`
` 1 and when they have been on for 15 seconds, and the blood
` 2 oxygen sensor typically takes 15 seconds or so to perform a
` 3 reading. As you can see, there's a significant gradient in
` 4 temperature over time.
` 5
`So there's neither the structure nor the function
` 6 nor the result that is taught by the '127 patent. This is
` 7 just not what the patent is directed at. There's no
` 8 infringement.
` 9
`If we go to the '745 patent, here we have this
` 10 purported invention involving shaping of light or light goes
` 11 through a material and goes from a first shape to a second
` 12 shape.
`What they're accusing of infringement is the
` 13
` 14 pattern of light as it emerges from something called the
` 15 microlens array or MLA. And there's a comparison being done
` 16 between light as it's emitted at the LED and the light as it
` 17 emerges from the MLA.
` 18
`But if Your Honor looks at the claim language,
` 19 the requirement is to change the first shape into a second
` 20 shape at the material, at the material. So the relevant
` 21 comparison is between the shape of the light when it reaches
` 22 the MLA and the shape of the light when it emerges from the
` 23 MLA.
` 24
` 25
`
`As the engineers will explain to Your Honor, the
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`MASIMO 2074
`Apple v. Masimo
`IPR2022-01291
`
`
`
` 65
` microlens array is not intended to change light into a
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`MASIMO 2074
`Apple v. Masimo
`IPR2022-01291
`
`
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