Case 3:22-cv-00694-MPS Document 1-8 Filed 05/23/22 Page 1 of 4
`
`Exhibit H
`
`CPC Ex. 2005 – Page 001
`ASSA ABLOY AB v. CPC Patent Technologies Pty Ltd.
`IPR2022-01006
`
`
`
`Exhibit H
`
`CPC Ex. 2005 – Page 001
`ASSA ABLOY AB v. CPC Patent Technologies Pty Ltd.
`IPR2022-01006
`
`
`
`Case 3:22-cv-00694-MPS Document 1-8 Filed 05/23/22 Page 2 of 4
`
`October 18, 2020
`
`SUBJECT TO FRE 408
`VIAFEDEX
`
`Yale Residential
`225 Episcopal Road
`Berlin, CT 0603 7
`
`George C. Summerfield
`george.summerfie1d@klgates.com
`(312) 807-4376
`
`Re: Charter Pacific Corporation Ltd. Patent Portfolio
`
`Dear Sir/Madam:
`
`We represent Charter Pacific Corporation Ltd/ ("Charter") in connection with its licensing
`and enforcement of its patent portfolio generally directed to electronic access security measures.
`That portfolio includes U.S. Patent No. 9,665,705 ("the '705 Patent"). A copy of the '705 Patent
`is attached hereto as Exhibit A. The invention of that patent is graphically depicted in Figure 2
`therein:
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`As shown in Figure 2, the major components of the claimed invention are transmitter and
`receiver subsystems, which work in concert to provide access to a "controlled item." A "controlled
`
`K&L GATES LLP
`70 West Madison Street, Chicago Illinois 60602
`T +1 312-807-4376 klgates.com
`
`CPC Ex. 2005 – Page 002
`ASSA ABLOY AB v. CPC Patent Technologies Pty Ltd.
`IPR2022-01006
`
`
`
`..
`
`Case 3:22-cv-00694-MPS Document 1-8 Filed 05/23/22 Page 3 of 4
`
`item" can be "an electronic key circuit in a personal computer" that is to be accessed by the user.
`'705 Patent, col. 6, lines 17-20. Representative claim IO of the '705 Patent reads as follows:
`
`A transmitter sub-system for operating in a system for providing secure access to a
`controlled item, wherein the transmitter sub-system comprises:
`
`a biometric sensor configured to receiving a biometric signal;
`
`a controller configured to match the biometric signal against members of a database of
`biometric signatures to thereby output an accessibility attribute; and
`
`a transmitter configured to emit a secure access signal conveying infonnation dependent
`upon said accessibility attribute; and
`
`wherein the controller is further configured to:
`
`receive a series of entries of the biometric signal, said series being characterized according
`to at least one of the number of said entries and a duration of each said entry;
`
`map said series into an instruction; and
`
`populate the data base according to the instruction, wherein the controlled item is one of:
`a locking mechanism of a physical access structure or an electronic lock on an electronic
`computing device.
`
`The "biometric signature" can be a fingerprint (id., col. 7, line 40), and the "biometric
`sensor" can be a fingerprint sensor (id., col. 5, lines 60-63). A claim chart showing how claims
`l, 2 10, 11, 14, 15, inter alia, of the '705 Patent reads on Yale Smart Locks as attached hereto as
`Exhibit B, also reflected In Yale's products below:
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`A similar invention is claimed in U.S. Patent No. 9,269,208 ("the '208 Patent"), which
`issue from the parent application to the '705 Patent. A copy of the '208 Patent is attached hereto
`
`2
`
`CPC Ex. 2005 – Page 003
`ASSA ABLOY AB v. CPC Patent Technologies Pty Ltd.
`IPR2022-01006
`
`
`
`Case 3:22-cv-00694-MPS Document 1-8 Filed 05/23/22 Page 4 of 4
`
`as Exhibit C. The '208 Patent contains the same Figure 2 as in the '705 Patent. Representative
`claim 9 of the '208 Patent reads as follows:
`
`A transmitter sub-system for operating in a system for providing secure access to a
`controlled item, wherein the transmitter sub-system comprises:
`
`a biometric sensor configured toreceive a biometric signal;
`
`means for matching the biometric signal against members of the database of biometric
`signatures to thereby output an accessibility attribute; and
`
`means for emitting a secure access signal conveying information dependent upon said
`accessibility attribute; and
`
`wherein the transmitter sub-system further comprises means for populating the data base
`of biometric signatures, the population means comprising:
`
`means for receiving a series of entries of the biometric signal, said series being
`characterised according to at least one of the number of said entries and a duration of each
`said entry; means for mapping said series into an instruction; and
`
`means for populating the data base according to the instruction, wherein the controlled
`item is one of: a locking mechanism of a physical access structure or an electronic lock on
`an electronic computing device.
`
`A claim chart showing how claim 9 of the '208 Patent, among others, reads on Yale Smart
`Locks attached hereto as Exhibit D. I have also attached hereto as Exhibit Ea list of patent assets
`owned by Charter and available for licensing.
`
`I would appreciate the chance to discuss this matter with you further, and propose a
`telephone conference on October 28, 2021 at I 0:00 your time. If there is another date and time
`that would be more convenient for you, please let me know. If you refer this matter to another
`individual, please provide me the contact information for that individual.
`
`Very truly yours,
`
`Isl George C. Summerfield
`George C. Summerfield
`
`3
`
`CPC Ex. 2005 – Page 004
`ASSA ABLOY AB v. CPC Patent Technologies Pty Ltd.
`IPR2022-01006
`
`
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