throbber
IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`Case No.: 6:21-cv-00755-ADA
`
`JURY TRIAL DEMANDED
`
`
`GENTEX CORPORATION and INDIGO
`TECHNOLOGIES, LLC,
`
`
`
`THALES VISIONIX, INC.,
`
`
`
`
`
`FACEBOOK, INC. and FACEBOOK
`TECHNOLOGIES, LLC,
`
`
`
`
`Plaintiffs,
`
`Involuntary Plaintiff,
`
`
`
`
`
`v.
`
`
`
`Defendants.
`
`
`
`
`
`
`
`PLAINTIFFS’ AMENDED DISCLOSURE OF
`PRELIMINARY INFRINGEMENT CONTENTIONS
`
`Pursuant to the Court’s Order Governing Proceedings, Plaintiffs Gentex Corporation and
`
`Indigo Technologies, LLC (collectively, “Gentex”) hereby serve their amended disclosure of
`
`preliminary infringement contentions.
`
`These infringement contentions are preliminary. Discovery has not yet begun, and
`
`Gentex’s investigation is ongoing. The parties have not discussed proposed constructions for, and
`
`the Court has not yet construed, any of the asserted claims. Gentex specifically reserves its right
`
`to supplement these disclosures—including by asserting additional claims, accusing different or
`
`additional functionality, and accusing additional and/or different products—based on information
`
`obtained as the case progresses. Gentex also reserves the right to amend its infringement
`
`contentions and asserted claims based on any proceedings before the U.S. Patent & Trademark
`
`Office regarding the asserted patents.
`
`
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`I.
`
`CHARTS SETTING FORTH WHERE IN THE ACCUSED PRODUCT(S) EACH
`ELEMENT OF THE ASSERTED CLAIMS IS FOUND.
`
`As set forth in detail in Gentex’s Complaint and the Exhibits attached thereto (Dkt. No. 1),
`
`Gentex alleges that Defendants Facebook, Inc. and Facebook Technologies, LLC (collectively,
`
`“Facebook”) have infringed and continued to infringe, directly and indirectly, literally or under the
`
`doctrine of equivalents, one or more claims of U.S. Patent Nos. 6,757,068 (the“’068 patent”),
`
`7,301,648 (the “’648 patent”), 8,224,024 (the “’024 patent”), 6,922,632 (the “’632 patent”), and
`
`7,725,253 (the “’253 patent”) (collectively, the “Asserted Patents”) by making, using, selling,
`
`offering to sell, and/or importing their Oculus Rift S, Oculus Quest, and Oculus Quest 2 products
`
`(collectively, with their respective related instructions, systems, services, and software, the
`
`“Accused Products”).
`
`Gentex attached as Exhibits 1-5 to its October 22, 2021 Disclosure of Preliminary
`
`Infringement Contentions (“Preliminary Infringement Contentions”) claim charts identifying the
`
`manner in which the Accused Products infringe each element of the asserted claims. These claim
`
`charts are based on a reasonable investigation of publicly available information currently available
`
`to Gentex. These preliminary infringement contentions are intended to serve a notice function,
`
`and do not constitute an exhaustive explanation of all theories Gentex may present in this case.
`
`Gentex reserves the right to amend, revise, alter, or otherwise modify these charts as this case
`
`progresses, including to incorporate new information obtained during the course of discovery (such
`
`as information that is not currently publicly available).
`
`Exhibit 1 sets forth Gentex’s preliminary contentions concerning Facebook’s direct and
`
`indirect infringement of claims 1-2, 4-5, 7-9, 11-20, 23-33, 35, 41, 45-48, 50, and 54-59 of the
`
`’068 patent, including a chart setting forth where in the Accused Products each element of the
`
`aforementioned claims is found, to the best of Gentex’s current knowledge and information.
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`
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`Exhibit 2 sets forth Gentex’s preliminary contentions concerning Facebook’s direct and
`
`indirect infringement of claims 1-5, 8-11, 16-18, 20-32, 35, 37-38, and 40-44 of the ’648 patent,
`
`including a chart setting forth where in the Accused Products each element of the aforementioned
`
`claims is found, to the best of Gentex’s current knowledge and information.
`
`Exhibit 3 sets forth Gentex’s preliminary contentions concerning Facebook’s direct and
`
`indirect infringement of claim 1 of the ’024 patent, including a chart setting forth where in the
`
`Accused Products each element of the aforementioned claim is found, to the best of Gentex’s
`
`current knowledge and information.
`
`Exhibit 4 sets forth Gentex’s preliminary contentions concerning Facebook’s direct and
`
`indirect infringement of claims 1-8, 11-26, 28-36, 44-45, 47-55, 57-61, and 66-69 of the ’632
`
`patent, including a chart setting forth where in the Accused Products each element of the
`
`aforementioned claims is found, to the best of Gentex’s current knowledge and information.
`
`Exhibit 5 sets forth Gentex’s preliminary contentions concerning Facebook’s direct and
`
`indirect infringement of claims 1-4 and 6-9 of the ’253 patent, including a chart setting forth where
`
`in the Accused Products each element of the aforementioned claims is found, to the best of
`
`Gentex’s current knowledge and information.
`
`The Court has not yet conducted claim construction proceedings. Depending on any
`
`constructions by the Court as to the Asserted Claims, and/or positions that Facebook or its expert
`
`witness(es) may take concerning claim interpretation, infringement, and/or validity issues, the
`
`charts in Exhibit 1–5 and the disclosures referenced therein may be of greater or lesser relevance,
`
`and different disclosures relating to the Accused Products may be implicated. Given this
`
`uncertainty, the charts may reflect alternative applications of the claims to the Accused Products.
`
`Nothing stated herein shall be construed as an admission or a waiver of any particular construction
`
`
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`of any claim term.
`
`II.
`
`THE PRIORITY DATE TO WHICH EACH ASSERTED CLAIM IS ENTITLED
`
`Gentex contends that the Asserted Claims of the ’068 patent are entitled to a priority date
`
`no later than January 28, 2000, the date of the filing of Provisional Application No. 60/178,797, to
`
`which the ’068 patent claims priority.
`
`Gentex contends that the Asserted Claims of the ’648 patent are entitled to a priority date
`
`no later than January 28, 2000, the date of the filing of Provisional Application No. 60/178,797, to
`
`which the ’648 patent claims priority.
`
`Gentex contends that claim 1 of the ’024 patent is entitled to a priority date no later than
`
`July 14, 2005.
`
`Gentex contends that the Asserted Claims of the ’632 patent are entitled to a priority date
`
`no later than June 13, 2001.
`
`Gentex contends that the Asserted Claims of the ’253 patent are entitled to a priority date
`
`no later than June 13, 2001.
`
`Gentex’s investigation is ongoing, and not all materials related to the conception and
`
`reduction to practice of the Asserted Claims are in its possession. Gentex reserves the right to
`
`amend its contentions regarding the priority dates of the Asserted Claims, including to identify and
`
`establish earlier dates, based on information learned as the case progresses.
`
`III. DOCUMENTS EVIDENCING THE CONCEPTION AND REDUCTION TO
`PRACTICE FOR EACH CLAIMED INVENTION
`
`Gentex produced a copy of the file histories for the Asserted Patents with its Preliminary
`
`Infringement Contentions. Gentex is concurrently producing certain documents evidencing
`
`conception and reduction to practice of the inventions claimed in the ’024, ’632, and ’253 patents
`
`with Bates numbers GNTX0001534–GNTX0001604. Gentex is working with and will continue
`
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`to work with the relevant third parties to locate any additional documents evidencing conception
`
`and reduction to practice of the claimed inventions and to produce them promptly.
`
`IV. A COPY OF THE FILE HISTORY FOR EACH PATENT IN SUIT
`
`Gentex has produced a copy of the file histories for each of the Asserted Patents with Bates
`
`numbers GNTX0000031–GNTX0000904.
`
`
`
`
`
`
`
`Dated: December 22, 2021
`
`
`
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`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`/s/ Adam D. Harber
`J. Mark Mann
`State Bar No. 12926150
`MANN | TINDEL | THOMPSON
`300 West Main Street
`Henderson, Texas 75652
`Tel: 903-657-8540
`Fax: 903-657-6003
`mark@themannfirm.com
`
`David I. Berl (pro hac vice)
`Adam D. Harber (pro hac vice)
`D. Shayon Ghosh (pro hac vice)
`Arthur John Argall III (pro hac vice)
`WILLIAMS & CONNOLLY LLP
`725 Twelfth Street, N.W.
`Washington, D.C. 20005
`Tel: 202-434-5000
`Fax: 202-434-5029
`dberl@wc.com
`aharber@wc.com
`sghosh@wc.com
`aargall@wc.com
`
`
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`Exhibit 4
`Exhibit 4
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`Gentex Corporation and Indigo Technologies, LLC (collectively, “Gentex”) presently
`contend that Facebook, Inc. and Facebook Technologies, LLC (collectively, “Facebook”)
`infringe claims 1-8, 11-26, 28-36, 44-45, 47-55, 57-61, and 66-69 (the “Asserted Claims”) of
`U.S. Patent No. 6,922,632, directly and/or indirectly, either literally or under the doctrine of
`equivalents. This chart sets forth Gentex’s preliminary infringement contentions relating to the
`Asserted Claims and the accused products, i.e., the Oculus Rift S, Oculus Quest, and Oculus
`Quest 2 (collectively, the “Accused Products”). In the event Facebook releases new products or
`services that infringe the ’632 patent, or further investigation reveals that other products or
`services infringe the ’632 patent, Gentex reserves the right to update these contentions as
`appropriate under the Order Governing Proceedings.
`
`
`These contentions articulate the structure and acts that constitute direct and/or indirect
`infringement of the ’632 patent and identify specifically where each element of each asserted
`claim is found within each Accused Product. Exemplary references to publicly available
`information concerning the Accused Products is provided where appropriate. Exemplary
`references to specific Accused Products are not intended and should not be read to exclude
`Accused Products not exemplified. On information and belief, the Accused Products are
`materially the same with respect to the claims of the ’632 patent discussed below, except the
`contentions below regarding hand tracking, which is performed by the Oculus Quest and Oculus
`Quest 2, but based on present information, is not performed by the Oculus Rift S. This
`disclosure is not intended to describe all acts of direct, induced, or contributory infringement
`Facebook has and continues to commit by making, using, selling, providing, developing,
`installing, testing, deploying, and/or directing the use of the Accused Products by customers and
`end users. The parties have not engaged in any discovery. The parties also have not discussed
`proposed constructions for, and the Court has not yet construed, any of the claims of the ’632
`patent. As a result, and consistent with the Order Governing Proceedings, Gentex reserves the
`right to modify, amend, or otherwise supplement these initial infringement contentions as
`discovery and the pre-trial phase of the litigation proceed and as additional information comes to
`light, including with respect to which claims Gentex is asserting, the infringement analysis for
`one or more of the claims, and whether and how limitations of one or more claims are met
`literally or under the doctrine of equivalents.
`
`
`Claim Limitation
`Claim 1
`(1pre) A method for
`tracking an object
`comprising:
`
`
`U.S. Patent 6,922,632
`Accused Products
`
`Facebook encourages, directs, or promotes users to use the Accused Products to carry
`out the claimed method, and Facebook performs the claimed method, as set forth below.
`For example, Facebook uses, and encourages users to use, a method for tracking an
`object (e.g., the user’s hand(s) and/or Oculus controller(s)). The Accused Products are
`especially adapted to carry out this method, which is a material part of the claimed
`invention, and have no substantial noninfringing uses. Further, on information and
`belief, Facebook conditions a user’s use of the Accused Products, and therefore the
`user’s receipt of the benefits of the Accused Products, upon this method and establishes
`the manner or timing of that use (e.g., through its software and/or user instructions,
`which have not been provided at this stage of the litigation).
`
`
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`
`
`See, e.g., Compare Headsets,
`See, e.g., Compare Headsets,
`https://www.oculus.com/compare/?products=quest%2Cquest-2 (hereinafter “Compare
`https://www.oculus.com/compare/?products=quest%2Cquest-2 (hereinafter “Compare
`Headsets”).
`
`Headsets’).
`
`
`
`Oculus Quest
`All-In-One VR Gaming
`
`
`
`TRACKING
`
`Six Degrees of Freedom
`
`With 6DOF, the headset tracks the movementof both your
`head and body, then translates them into VR with realistic
`precision. No external sensors required.
`
`
`
`
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`3
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`Oculus Quest 2
`AdvancedAll-In-One VR Gaming
`
`Starting At $2799 USD"
`
`ee
`TRACKING
`
`Six Degrees of Freedom
`
`
`
`
`
`With GDOF, the headsettracks the movementof both your
`head and body, then translates them into VR with realistic
`precision. No external sensors required.
`
`
`
`
`
`
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`Oculus Rift S
`PC-Powered VR Gaming
`
`
`
`TRACKING
`
`Six Degrees of Freedom
`
`With 6DOF, the headset tracks the movementof both your
`head and body, then translates them into VR with realistic
`precision. No external sensors required.
`
`
`
`
`
`
`See also Oculus Quest Features.
`See also Oculus Quest Features.
`
`Feeling is believing.
`
`
`
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`See also Oculus Rift S, https://www.oculus.com/rift-s/.
`
`(1a) coupling a sensor
`subsystem to an
`estimation subsystem,
`said sensor subsystem
`enabling
`measurement related
`to relative locations
`or orientations of
`sensing elements;
`
`
`
`
`
`Facebook encourages, directs, or promotes users to couple a sensor subsystem to an
`estimation subsystem, wherein the sensor subsystem enables measurement related to
`relative locations or orientations of sensing elements, and Facebook performs such step
`itself. For example, the Accused Products include a sensor subsystem (e.g., the cameras
`and/or inertial measurement units (“IMUs”), such as accelerometers and gyroscopes,
`within the headset, and/or the IMUs within the Oculus controller(s)) that is coupled to an
`estimation subsystem (e.g., the Oculus Insight tracking system). The sensor subsystem
`enables measurement related to the relative locations or orientations of sensing elements
`(e.g., the positions and orientations of the user’s hand(s) and/or the Oculus controller(s)
`relative to the headset). The Accused Products are especially adapted to carry out this
`method, which is a material part of the claimed invention, and have no substantial
`noninfringing uses. Further, Facebook conditions a user’s use of the Accused Products,
`and therefore the user’s receipt of the benefits of the Accused Products, upon this
`method and establishes the manner or timing of that use.
`
`See, e.g., Oculus Quest Features,
`https://web.archive.org/web/20200901154027if_/https://www.oculus.com/quest/features/
`(hereinafter “Oculus Quest Features”).
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`
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`See also Oculus Rift S.
`See also Oculus Rift S.
`
`
`7
`
`
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`
`
`Make your move.
`
`
`
`See also Tech@facebook, From the Lab to the living room: The story behind
`See also Tech@facebook, From the Lab to the living room: The story behind
`Facebook’s Oculus Insight technology and a new era of consumer VR (Aug. 22, 2019),
`Facebook’s Oculus Insight technology and a new era ofconsumer VR (Aug. 22, 2019),
`https://tech.fb.com/the-story-behind-oculus-insight-technology/, Sensor Placement at
`https://tech.fb.com/the-story-behind-oculus-insight-technology/, Sensor Placementat
`0:15 (hereinafter “From the Lab”).
`0:15 (hereinafter “From the Lab’’).
`
`
`
`ra) Sensor Placement
`Tech@Facebook @ - Follow
`
`temtsemeriit
`Tieme
`
`iTeeeee raDe © a £)
`
`
`
`Inertial \
`
`I SSS even) go .20
`
`FB Tem ales
`Tech@Facebook @ - Follow—_
`od
`
`|
`
`*
`
`@®
`
`rmemercd
`Steetme
`
`Cameras
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`
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`See also Oculus Blog, Powered by AI (Aug. 22, 2019),
`https://ai.facebook.com/blog/powered-by-ai-oculus-insight/ (hereinafter “Powered by
`AI”).
`
`
`
`
`See also id.
`
`
`
`
`See also Oculus for Developers, Oculus Device Specifications,
`https://developer.oculus.com/learn/oculus-device-specs/ (hereinafter “Oculus for
`Developers”).
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`See also id.
`
`
`
`
`See also Ben Lang, Quest Teardown Shows How Oculus Crammed Cooling & Cameras
`Inside (July 17, 2019), https://www.roadtovr.com/oculus-quest-teardown-disassembly/
`(hereinafter “Lang”).
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`playspace.
`
`Image courtesy BadVR, Jad Meouchy
`
`Around the mainboard wecan also see the headset’s four cameras mounted at very
`
`purposeful angles at the corners. The cameras are essential to enabling 6DOF tracking
`
`on both the headset and the controllers; their views are also merged together to allow a
`
`pass-through vision mode on the headset which is used to trace the boundary of your
`
`
`
`
`See also Powered by AI.
`See also Powered by AI.
`To unlockthe full potential of virtual reality (VR) and augmented reality (AR) experiences, the technology
`needs to work anywhere, adapting to the spaces where people live and how they move within those real-
`
`world environments. When we developed Oculus Quest, thefirst all-in-one, completely wire-free VR gaming
`system, we knew we neededpositional tracking that was precise, accurate, and available in real time — within
`the confines of a standalone headset, meaning it had to be compact and energy efficient.
`
`See also Powered by AI.
`See also Powered by AI.
`Academic research has been done on SLAM techniques for several decades, but the technology has only
`recently become mature enoughfor consumer applications, such as driverless cars and mobile AR apps.
`Facebookpreviously released a version of SLAM for AR on mobile devices which uses a single camera and
`inertial measurement unit (IMU) to track a phone's position and enable world-locked content — content that’s
`visually anchored to real objects in the world. Oculus Insight is the second generationofthis library, andit
`incorporates significantly more information from a combination of multiple IMUs and ultra-wide-angle
`cameras, as well as infrared LEDsto jointly track the 6DoF pasition of a VR headset and controllers.
`
`The Oculus Insight system uses a custom hardware architecture and advanced computervision algorithms —
`including visual-inertial mapping, place recognition, and geometry reconstruction — to establish the location
`of objectsin relation to other objects within a given space. This novel algorithm stack enables a VR device to
`pinpointits location, identify aspects of room geometry (suchasfloor location), and track the positions of the
`headset and controllers with respect to a 3D mapthatis generated and constantly updated by Insight. The
`data used for this process comes from three types of sensors built into the Quest and Rift S hardware:
`
`See also Powered by AI.
`See also Powered by AI.
`At last year's Oculus Connect event we shared some details about Oculus Insight, the cutting-edge
`technology that powers both Quest and Rift S. Now that both of those products are available, we're providing
`a deeperlook at the Al systems and techniques that powerthis VR technology. Oculus Insight marks thefirst
`time that fully untethered six-degree-of-freedom (6DoF) headset and controller tracking has shipped in a
`consumer AR/VR device. Built from the ground up, the Insight stack leverages state-of-the-art computer
`vision (CV) systems and visual-inertial simultaneous localization and mapping, or SLAM.
`
`
`
`
`
`
`
`
`
`
`See also From the Lab.
`See also From the Lab.
`
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`“We wanted to create a system that lets you move and explore a VR world just as
`naturally and easily as you would in real life,” says Kozminski.
`
`Kozminski joined a team whose mission was to create the first full-featured “inside-out”
`tracking system for a consumer VR device. The technology would have to track the full
`range of a person’s movements (known as six degrees of freedom) and be able to
`pinpoint the location of the two handheld controllers as well as the headset.
`
`Previously, VR devices relied on external sensors to track these movements. These
`cameras attach to a PC, and while they work well, they make VR less portable and more
`complicated to set up.
`
`“With inside-out tracking in the headset, VR becomes as easy as putting on headphones
`to listen to music,” says Kozminski.
`
`
`See also From the Lab.
`See also From the Lab.
`Taking SLAM technology...
`
`
`
`The foundation of Oculus Insight's inside-out tracking is simultaneous localization and
`mapping, or SLAM, which uses computer vision CV algorithms to essentially fuse
`incoming data from multiple sensors in order to fix the position of an object within a
`constantly updated digital map. SLAM has been used in robotics and in AR camera
`
`effects on smartphones and was demoedin the Oculus Santa Cruz VR headset prototype
`in 2016. But Oculus Insight required an unprecedentedlevel of precision and efficiency,
`and that meant adapting the latest research on tracking and computer vision.
`
`“A lot of these technologiesreally start in academia — inside the lab," Kozminski notes.
`It's no coincidence, then, that she’s part of Facebook's Zurich-based team of engineers,
`many of whom came from Zurich Eye — a joint program from theprestigious ETH
`
`University and University of Zurich that researched self-navigating systems.
`
`
`
`
`See also From the Lab.
`See also From the Lab.
`There are other complications, too. The infrared LEDs in the two hand
`controllers drastically change appearance when they movecloser or farther
`away from the headset as you swing a virtual sword or maneuver a virtual
`spaceship. Oculus Insight also uses other sensors, drawing acceleration and
`velocity data from the inertial measurement units (IMUs) located in the headset
`and controllers. The system must processall of these data points in real time
`and, in the case of Quest, on a mobile chipset.
`
`
`See also From the Lab.
`See also From the Lab.
`Previously, VR devices relied on external sensors to track these movements.
`These cameras attach to a PC, and while they work well, they make VR less
`portable and more complicated to set up.
`
`
`
`
`
`
`See also Oculus Quest 2, https://www.oculus.com/quest-2/.
`See also Oculus Quest 2, https://www.oculus.com/quest-2/.
`
`
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`[—}
`
`Introducing Oculus Quest 2.
`
`° — ro
`
`Wireless
`All-in-One VR
`
`
`
`
`
`
`See also Compare Headsets,
`See also Compare Headsets,
`https://www.oculus.com/compare/?products=quest%2Cquest-2.
`
`https://www.oculus.com/compare/?products=quest%2Cquest-2.
`
`Oculus Quest
`All-In-One VR Gaming
`
`
`
`TRACKING
`
`Six Degrees of Freedom
`
`With 6DOF, the headset tracks the movementof both your
`head and body, then translates them into VR with realistic
`precision. No external sensors required.
`
`
`
`
`
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`Oculus Quest 2
`AdvancedAll-In-One VR Gaming
`
`Starting At $299 USD’
`
`
`TRACKING
`
`
`
`Six Degrees of Freedom
`
`With GDOF, the headset tracks the movement of both your
`head and body, then translates them into VR with realistic
`precision. No external sensors required.
`
`
`
`
`
`
`See also David Heaney, Oculus Firmware Reveals New Touch Controllers, Referencing
`See also David Heaney, Oculus Firmware Reveals New Touch Controllers, Referencing
`Improvements to Tracking, Finger Sensing, Haptics (Apr. 16, 2020),
`Improvements to Tracking, Finger Sensing, Haptics (Apr. 16, 2020),
`https://uploadvr.com/oculus-jedi-controller-driver-found/ (hereinafter “Heaney”).
`https://uploadvr.com/oculus-jedi-controller-driver-found/ (hereinafter “Heaney’’).
`
`
`
`
`
`
`13
`13
`
`META 1012
`META V. THALES
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`META 1012
`META V. THALES
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`

`

`
`
`More Precise Tracking
`
`A functionfor infrared LED calibration exists, suggesting this controlleris
`optically tracked in the same way as the current Touch— cameras on the
`headset follow the movementof the LED constellation, and this is fused with
`the accelerometer readings to achieve sub-mm precision.
`
`ICM-20601 IMU fromlate 2015.
`
`
`
`
`
`
`
`
`
`See also Heaney.
`The driver also reveals the series model numberof the controller's inertial
`measurementunit (IMU)- the chip within all VR controllers which contains
`the accelerometer.
`
`Teardownsand the FCCfilings for the current Touch showed it uses TDK’s
`
`
`See also ICM-20601 Specification.
`See also ICM-20601 Specification.
`
`
`
`14
`14
`
`META 1012
`META V. THALES
`
`META 1012
`META V. THALES
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`

`

`
`
`(1b) accepting
`configuration data
`from the sensor
`subsystem;
`
`
`
`
`
`Facebook encourages, directs, or promotes users to use the Accused Products to accept
`configuration data from the sensor subsystem, and Facebook performs such step itself.
`For example, the Accused Products can operate using both controllers, a single
`controller, or no controller at all, and the headset in the Accused Products is configured
`using the applicable configuration data of the sensors in use at a given time. As a further
`example, the Accused Products enumerate the sensing elements available in the sensor
`subsystem, including optical sensors (e.g., cameras) and inertial sensors (e.g., IMUs),
`and configuration data regarding these sensing elements, including the characteristics of
`these sensing elements, is accepted from the sensor subsystem. The Accused Products
`are especially adapted to carry out this method, which is a material part of the claimed
`invention, and have no substantial noninfringing uses. Further, Facebook conditions a
`user’s use of the Accused Products, and therefore the user’s receipt of the benefits of the
`Accused Products, upon this method and establishes the manner or timing of that use.
`
`See, e.g., Hand Tracking.
`
`
`See also Designing for Hands.
`
`
`
`
`
`15
`
`META 1012
`META V. THALES
`
`

`

`
`
`
`
`
`See also Hand Tracking Deep Dive.
`
`
`
`
`
`
`
`
`See also id. at 4:00–10:00.
`
`
`See also Oculus Quest.
`
`16
`
`META 1012
`META V. THALES
`
`

`

`Controllers
`
`Oculus Quest
`elasleiced
`
`Two Touch
`
`
`See also Oculus Rift S.
`See also Oculus Rift S.
`
`
`
`
`
`
`Controllers
`
`Or ol0|(Nima iipmee)
`
`ereceisied
`
`Bem (eltcee
`
`
`
`
`See also From the Lab.
`See also From the Lab.
`
`
`
`17
`17
`
`META 1012
`META V. THALES
`
`META 1012
`META V. THALES
`
`

`

`
`
`
`
`
`See also From the Lab.
`
`
`See also Powered by AI.
`
`See also id.
`
`18
`
`
`
`
`
`
`
`META 1012
`META V. THALES
`
`

`

`
`
`TRACKER THREAD
`
`*
`
`Headset tracking computearchitecture
`MAPPER THREAD
`—_aD ee
`
`Converged points
`New seeds
`
`
`
`Selectseeds.asbackupaEw
`
`+ Update
`tirespas
`
`IMU THREAD
`
`DSP
`
`Update& reintegrai
`
`
`See
` Naueu)
`
`
`
` See also From the Lab, Sensor Placementat 0:30
`
`
`Deed
`window pose estimation
`
`
`
`Feature
`
`ellation LEDs QcTSSsos 0) Ow @
`
`
`
`in real-time — the mapperthread modifies the map, sending updated copies to the
`Oculus Insight processes multiple threads of data at once,
`tracker thread, which uses camera frames to estimate poses in the mapper-provided frames, while the JMU thread uses measurements from
`the JMUs to update the latest SLAM state.
`
`
`See also From the Lab, Sensor Placement at 0:23.
`See also From the Lab, Sensor Placementat 0:23
`
`Sensor Placement
`a) Steteectsa ie
`
`eMCtemaETtcd
`Report Video Issue
`
`>
`
`
`See also From the Lab, Sensor Placement at 0:30.
`
`
`
`
`
`
`
`19
`19
`
`META 1012
`META V. THALES
`
`META 1012
`META V. THALES
`
`

`

`
`
`
`
`
`See also Heaney.
`
`
`
`
`See also Does the Quest have a single controller mode for any games?, Reddit,
`https://www.reddit.com/r/OculusQuest/comments/c1rwr1/
`does_the_quest_have_a_single_controller_mode_for/
`(hereinafter
`Controller Discussion”).
`
`
`“Reddit Single
`
`
`
`20
`
`META 1012
`META V. THALES
`
`

`

`
`
`Does the Quest have a single controller mode for any games?
`http mgur.com/a/1dLoatG
`
`My stepdad sent his old Oculus Go,it is 2 lot better than I expected! My good friend who Is in the
`picture absolutely loves the Go. I make sure I bring it every time we hang out since I got it recently. He
`is able to play some of the games because there is only one controller. He would not be able to
`operate 2 controller with his other hand. We are looking at getting him one so we can play together, or
`both of us upgrading to the Quest. I was wondering if you guys have seen many games youcan play
`with only one controller on the quest, orif we should stick to the Go. My friend would be doing a lot of
`video but I know he did like the ability to play some of the games. This has been the only video game
`system he has every really been able to play. I hope the quest will work out for us. Let me know what
`you guysthink, thanks for the help.
`
`M 141Comments # Share
`
`ff Save @ Hide
`
`[EE Report
`
`8% Upvoted
`
`
`a This thread is archived
`Newcomments cannot be posted and votes cannot be cast
`
`soRTeY BEST +
`
`maltakanO & points -
`
`araa
`iF
`
`ago
`
`oo,
`
`Virtual virtual reality can be played with one controller
`
`
`ago
`MRHBE 5 points - 1 year
`Quest is a bit heavier too if that is a factor
`
`stigzcousin y* 1 point - 1 year ago
`+>
`%=This is something 1 did not think about. Good to know. Thank you
`
`
`jebwillnotdivideus 5 points - 1 ye
`go
`Beatsaber and sportsscramble can be played with 1 controller. Other games im not sure.
`
`
`See also Expert Mode at 2:36.
`See also Expert Modeat 2:36.
`
`
`
`eeDeTa)
`
`
`
`
`
`
`
`
`
`21
`21
`
`META 1012
`META V. THALES
`
`META 1012
`META V. THALES
`
`

`

`
`
`(1c) configuring the
`estimation system
`according to the
`accepted
`configuration data;
`
`Facebook encourages, directs, or promotes users to use the Accused Products to
`configure the estimation system according to the accepted configuration data, and
`Facebook performs such step itself. For example, the Accused Products configure the
`estimation system (e.g., the Oculus Insight tracking system) based on the accepted
`configuration data (e.g., the configuration of the Oculus controller(s) and/or the available
`sensing elements). The Accused Products are especially adapted to carry out this
`method, which is a material part of the claimed invention, and have no substantial
`noninfringing uses. Further, Facebook conditions a user’s use of the Accused Products,
`and therefore the user’s receipt of the benefits of the Accused Products, upon this
`method and establishes the manner or timing of that use.
`
`See, e.g., From the Lab.
`
`
`See also Oculus Rift S.
`
`
`See also Hand Tracking.
`
`
`See also Designing for Hands.
`
`
`
`
`
`
`
`
`
`22
`
`META 1012
`META V. THALES
`
`

`

`
`
`
`
`
`See also Hand Tracking Deep Dive at 4:00–10:00.
`
`
`
`
`
`
`
`
`See also id. at 4:00–10:00.
`
`
`See also Oculus Quest.
`
`23
`
`META 1012
`META V. THALES
`
`

`

`Controllers
`
`Oculus Quest
`elasleiced
`
`Two Touch
`
`
`See also Oculus Rift S.
`See also Oculus Rift S.
`
`
`
`
`
`
`Controllers
`
`Or ol0|(Nima iipmee)
`
`ereceisied
`
`Bem (eltcee
`
`
`
`
`See also Reddit Single Controller Discussion.
`See also Reddit Single Controller Discussion.
`
`
`
`24
`24
`
`META 1012
`META V. THALES
`
`META 1012
`META V. THALES
`
`

`

`
`
`
`
`Does the Quest have a single controller mode for any games?
`
`https://imgur.com/a/1dLoatG
`
`My stepdadsent his old Oculus Go,it is a lot better than I expected! My good friend who is in the
`picture absolutely loves the Go. I make sure I bring it every time we hang out since I gotit recently. He
`is able to play some of the games because there is only one controller. He would not be able to
`operate 2 controller with his other hand. We are looking at getting him one so we can play together, or
`both of us upgrading to the Quest. I was wondering if you guys have seen many games youcan play
`with only one controller on the quest, or if we should stick to the Go. My friend would be doing a lot of
`video but I know he did like the ability to play some of the games. This has been the only video game
`system he has every really been able to play. I hope the quest will work out for us. Let me know what
`you guysthink, thanks for the help.
`
`M11 Comments # Share
`
`fj Save @ Hide M Report
`
`oo Upvoted
`
`
`EZ This thread is archived
`New comments cannot be posted and votes cannot be cast
`
`soRTeY BEST +
`
`maltakan0 6 points - = year a
`
`oe,
`
`Virtual virtual reality can be played with one controller
`
`
`MRHBEK5 points - 1 year ago
`Questis a bit heavier too if that is a factor
`
`
`+ stigzcousin »” 1 point - 1 yea
`
`%=This is something I did not think about. Goodto know. Thank you
`
`
`jebwillnotdivideus

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