§§§§§§§
`
`JAPAN DISPLAY INC. and PANASONIC
`LIQUID CRYSTAL DISPLAY CO. LTD.
`
`Plaintiffs,
`
`v.
`
`TIANMA MICROELECTRONICS CO.
`LTD.
`
` Defendant
`JAPAN DISPLAY INC.
`
`v.
`
`TIANMA MICROELECTRONICS CO.
`LTD.
`
`Defendant.
`JAPAN DISPLAY INC.,
`
`v.
`
`TIANMA MICROELECTRONICS CO.
`LTD.
`
`Defendant.
`
`PLAINTIFFS’ DISCLOSURE OF
`ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
`
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`Page 1 of 141
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`Tianma Exhibit 1020
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`

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`Infringement Contentions
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`Pursuant to the Court’s Orders dated December 22, 2020 in each of the above-captioned
`
`cases (Dkt. Nos. 22, 19, and 20, respectively) and Patent Local Rules 3-1 and 3-2, plaintiffs Japan
`
`Display Inc. (“JDI” or “Plaintiff”) and Panasonic Liquid Crystal Display Co., Ltd. (individually,
`
`“PLD” or, together with JDI, “Plaintiffs”) serve this Disclosure of Asserted Claims and
`
`Infringement Contentions (“Infringement Contentions”).
`
`These Infringement Contentions are derived from Plaintiffs’ good faith evaluation of
`
`information known to Plaintiffs at this time based upon reasonably available public information
`
`and documents, including time-consuming and resource-intensive reverse engineering efforts.
`
`Plaintiffs reserve the right to supplement and/or amend these Infringement Contentions in view of
`
`information and/or documents that may be obtained during discovery, further investigation, the
`
`Court’s claim construction ruling, applicable case law and authorities, and/or any other reasons
`
`permitted under the Court’s orders, the Patent Rules, and the Federal Rules of Civil Procedure.
`
`I.
`
`P.R. 3-1 DISCLOSURE OF ASSERTED CLAIMS AND INFRINGEMENT
`CONTENTIONS
`
`A. Each claim of each patent in suit that is allegedly infringed by each opposing party;
`
`Based upon information reasonably available to Plaintiffs at this time, including time-
`
`consuming and resource-intensive reverse engineering efforts, Plaintiffs allege that Defendant has
`
`directly or indirectly infringed the following claims of the patents listed below (collectively, the
`
`“Asserted Claims” of the “Asserted Patents”), either literally or under the doctrine of equivalents,
`
`by, through, or in connection with the making, having made, use, offer for sale, sale, and/or
`
`importation of certain products:
`
`-283 Case
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`1. Claims 1-11 of U.S. Patent No. 8,218,119 (“the ’119 patent”). See also Exhibits
`
`A1 through A6.
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`Infringement Contentions
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`2. Claims 1-3, 5-13, and 15-19 of U.S. Patent No. 10,139,687 (“the ’687 patent”). See
`
`also Exhibits B1 through B6.
`
`3. Claims 1-8, and 10-21 of U.S. Patent No. 9,715,132 (“the ’132 patent”). See also
`
`Exhibits C1 through C6.
`
`4. Claims 1-11, 15, and 16 of U.S. Patent No. 9,793,299 (“the ’299 patent”). See also
`
`Exhibits D1 through D7.
`
`5. Claims 1, 3-9, and 11-14 of U.S. Patent No. 10,018,859 (“the ’859 patent”). See
`
`also Exhibits E1 through E6.
`
`6. Claims 1-5 of U.S. Patent No. 8,218,118 (“the ’118 patent”). See also Exhibits F1
`
`through F2.
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`7. Claims 1, 2, 4, and 6-8 of U.S. Patent No. 10,423,034 (“the ’034 patent”). See also
`
`Exhibits G1 through G6.
`
`8. Claims 1-2 of U.S. Patent No. 10,330,989 (“the ’989 patent”). See also Exhibit H1.
`
`9. Claims 1-6 of U.S. Patent No. 7,936,429 (“the ’429 patent”). See also Exhibits I1
`
`through I6.
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`-284 Case
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`1. Claims 1-4, 12, and 14 of U.S. Patent No. 9,310,654 (“the ’654 patent”). See also
`
`Exhibit J1.
`
`2. Claims 1-9 of U.S. Patent No. 8,830,409 (“the ’409 patent”). See also Exhibits K1
`
`through K8.
`
`3. Claims 1, 2, 4, and 6-8 of U.S. Patent No. 9,817,288 (“the ’288 patent”). See also
`
`Exhibits L1 through L6.
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`Infringement Contentions
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`1. Claims 1, 3, 5, 6, and 8 of U.S. Patent No. 7,636,142 (“the ’142 patent”). See also
`Exhibits M1 through M6.
`
`2. Claims 1-4 of U.S. Patent No. 7,385,665 (“the ’665 patent”). See also Exhibits N1
`through N8.
`
`3. Claims 1-4, 6-12, and 14-16 of U.S. Patent No. 9,939,698 (“the ’698 patent”). See
`also Exhibits O1 through O6.
`
`B. Separately for each asserted claim, each accused apparatus, product, device, process,
`method, act, or other instrumentality (“Accused Instrumentality”) of each opposing
`party of which the party is aware. This identification shall be as specific as possible.
`Each product, device, and apparatus must be identified by name or model number, if
`known. Each method or process must be identified by name, if known, or by any
`product, device, or apparatus which, when used, allegedly results in the practice of
`the claimed method or process;
`
`The Asserted Patents are directed to improvements in liquid crystal displays (“LCDs”)
`
`incorporating thin film transistor (“TFT”) technologies (“TFT LCDs”). Based upon a diligent
`
`investigation of information reasonably available to Plaintiffs at this time, Plaintiffs contend that
`
`Defendant makes, has made, uses, offers for sale, sells, and/or imports thousands of unique models
`
`of TFT LCDs that potentially infringe the Asserted Patents, but that a full accounting of all
`
`potentially infringing models of TFT LCDs is exclusively within Defendant’s knowledge. Further,
`
`it is impossible for Plaintiffs to determine infringement from publicly available documentation
`
`regarding Defendant’s TFT LCD products without purchasing each product and engaging in time-
`
`consuming and resource-intensive reverse engineering of each product. It is neither possible nor
`
`reasonably practical to identify each and every infringing product at this time. For instance, in
`
`most cases infringing products were incorporated into other products and branded and sold under
`
`the trade names of various third-party companies, making it impractical to identify all of them.
`
`Additionally, Defendant is continually developing and selling new models and will undoubtedly
`
`introduce additional models during the course of this case. This information is readily available
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`Infringement Contentions
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`to Defendant, who has access to the design details and manufacturing specifications of Defendant’s
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`TFT LCD products. Therefore, the full scope of Defendant’s infringement is not publicly available
`
`to Plaintiffs, who do not have unlimited time or resources. See, e.g., MOSAID Techs. Inc. v.
`
`Micron Tech., Inc., No. 2:06-CV-302 (DF), 2008 WL 11344767, at *2 (E.D. Tex. Jan. 29, 2008)
`
`(holding that “the cumulative authority in this district” is that when “there is a lack of public
`
`information” a plaintiff need not “perform reverse engineering on every accused product[] to
`
`satisfy P.R. 3-1.”).
`
`Even so, Plaintiffs have undertaken a reasonable investigation of publicly available
`
`information, including time-consuming and resource-intensive reverse engineering efforts, and
`
`have identified the following of Defendant’s TFT LCD products that practice the Asserted Claims
`
`and are representative of Defendant’s broader infringement (the “Representative Products”):
`
`[1] TL062FVMC70;
`
`[2] TL079QDXP02;
`
`[3] TL051VVXS09;
`
`[4] TL063FVMC80;
`
`[5] TL063FVMCA1;
`
`[6] NL1294A5ANA0125439391221;
`
`[7] TM062JDSC03; and
`
`[8] TM070RDHP03.
`
`Appendix 1 provides a chart specifically identifying which of the claims are asserted
`
`against each of the Representative Products.
`
`Plaintiffs accuse the Representative Products as well as all other reasonably similar
`
`products that Defendant has made, had made, used, offered for sale, sold, and/or imported since
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`August 31, 2014 (the “Accused Products”). Plaintiffs provide the following categorical
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`descriptions of the Accused Products.
`
`Representative Products [1] through [6] utilize a low-temperature polycrystalline silicon
`
`(“LTPS”) process, a technology that was pioneered by JDI and that allows TFT LCD panels to
`
`achieve a higher resolution while minimizing power consumption, and implement in-plane
`
`switching (“IPS”) type technology. As described in more detail below, Representative Products
`
`[1] through [6] are specifically representative of each of Defendant’s modern LTPS TFT LCD
`
`products that implement IPS-type technology (the “LTPS IPS Products”). Appendix 2 provides a
`
`list of all such LTPS IPS Products currently known to Plaintiffs. As further described below with
`
`respect to certain claims, Representative Products [1] through [6] are also specifically
`
`representative of each of Defendant’s modern LTPS TFT LCD products that implement non-IPS-
`
`type technology (the “LTPS non-IPS Products”). Appendix 3 provides a list of all such LTPS non-
`
`IPS Products currently known to Plaintiffs.
`
`Representative Products [7] and [8] utilize an amorphous silicon (“a-Si”) process and
`
`implement IPS-type technology. As described in more detail below, Representative Products [7]
`
`and [8] are specifically representative of each of Defendant’s modern a-Si TFT LCD products that
`
`implement IPS-type technology (the “a-Si IPS Products”). Appendix 4 provides a list of all such
`
`a-Si IPS Products currently known to Plaintiffs. As further described below with respect to certain
`
`claims, Representative Products [7] and [8] are also specifically representative of each of
`
`Defendant’s modern a-Si TFT LCD products that implement non-IPS-type technology (the “a-Si
`
`non-IPS Products”). Appendix 5 provides a list of all such a-Si non-IPS Products currently known
`
`to Plaintiffs.
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`Infringement Contentions
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`The “Accused Products” include the Representative Products, LTPS IPS Products, LTPS
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`non-IPS Products, a-Si IPS Products, and a-Si non-IPS Products, as well as all other reasonably
`
`similar products, that Defendant has made, had made, used, offered for sale, sold, and/or imported
`
`since August 31, 2014. All Accused Products currently known to Plaintiffs are listed in
`
`Appendices 2-5. These lists have been created based upon publicly available information.
`
`However, it is neither possible nor reasonably practical to identify each and every infringing
`
`product at this time. For instance, in most cases infringing products were incorporated into other
`
`products and branded and sold under the trade names of various third-party companies, making it
`
`impractical to identify all of them. Additionally, Defendant is continually developing and selling
`
`new models and will undoubtedly introduce additional models during the course of this case. As
`
`previously noted, the complete identification of Defendant’s infringing TFT LCD products is
`
`known exclusively to Defendant and is not publicly available to Plaintiffs through a reasonable
`
`and diligent investigation. Therefore, Plaintiffs intend and specifically reserve the right to
`
`promptly supplement and/or amend these Infringement Contentions to more specifically identify
`
`additional Accused Products once Defendant has provided discovery regarding the identity of all
`
`LTPS IPS Products, LTPS non-IPS Products, a-Si IPS Products, and a-Si non-IPS Products that
`
`Defendant has made, had made, used, offered for sale, sold, and/or imported since August 31, 2014
`
`(“Accused Product Discovery”). See, e.g., Honeywell Int’l Inc. v. Acer Am. Corp., 655 F. Supp.
`
`2d 650, 657-58 (E.D. Tex. 2009) (plaintiff is entitled to discovery regarding products that “likely
`
`operate in a manner reasonably similar to the infringement theory contained in its [Preliminary
`
`Infringement Contentions]” when plaintiff undertook a diligent investigation and the discovery
`
`sought was not publicly available). Plaintiffs further intend and specifically reserve the right to
`
`promptly supplement and/or amend these Infringement Contentions to remove products that are
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`shown through discovery not to have been made, used, offered for sale, sold, and/or imported in
`
`or into the United States since August 31, 2014.
`
`Plaintiffs do not contend that each Representative Product practices each of the Asserted
`
`Claims. However, Plaintiffs contend that certain subsets of the Representative Products share the
`
`same basic technology and incorporate the same relevant features embodying specific subsets of
`
`the Asserted Claims in the exact same fashion, such that there is no material difference between
`
`them affecting Plaintiffs’ infringement theories for those claims, and that those subsets of
`
`Representative Products are therefore representative of additional categories of Defendant’s other
`
`TFT LCDs that share that same basic technology and incorporate those same relevant features
`
`(“Representative Categories”).
`
`It is impossible for Plaintiffs to fully determine from publicly available documentation
`
`regarding Defendant’s TFT LCD products which of the Accused Products belong in each
`
`Representative Category without purchasing each Accused Product and engaging in time-
`
`consuming and resource-intensive reverse engineering of each product. This information is readily
`
`available to Defendant, who has access to the design details and manufacturing specifications of
`
`Defendant’s TFT LCD products. Therefore, the full scope of each Representative Category is not
`
`publicly available to Plaintiffs, who do not have unlimited time or resources. Plaintiffs intend and
`
`specifically reserve the right to promptly supplement and/or amend these Infringement
`
`Contentions to specifically identify which Accused Products belong in each Representative
`
`Category once Defendant has provided technical discovery regarding the design, structure,
`
`operation, and functionality of all LTPS IPS Products, LTPS non-IPS Products, a-Si IPS Products,
`
`and a-Si non-IPS Products that Defendant has made, had made, used, offered for sale, sold, and/or
`
`imported since August 31, 2014 (“Technical Discovery”). Plaintiffs expect the Technical
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`Discovery to include at least (1) documents sufficient to show the structure, manufacture, and
`
`operation of each Accused Product (e.g., operation manuals, product literature, schematics, and
`
`specifications); (2) files or documents for each Accused Product containing a graphical
`
`representation of the integrated circuit that shows the connections between the various components
`
`of the circuit, including complete hierarchical printouts (e.g., in PDF format) of schematic and
`
`logical netlist views that are used for abstract level simulation; (3) files or documents for each
`
`Accused Product that show the physical arrangement of the components of an integrated circuit,
`
`also called the circuit layout which are used by a foundry to fabricate an integrated circuit (e.g.,
`
`GDS (Graphic Design/Data/Database System), GDSII stream format, DEF (Design Exchange
`
`Format), and LEF (Library Exchange Format) files), including the related layer definition files;
`
`(4) files or documents that show the fabrication process flow referring or relating to any Accused
`
`Product, including the order and relevant specifications of all processing steps (e.g., the process
`
`“recipe”), the full complement of design rules for said process, physical layer and mask
`
`information, any process design kit (“PDK”) deliverables with the associated documentation, and
`
`any standard operating procedure (“SOP”) deliverables; and (5) documents associated with each
`
`Accused Product. These types of files are often treated as computer source code, and, similar to
`
`computer source code, the Technical Discovery is exclusively within Defendant’s control, cannot
`
`be reverse engineered without unduly and burdensome investments in time and money, and is
`
`critically relevant to the question of infringement. Thus, Plaintiffs contend that this situation is
`
`akin to that included in Section 3(a)(i) of the Court’s model Discovery Order, which allows a
`
`plaintiff to defer identification under P.R. 3-1 of claim elements that are implemented by software
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`until 30 days after source code for the accused products is produced by the defendant.
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`A chart detailing the Representative Products comprising the Representative Categories
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`and the claims asserted against each Representative Category is presented in Appendix 6, and a
`
`detailed technical definition of each Representative Category on a per-Accused Patent basis is
`
`provided in Appendix 7.
`
`C. A chart identifying specifically where each element of each asserted claim is found
`within each Accused Instrumentality, including for each element that such party
`contends is governed by 35 U.S.C. § 112(¶ 6), the identity of the structure(s), act(s), or
`material(s) in the Accused Instrumentality that performs the claimed function;
`
`Based upon information reasonably available to Plaintiffs at this time, including time-
`
`consuming and resource-intensive reverse engineering efforts, Plaintiffs provide the below claim
`
`charts for each of the Representative Products. Each of the charts, identified below as appropriate,
`
`serve as exemplars for specific Representative Categories with respect to specific claims because
`
`there are no material differences between the Representative Products and the Representative
`
`Categories that would affect Plaintiffs’ infringement theories, such that separate charts would be
`
`the same for the Representative Categories in all relevant respects. See Eolas Techs. Inc. v.
`
`Amazon.com, Inc., No. 6:15-CV-01038, 2016 WL 7666160, at *3 (E.D. Tex. Dec. 5, 2016)
`
`(“[T]his Court has consistently found that multiple instrumentalities can apply to the same chart
`
`where separate charts would be identical for each instrumentality.”); see also Rapid Completions
`
`LLC v. Baker Hughes Inc., 6:15-CV-724, 2016 WL 3407688, at *7 (E.D. Tex. June 21, 2016)
`
`(“[A] plaintiff may provide an exemplar chart, which encompasses multiple products, if that chart
`
`would be representative of each of those products.”).
`
`-283 Case
`
`1. The elements of the Asserted Claims of the ’119 patent are found within the
`Representative Products as identified in the charts contained in Exhibits A1 through
`A6:
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`a. Exhibit A1 charts claims 1-11 against Representative Product [1]. Exhibit
`A1 is also representative of Representative Category [A] with respect to
`claims 1-11.
`
`b. Exhibit A2 charts claims 1-11 against Representative Product [2]. Exhibit
`A2 is also representative of Representative Category [A] with respect to
`claims 1-11.
`
`c. Exhibit A3 charts claims 1-11 against Representative Product [3]. Exhibit
`A3 is also representative of Representative Category [A] with respect to
`claims 1-11.
`
`d. Exhibit A4 charts claims 1-11 against Representative Product [4]. Exhibit
`A4 is also representative of Representative Category [A] with respect to
`claims 1-11.
`
`e. Exhibit A5 charts claims 1-11 against Representative Product [5]. Exhibit
`A5 is also representative of Representative Category [A] with respect to
`claims 1-11.
`
`f. Exhibit A6 charts claims 1-11 against Representative Product [6]. Exhibit
`A6 is also representative of Representative Category [A] with respect to
`claims 1-11.
`
`2. The elements of the Asserted Claims of the ’687 patent are found within the
`Accused Products as identified in the charts contained in Exhibits B1 through B6:
`
`a. Exhibit B1 charts claims 1-3, 5-13, and 15-19 against Representative
`Product [1]. Exhibit B1 is also representative of Representative Category
`[B] with respect to claims 1-3, 5-8, 10-13, and 15-18; and Representative
`Category [B-SUB1] with respect to claims 9 and 19.
`
`b. Exhibit B2 charts claims 1-3, 5-8, 10-13, and 15-18 against Representative
`Product [2]. Exhibit B2 is also representative of Representative Category
`[B] with respect to claims 1-3, 5-8, 10-13, and 15-18.
`
`c. Exhibit B3 charts claims 1-3, 5-13, and 15-19 against Representative
`Product [3]. Exhibit B3 is also representative of Representative Category
`[B] with respect to claims 1-3, 5-8, 10-13, and 15-18; and Representative
`Category [B-SUB1] with respect to claims 9 and 19.
`
`d. Exhibit B4 charts claims 1-3, 5-13, and 15-19 against Representative
`Product [4]. Exhibit B4 is also representative of Representative Category
`[B] with respect to claims 1-3, 5-8, 10-13, and 15-18; and Representative
`Category [B-SUB1] with respect to claims 9 and 19.
`
`e. Exhibit B5 charts claims 1-3, 5-13, and 15-19 against Representative
`Product [5]. Exhibit B5 is also representative of Representative Category
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`[B] with respect to claims 1-3, 5-8, 10-13, and 15-18; and Representative
`Category [B-SUB1] with respect to claims 9 and 19.
`
`f. Exhibit B6 charts claims 1-3, 5-13, and 15-19 against Representative
`Product [6]. Exhibit B6 is also representative of Representative Category
`[B] with respect to claims 1-3, 5-8, 10-13, and 15-18; and Representative
`Category [B-SUB1] with respect to claims 9 and 19.
`
`3. The elements of the Asserted Claims of the ’132 patent are found within the
`Accused Products as identified in the charts contained in Exhibits C1 through C6:
`
`a. Exhibit C1 charts claims 1-8 and 10-21 against Representative Product [1].
`Exhibit C1 is also representative of Representative Category [C] with
`respect to claims 1-8, 10, and 20-21; and Representative Category
`[C-SUB1] with respect to claims 11-19.
`
`b. Exhibit C2 charts claims 1-8 and 10-21 against Representative Product [2].
`Exhibit C2 is also representative of Representative Category [C] with
`respect to claims 1-8, 10, and 20-21; and Representative Category
`[C-SUB1] with respect to claims 11-19.
`
`c. Exhibit C3 charts claims 1-8, 10, and 20-21 against Representative
`Product [3]. Exhibit C3 is also representative of Representative Category
`[C] with respect to claims 1-8, 10, and 20-21.
`
`d. Exhibit C4 charts claims 1-8 and 10-21 against Representative Product [4].
`Exhibit C4 is also representative of Representative Category [C] with
`respect to claims 1-8, 10, and 20-21; and Representative Category
`[C-SUB1] with respect to claims 11-19.
`
`e. Exhibit C5 charts claims 1-8, 10, and 20-21 against Representative
`Product [5]. Exhibit C5 is also representative of Representative Category
`[C] with respect to claims 1-8, 10, and 20-21.
`
`f. Exhibit C6 charts claims 1-8 and 10-21 against Representative Product [6].
`Exhibit C6 is also representative of Representative Category [C] with
`respect to claims 1-8, 10, and 20-21; and Representative Category
`[C-SUB1] with respect to claims 11-19.
`
`4. The elements of the Asserted Claims of the ’299 patent are found within the
`Accused Products as identified in the charts contained in Exhibits D1 through D7:
`
`a. Exhibit D1 charts claims 1-11 and 15-16 against Representative Product [1].
`Exhibit D1 is also representative of Representative Category [D-LTPS]
`with respect to claims 1-11 and 15-16.
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`b. Exhibit D2 charts claims 1-11 and 15-16 against Representative Product [2].
`Exhibit D2 is also representative of Representative Category [D-LTPS]
`with respect to claims 1-11 and 15-16.
`
`c. Exhibit D3 charts claims 1-11 and 15-16 against Representative Product [3].
`Exhibit D3 is also representative of Representative Category [D-LTPS]
`with respect to claims 1-11 and 15-16.
`
`d. Exhibit D4 charts claims 1-11 and 15-16 against Representative Product [4].
`Exhibit D4 is also representative of Representative Category [D-LTPS]
`with respect to claims 1-11 and 15-16.
`
`e. Exhibit D5 charts claims 1-11 and 15-16 against Representative Product [5].
`Exhibit D5 is also representative of Representative Category [D-LTPS]
`with respect to claims 1-11 and 15-16.
`
`f. Exhibit D6 charts claims 1-11 and 15-16 against Representative Product [6].
`Exhibit D6 is also representative of Representative Category [D-LTPS]
`with respect to claims 1-11 and 15-16.
`
`g. Exhibit D7 charts claims 1-4, 6-10, and 15-16 against Representative
`Product [7]. Exhibit D7 is also representative of Representative Category
`[D-aSi] with respect to claims 1-4, 6-10, and 15-16.
`
`5. The elements of the Asserted Claims of the ’859 patent are found within the
`Accused Products as identified in the charts contained in Exhibits E1 through E6:
`
`a. Exhibit E1 charts claims 1, 3-9, and 11-14 against Representative
`Product [1].
` Exhibit E1
`is also representative of Representative
`Category [E] with respect to claims 1, 3-9, and 11-14.
`
`b. Exhibit E2 charts claims 1, 3-9, and 11-14 against Representative
`Product [2].
` Exhibit E2
`is also representative of Representative
`Category [E] with respect to claims 1, 3-9, and 11-14.
`
`c. Exhibit E3 charts claims 1, 3-9, and 11-14 against Representative
`Product [3].
` Exhibit E3
`is also representative of Representative
`Category [E] with respect to claims 1, 3-9, and 11-14.
`
`d. Exhibit E4 charts claims 1, 3-9, and 11-14 against Representative
`Product [4].
` Exhibit E4
`is also representative of Representative
`Category [E] with respect to claims 1, 3-9, and 11-14.
`
`e. Exhibit E5 charts claims 1, 3-9, and 11-14 against Representative
`Product [5].
` Exhibit E5
`is also representative of Representative
`Category [E] with respect to claims 1, 3-9, and 11-14.
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`f. Exhibit E6 charts claims 1, 3-9, and 11-14 against Representative
`Product [6].
` Exhibit E6
`is also representative of Representative
`Category [E] with respect to claims 1, 3-9, and 11-14.
`
`6. The elements of the Asserted Claims of the ’118 patent are found within the
`Accused Products as identified in the charts contained in Exhibits F1 through F2:
`
`a. Exhibit F1 charts claims 1-5 against Representative Product [7]. Exhibit F1
`is also representative of Representative Category [F] with respect to
`claims 1-5.
`
`b. Exhibit F2 charts claims 1-5 against Representative Product [8]. Exhibit F2
`is also representative of Representative Category [F] with respect to
`claims 1-5.
`
`7. The elements of the Asserted Claims of the ’034 patent are found within the
`Accused Products as identified in the charts contained in Exhibits G1 through G6:
`
`a. Exhibit G1 charts claims 1, 2, 4, and 6-8 against Representative Product [1].
`Exhibit G1 is also representative of Representative Category [G] with
`respect to claims 1, 2, and 6-8; and Representative Category [G-SUB1] with
`respect to claim 4.
`
`b. Exhibit G2 charts claims 1, 2, 4, and 6-8 against Representative Product [2].
`Exhibit G2 is also representative of Representative Category [G] with
`respect to claims 1, 2, and 6-8; and Representative Category [G-SUB1] with
`respect to claim 4.
`
`c. Exhibit G3 charts claims 1, 2, and 6-8 against Representative Product [3].
`Exhibit G3 is also representative of Representative Category [G] with
`respect to claims 1, 2, and 6-8.
`
`d. Exhibit G4 charts claims 1, 2, 4, and 6-8 against Representative Product [4].
`Exhibit G4 is also representative of Representative Category [G] with
`respect to claims 1, 2, and 6-8; and Representative Category [G-SUB1] with
`respect to claim 4.
`
`e. Exhibit G5 charts claims 1, 2, and 6-8 against Representative Product [5].
`Exhibit G5 is also representative of Representative Category [G] with
`respect to claims 1, 2, and 6-8.
`
`f. Exhibit G6 charts claims 1, 2, and 6-8 against Representative Product [6].
`Exhibit G6 is also representative of Representative Category [G] with
`respect to claims 1, 2, and 6-8.
`
`8. The elements of the Asserted Claims of the ’989 patent are found within the
`Accused Products as identified in the charts contained in Exhibit H1:
`
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`a. Exhibit H1 charts claims 1 and 2 against Representative Product [2].
`Exhibit H1 is also representative of Representative Category [H] with
`respect to claims 1 and 2.
`
`9. The elements of the Asserted Claims of the ’429 patent are found within the
`Accused Products as identified in the charts contained in Exhibits I1 through I6:
`
`a. Exhibit I1 charts claims 1-6 against Representative Product [1]. Exhibit I1
`is also representative of Representative Category [I] with respect to
`claims 1-6.
`
`b. Exhibit I2 charts claims 1-6 against Representative Product [2]. Exhibit I2
`is also representative of Representative Category [I] with respect to
`claims 1-6.
`
`c. Exhibit I3 charts claims 1-6 against Representative Product [3]. Exhibit I3
`is also representative of Representative Category [I] with respect to
`claims 1-6.
`
`d. Exhibit I4 charts claims 1-6 against Representative Product [4]. Exhibit I4
`is also representative of Representative Category [I] with respect to
`claims 1-6.
`
`e. Exhibit I5 charts claims 1-6 against Representative Product [5]. Exhibit I5
`is also representative of Representative Category [I] with respect to
`claims 1-6.
`
`f. Exhibit I6 charts claims 1-6 against Representative Product [6]. Exhibit I6
`is also representative of Representative Category [I] with respect to
`claims 1-6.
`
`-284 Case
`
`1. The elements of the Asserted Claims of the ’654 patent are found within the
`Accused Products as identified in the charts contained in Exhibit J1:
`
`a. Exhibit J1 charts claims 1-4, 12, and 14 against Representative Product [2].
`Exhibit J1 is also representative of Representative Category [J] with respect
`to claims 1-4, 12, and 14.
`
`2. The elements of the Asserted Claims of the ’409 patent are found within the
`Accused Products as identified in the charts contained in Exhibits K1 through K8:
`
`a. Exhibit K1 charts claims 1-9 against Representative Product [1].
`Exhibit K1 is also representative of Representative Category [K-LTPS]
`with respect to claims 1-9.
`
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`b. Exhibit K2 charts claims 1-9 against Representative Product [2].
`Exhibit K2 is also representative of Representative Category [K-LTPS]
`with respect to claims 1-9.
`
`c. Exhibit K3 charts claims 1-9 against Representative Product [3].
`Exhibit K3 is also representative of Representative Category [K-LTPS]
`with respect to claims 1-9.
`
`d. Exhibit K4 charts claims 1-9 against Representative Product [4].
`Exhibit K4 is also representative of Representative Category [K-LTPS]
`with respect to claims 1-9.
`
`e. Exhibit K5 charts claims 1-9 against Representative Product [5].
`Exhibit K5 is also representative of Representative Category [K-LTPS]
`with respect to claims 1-9.
`
`f. Exhibit K6 charts claims 1-9 against Representative Product [6].
`Exhibit K6 is also representative of Representative Category [K-LTPS]
`with respect to claims 1-9.
`
`g. Exhibit K7 charts claims 1-9 against Representative Product [7].
`Exhibit K7 is also representative of Representative Category [K-aSi] with
`respect to claims 1-9.
`
`h. Exhibit K8 charts claims 1-9 against Representative Product [8].
`Exhibit K8 is also representative of Representative Category [K-aSi] with
`respect to claims 1-9.
`
`3. The elements of the Asserted Claims of the ’288 patent are found within the
`Accused Products as identified in the charts contained in Exhibits L1 through L6:
`
`a. Exhibit L1 charts claims 1, 2, 4, and 6-8 against Representative Product [1].
`Exhibit L1 is also representative of Representative Category [L] with
`respect to claims 1, 7, and 8; Representative Category [L-SUB1] with
`respect to claim 2; and Representative Category [L-SUB2] with respect to
`claims 4 and 6.
`
`b. Exhibit L2 charts claims 1 and 7-8 against Representative Product [2].
`Exhibit L2 is also representative of Representative Category [L] with
`respect to claims 1, 7, and 8.
`
`c. Exhibit L3 charts claims 1, 2, and 7-8 against Representative Product [3].
`Exhibit L3 is also representative of Representative Category [L] with
`respect to claims 1, 7, and 8; and Representative Category [L-SUB1] with
`respect to claim 2.
`
`d. Exhibit L4 charts claims 1, 2, 4, and 6-8 against Representative Product [4].
`Exhibit L4 is also representative of Representative Category [L] with
`
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`
`respect to claims 1, 7, and 8; Representative Category [L-SUB1] with
`respect to claim 2; and Representative Category [L-SUB2] with respect to
`clai