throbber
IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`Civil Action No. 1:23-cv-122-RGA
`
`LITL LLC,
`
`v.
`
`Plaintiff,
`
`ASUSTEK COMPUTER INC. and ASUS
`GLOBAL PTE. LTD.,
`
`Defendants.
`
`MICROSOFT CORPORATION,
`
`Intervenor-Plaintiff,
`
`v.
`
`LITL LLC,
`
`LITL LLC,
`
`Intervenor-Defendant.
`
`Intervenor-Defendant /
`Counterclaim Plaintiff in
`Intervention,
`
`v.
`
`MICROSOFT CORPORATION,
`
`Intervenor-Plaintiff /
`Counterclaim Defendant in
`Intervention.
`
`PLAINTIFF’S INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT
`
`1
`
`LiTL Exhibit 2021
`MSFT v. LiTL
`IPR2024-00457
`
`

`

`Pursuant to the Court’s Scheduling Order (D.I. 42) and Delaware Default ESI Rule 4.c,
`
`Plaintiff LiTL LLC (“Plaintiff” or “LiTL”) hereby serves the attached initial claim charts
`
`regarding infringement by ASUS of U.S. Patent Nos. 8,289,688, 8,624,844, 9,563,229,
`
`10,289,154, 9,003,315, 9,880,715, 10,564,818, and 8,612,888 (collectively, the “Asserted
`
`Patents”).
`
`LiTL’s claim charts are based upon the documents that Defendants ASUSTeK Computer
`
`Inc. and Asus Global Pte. Ltd. (collectively “Defendants” or “ASUS”) provided to LiTL
`
`pursuant to the Scheduling Order and Delaware Default ESI Rule 4.b and information reasonably
`
`available to LiTL. To date, Defendants have failed to provide LiTL with the “core technical
`
`documents” required under the Scheduling Order and Delaware Default ESI Rule 4.b. As
`
`detailed in LiTL’s letters to ASUS dated March 15 and 18, 2024, and as discussed during our
`
`meet and confers on March 22 and 29, 2024, ASUS’s core technical document production to date
`
`suffers numerous deficiencies. ASUS’s production consists entirely of webpage captures and
`
`manuals available on ASUS’s website. ASUS has failed to provide documents sufficient to
`
`show how the accused products operate, and in particular, how different physical configurations
`
`detect and cause transitions on the user interface between one configuration and another. ASUS
`
`was obligated to produce these documents as part of its core technical document production and
`
`in response to LiTL’s Request Nos. 2-4 and 23-25 of its First Set of Requests for Production of
`
`Documents. LiTL reserves the right to supplement its initial claim charts to incorporate
`
`additional information regarding the accused products as additional information becomes
`
`available.
`
`In the claim charts attached as Exhibits A-H, LiTL identifies the following asserted claims
`
`from the Asserted Patents:
`
`2
`
`

`

`Asserted Patent Asserted Claims
`8,289,688
`11, 17-19, 21, 22, 27, 28, 30-32
`8,624,844
`10, 16, 17
`9,563,229
`1-6, 8-11, 16-21, 23, 25
`10,289,154
`1-9, 11-15
`9,003,315
`1-16, 18, 23, 24, 27-29, 53-57
`9,880,715
`1, 2, 4-9, 12, 14-17, 19, 20
`10,564,818
`1-20
`8,612,888
`1, 2, 4-9, 18, 19, 22-27
`
`Exhibit
`A
`B
`C
`D
`E
`F
`G
`H
`
`LiTL accuses Defendants of infringing the Asserted Patents with respect to the following
`
`products (collectively, the “Accused Products”):
`
`No. Product Line Product Name
`1
`Zenbook
`ZenBook Flip
`2
`Zenbook
`ZenBook Flip S13
`Zenbook S 13 Flip
`3
`Zenbook
`OLED
`Zenbook Flip 13
`Zenbook Flip 14
`Zenbook 14 Flip
`Zenbook Flip 15
`Zenbook Pro Flip 15
`Zenbook Pro 15 Flip
`VivoBook Flip 12
`VivoBook Flip 14
`VivoBook S14 Flip
`VivoBook Go 14 Flip
`VivoBook Flip 15
`VivoBook S 16 Flip
`ExpertBook B3 Flip
`
`Zenbook
`4
`Zenbook
`5
`Zenbook
`6
`Zenbook
`7
`Zenbook
`8
`Zenbook
`9
`10 VivoBook
`11 VivoBook
`12 VivoBook
`13 VivoBook
`14 VivoBook
`15 VivoBook
`16
`ExpertBook
`
`No. Product Line Product Name
`17
`ExpertBook
`ExpertBook B5 Flip
`18
`ExpertBook
`ExpertBook B7 Flip
`19 NovaGo
`NovaGo
`20 ASUS
`BR1100F (11.6 inch)
`21 ASUS
`Q304UA (13.3 inch)
`22 ASUS
`Q325UA (13.3 inch)
`23 ASUS
`Q504UA (15.6 inch)
`24 ASUS
`Q505UA (15.6 inch)
`25 ASUS
`Q524 (15.6 inch)
`26 ASUS
`Q525 (15.6 inch)
`27 ASUS
`Q526 (15.6 inch)
`28 ASUS
`Q536 (15.6 inch)
`Transformer Book
`29
`Transformer
`Flip
`ROG Flow X13
`ROG Flow X16
`
`ROG
`ROG
`
`30
`31
`
`The claim charts attached as Exhibits A-H identify where each element of each Asserted
`
`Claim is found within the Zenbook Flip 13 (UX363). Based upon the information reasonably
`
`available to LiTL and the limited documents that ASUS has produced to date, LiTL contends that
`
`the Zenbook Flip 13 (UX363) is representative of each Accused Product because each Accused
`
`Product operates in substantially the same manner as the Zenbook Flip 13 (UX363) insofar as the
`
`limitations of the asserted claims of the Asserted Patents are concerned. LiTL reserves the right to
`
`3
`
`

`

`amend its identification of a representative product pending ASUS’s production of the additional
`
`documents that it is obligated to produce.
`
`LiTL contends that for each asserted claim, unless otherwise specified in the claim charts,
`
`each claim limitation is literally present in each of the Accused Products identified above. LiTL
`
`reserves the right to supplement its initial claim charts in light of ASUS’s discovery responses and
`
`in light of additional information identified in discovery. To the extent that ASUS contends that
`
`the Accused Products do not infringe any claim elements literally, ASUS infringes under the
`
`Doctrine of Equivalents (“DOE”). LiTL reserves the right to supplement its initial claim charts to
`
`detail how the Accused Products infringe the Asserted Patents under DOE.
`
`YOUNG CONAWAY STARGATT &
`TAYLOR, LLP
`
`/s/Adam W. Poff
`Adam W. Poff (#3990)
`Robert M. Vrana (#5666)
`Alexis Stombaugh (#6702)
`Rodney Square
`1000 North King Street
`Wilmington, DE 19801
`(302) 571-6600
`apoff@ycst.com
`rvrana@ycst.com
`astombaugh@ycst.com
`
`Counsel for LiTL LLC
`
`Date: April 1, 2024
`
`OF COUNSEL:
`
`Michael A. Albert
`Eric J. Rutt
`Gerald B. Hrycyszyn
`Suresh Rav
`Jason W. Balich
`Jie Xiang
`Kevin Y. Li
`WOLF, GREENFIELD & SACKS, P.C.
`600 Atlantic Avenue
`Boston, MA 02210
`(617) 646-8000
`malbert@wolfgreenfield.com
`erutt@WolfGreenfield.com
`ghrycyszyn@wolfgreenfield.com
`srav@wolfgreenfield.com
`jbalich@wolfgreenfield.com
`jxiang@wolfgreenfield.com
`kli@wolfgreenfield.com
`
`(cid:23)
`
`

`

`EXHIBIT F
`EXHIBIT F
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`LiTL’s provision of supporting evidence for the preamble should not be construed as an admission that the preamble is limiting. Furthermore, the contentions in this chart are
`based on the limited discovery received from ASUS to date. LiTL reserves the right to supplement these infringement contentions as additional information becomes available.
`Further, to the extent that ASUS contends that its products do not infringe any claim elements literally, ASUS nevertheless infringes under the Doctrine of Equivalents.
`Claim 9,880,715 Claims
`Zenbook Flip 13 (UX363)
`A customized user
`1[a]
`The Zenbook Flip 13 (UX363) includes a customized user interface to display computer content on a display component of a computer system including a
`interface to display
`keyboard. For example:
`computer content on a
`display component of a
`computer system including a
`keyboard, the user interface
`comprising:
`
`ASUS_0002331 at ASUS_0002376
`
`1
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`
`Zenbook Flip 13 (UX363)
`
`
` Id. at ASUS_0002377
`
`
`
`
`
`
`2
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`1[b]
`
`at least one processor
`operatively connected to a
`memory of the computer
`system
`
`The Zenbook Flip 13 (UX363) includes a processor operatively connected to a memory of the computer system. For example:
`
`
`
`
`
`
`
`https://www.youtube.com/watch?v=GG1hTpHLMjM at 2:40
`
`ASUS_0000117 at ASUS_0000117
`
`3
`
`
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`
`Zenbook Flip 13 (UX363)
`
`ASUS_0000117 at ASUS_0000118
`The Zenbook Flip 13 (UX363) includes a graphical user interface that executes on the processor and is configured to display the computer content on the
`display component of the computer system. For example:
`
`
`
`1[c]
`
`a graphical user interface,
`executing on the at least one
`processor, configured to
`display the computer
`content on the display
`component of the computer
`system,
`
`
`
`
`
`
`
`
`
`
`4
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`the graphical user interface
`1[d]
`configured to: display a
`plurality of views of a
`plurality of visual
`representations of computer
`content, wherein the
`computer content includes
`at least one of selectable
`digital content, selectable
`computer operations and
`passive digital content;
`
`
`
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a graphical user interface configured to display a plurality of views of a plurality of visual representations of
`computer content, wherein the computer content includes at least one of selectable digital content, selectable computer operations and passive digital
`content. For example:
`
`
`
`
`
`
`5
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`1[e]
`an execution component,
`executing on the at least one
`processor, configured to:
`detect a current computer
`system configuration from at
`least a first computer
`system configuration where
`the keyboard is operable to
`receive input from an
`operator of the computer
`system to control the
`computer system and
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes an execution component that executes on the processor and is configured to detect a current computer system
`configuration from at least a first computer system configuration where the keyboard is operable to receive input from an operator of the computer system
`to control the computer system. For example:
`
`
`For example, the Zenbook Flip 13 (UX363) includes sensors and software that, upon information and belief, interact with the processor to detect a current
`computer system configuration. For example, some sensors are noted below:
`
`
`
`6
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`
`Zenbook Flip 13 (UX363)
`For example, Microsoft’s SensorExplorer app (depicted below) indicates that the Zenbook Flip 13 (UX363) includes an accelerometer that, upon
`information and belief, interacts with the processor to detect a current computer system configuration.
`
`
`
`
`
`
`
`
`
`
`7
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes an execution component that executes on the processor and is configured to detect a current computer system
`configuration from at least a second computer system configuration where the keyboard is inoperable to receive input from the operator of the computer
`system to control the computer system. For example:
`
`Claim 9,880,715 Claims
`a second computer system
`1[f]
`configuration where the
`keyboard is inoperable to
`receive input from the
`operator of the computer
`system to control the
`computer system;
`
`
`
`For example, the Zenbook Flip 13 (UX363) includes sensors and software that, upon information and belief, interact with the processor to detect a current
`computer system configuration. For example, some sensors are noted above for limitation 1[e].
`
`For example, the keyboard is automatically disabled when the Zenbook Flip 13 (UX363) is in the second computer system configuration (e.g., when the
`computer is placed in Stand or Tent mode):
`
`
`
`
`
`8
`
`ASUS_0002331 at ASUS_0002377
`
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`select one of the plurality of
`1[g]
`views for display on the
`computer system in response
`to the detected current
`computer system
`configuration; and
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes an execution component that executes on the processor and is configured to select one of the plurality of views for
`display on the computer system in response to the detected current computer system configuration. For example:
`
`
`
`
`
`9
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`1[h]
`transition the display
`component to the selected
`one of the plurality of
`views.
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes an execution component that executes on the processor and is configured to transition the display component to
`the selected one of the plurality of views. For example:
`
`
`
`
`
`10
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a user interface, wherein in the plurality of views includes a home view configured to organize a plurality of
`content modes and a channel view configured to organize at least one of a single content mode and two content modes. For example:
`
`
`Claim 9,880,715 Claims
`2
`The user interface of claim
`1, wherein in the plurality
`of views includes a home
`view configured to organize
`a plurality of content
`modes and a channel view
`configured to organize at
`least one of a single content
`mode and two content
`modes.
`
`
`
`
`
`
`
`
`
`
`11
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`
`Zenbook Flip 13 (UX363)
`
`
`
`
`
`12
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`For example, the single content mode (e.g., a link to a webpage containing a news story from a source, e.g., Reuters) links to the underlying content (e.g.,
`the news story) and other news stories from the same source.
`
`
`
`
`
`
`13
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`
`Zenbook Flip 13 (UX363)
`
`
`
`
`
`
`
`14
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`4 [a]
`
`The user interface of claim
`1, wherein the plurality of
`views includes a home view
`organizing a plurality of
`visual representations of
`digital content,
`
`The Zenbook Flip 13 (UX363) includes a plurality of views that includes a home view organizing a plurality of visual representations of digital content.
`For example, the taskbar can be positioned at the top of the view instead of at the bottom:
`
`
`
`
`
`
`
`15
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`wherein the home view
`4 [b]
`comprises a header display
`and a body display, and
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a home view that comprises a header display and a body display. For example:
`
`
`
`
`
`
`
`16
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`wherein the header display
`4 [c]
`comprises a lateral frame
`extending from the left of the
`display component to the
`right of the display
`component,
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a header display that comprises a lateral frame extending from the left of the display component to the right of the
`display component. For example:
`
`
`
`
`
`
`
`17
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`wherein the body display is
`4 [d]
`rendered below the header
`display in the display
`component of the computer
`system.
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a body display that is rendered below the header display in the display component of the computer system. For
`example:
`
`
`The Zenbook Flip 13 (UX363) includes a computer system configuration that comprises a physical positioning of a computer system display relative to a
`base of the computer system that includes the keyboard about a longitudinal axis of rotation. For example:
`
`5
`
`The user interface of claim
`4, wherein the computer
`system configuration
`comprises a physical
`positioning of a computer
`system display relative to a
`base of the computer system
`that includes the keyboard
`about a longitudinal axis of
`rotation.
`
`
`
`18
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`6 [a]
`The user interface of claim
`4, wherein the graphical user
`interface is further
`configured to display a
`search tool displayed in the
`header display,.
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a graphical user interface that is further configured to display a search tool displayed in the header display. For
`example:
`
`
`
`
`
`
`
`19
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a search tool that is configured to accept search terms entered by a user and, in response to execution, causes the
`computer system to navigate to a view of a first visual representation of digital content. For example:
`
`Claim 9,880,715 Claims
`wherein the search tool is
`6 [b]
`configured to accept search
`terms entered by a user and
`in response to execution,
`causes the computer system
`to navigate to a view of a
`first visual representation
`of digital content,
`
`
`
`
`
`
`20
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`
`Zenbook Flip 13 (UX363)
`
`
`
`
`
`
`21
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`6 [c]
`wherein the digital content
`includes a search engine,
`and the search engine
`presents results for the
`search terms.
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes digital content that includes a search engine and the search engine presents results for the search terms. For
`example:
`
`
`
`
`
`
`22
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`7
`The user interface of claim
`1, further comprising a
`storage component
`configured to retain a
`previous view state.
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a storage component configured to retain a previous view state. For example:
`
`ASUS_0000117 at ASUS_0000118
`
`
`
`
`
`
`23
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes an execution component that is further configured to cause the computer system to transition to a previous view in
`response to execution of a navigation element by a user. For example:
`
`Claim 9,880,715 Claims
`8
`The user interface of claim
`7, wherein the execution
`component is further
`configured to cause the
`computer system to
`transition to a previous view
`in response to execution of a
`navigation element by a
`user.
`
`
`
`24
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`9
`
`The user interface of claim
`7, further comprising the
`navigation element
`displayed in a header
`display.
`
`The Zenbook Flip 13 (UX363) includes a navigation element displayed in a header display. For example, the taskbar can be positioned at the top of the
`view instead of at the bottom:
`
`
`
`25
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`
`Zenbook Flip 13 (UX363)
`
`
`
`
`
`
`
`
`
`
`
`26
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`12
`The user interface of claim
`4, wherein the graphical user
`interface is further
`configured to display a
`nascent card in the home
`view, wherein the nascent
`card is configured to permit
`generation of additional
`visual representations of
`digital content.
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a graphical user interface further configured to display a nascent card in the home view, wherein the nascent card
`is configured to permit generation of additional visual representations of digital content.
`
`For example, the Zenbook Flip 13 (UX363) allows the user to generate and pin an additional visual representation (e.g., icon) associated with digital
`content (e.g., an underlying application) to the home view by selecting the search icon in the taskbar and then right-clicking or pointing to and holding a
`representation of digital content (e.g., the Paint app icon) and selecting the ‘Pin to Start’ option in the nascent card (e.g., the dialog box) that appears, as
`depicted below:
`
`
`
`27
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`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`
`Zenbook Flip 13 (UX363)
`
`
`
`28
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`14
`The user interface of claim
`1, wherein the plurality of
`views includes a quick
`access view configured to
`permit user generation of a
`mapping between digital
`content and a visual
`representation.
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a plurality of views that includes a quick access view configured to permit user generation of a mapping between
`digital content and a visual representation.
`
`For example, a user may select the search icon in the taskbar to open the quick access view, which permits the user to pin a visual representation (e.g.,
`icon) associated with digital content (e.g., an underlying application) to one of the plurality of views by right-clicking or pointing to and holding an image
`of digital content in the quick access view and selecting the ‘Pin to Start’ option, as depicted below:
`
`
`
`
`
`
`
`
`
`29
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`15
`The user interface of claim
`1, wherein the plurality of
`views includes a channel
`view including a channel
`selector that displays a
`sequence of visual
`representations.
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a user interface, wherein the plurality of views includes a channel view including a channel selector that displays
`a sequence of visual representations. For example:
`
`
`
`
`
`
`
`
`30
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a user interface, wherein the execution component is further configured to transition the computer system to the
`channel view in response to receiving user input via at least one input device integral to or operatively connected with the computer system. For example:
`
`
`Claim 9,880,715 Claims
`16
`The user interface of claim
`15, wherein the execution
`component is further
`configured to transition the
`computer system to the
`channel view in response to
`receiving user input via at
`least one input device
`integral to or operatively
`connected with the computer
`system.
`
`17[a] A customized user
`interface to display
`computer content on a
`display component of a
`computer system including a
`keyboard, the user interface
`comprising:
`
`
`
`
`The Zenbook Flip 13 (UX363) includes a customized user interface to display computer content on a display component of a computer system including a
`keyboard, the user interface comprising.
`
`For example, see limitation 1[a].
`
`
`
`
`31
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes at least one processor operatively coupled to a memory of the computer system.
`
`For example, see limitation 1[b].
`
`The Zenbook Flip 13 (UX363) includes a graphical user interface, executing on at least one processor, configured to display a plurality of views of a
`plurality of visual representations of the computer content. For example:
`
`17[c]
`
`Claim 9,880,715 Claims
`at least one processor
`17[b]
`operatively coupled to a
`memory of the computer
`system;
`a graphical user interface,
`executing on at least one
`processor, configured to
`display a plurality of views
`of a plurality of visual
`representations of the
`computer content;
`
`
`
`
`
`
`
`32
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes an execution component, executing on the at least one processor, configured to identify at least a first computer
`system configuration where the keyboard is operable to receive input from an operator of the computer system to control the computer system. For
`example:
`
`
`Claim 9,880,715 Claims
`17[d]
`an execution component,
`executing on the at least one
`processor, configured to:
`identify at least a first
`computer system
`configuration where the
`keyboard is operable to
`receive input from an
`operator of the computer
`system to control the
`computer system and
`
`
`For example, the Zenbook Flip 13 (UX363) includes sensors and software that, upon information and belief, interact with the processor to identify at least
`a first computer system configuration. For example, some sensors are noted above for limitation 1[e].
`
`
`
`
`33
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes an execution component, executing on the at least one processor, configured to identify at least a second computer
`system configuration where the keyboard is inoperable to receive input from the operator of the computer system to control the computer system based on
`sensor input indicating a position of the display component. For example:
`
`
`Claim 9,880,715 Claims
`a second computer system
`17[e]
`configuration where the
`keyboard is inoperable to
`receive input from the
`operator of the computer
`system to control the
`computer system based on
`sensor input indicating a
`position of the display
`component;
`
`
`For example, the Zenbook Flip 13 (UX363) includes sensors and software that, upon information and belief, interact with the processor to identify at least
`a second computer system configuration where the keyboard is inoperable to receive input from the operator of the computer system to control the
`computer system based on sensor input indicating a position of the display component. For example, some sensors are noted above for limitation 1[e].
`
`For example, the keyboard is automatically disabled when the Zenbook Flip 13 (UX363) is in easel mode or frame mode.
`
`For example, see limitation 1[f].
`
`
`
`
`
`
`
`
`34
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`17[f]
`select, responsive to the
`sensor input, a first content
`view from the plurality of
`views for the first computer
`system configuration;
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes an execution component that is configured to select, responsive to the sensor input, a first content view from the
`plurality of views for the first computer system configuration. For example:
`
`
`
`
`
`
`35
`
`
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes an execution component that is configured to transition, automatically in response to the sensor input, the display
`component between at least the first content view of the plurality of views and a second content view of the plurality of views. For example:
`
`
`The Zenbook Flip 13 (UX363) includes an execution component that is configured to receive user input via at least one input device integral to or
`operatively connected with the computer system; and transition, automatically in response to receiving the user input, the display component from one of
`the first content view and the second content view to a channel view including a channel selector that displays a sequence of visual representations. For
`example:
`
`Claim 9,880,715 Claims
`17[g]
`transition, automatically in
`response to the sensor input,
`the display component
`between at least the first
`content view of the
`plurality of views and a
`second content view of the
`plurality of views;
`
`17[h]
`
`receive user input via at least
`one input device integral to
`or operatively connected
`with the computer system;
`and transition, automatically
`in response to receiving the
`user input, the display
`component from one of the
`first content view and the
`second content view to a
`channel view including a
`channel selector that
`displays a sequence of
`visual representations.
`
`
`
`
`
`36
`
`
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`
`Zenbook Flip 13 (UX363)
`
`
`
`
`
`37
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`
`Zenbook Flip 13 (UX363)
`
`
`
`
`
`
`
`38
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a user interface, wherein the first mode is a laptop mode where the keyboard is oriented to be accessible to the
`operator and wherein the second mode is an easel mode or a frame mode where the keyboard is oriented to be inaccessible to the operator. For example:
`
`
`Claim 9,880,715 Claims
`The user interface of claim
`19
`1, wherein the first mode is
`a laptop mode where the
`keyboard is oriented to be
`accessible to the operator
`and wherein the second
`mode is an easel mode or a
`frame mode where the
`keyboard is oriented to be
`inaccessible to the operator.
`
`
` ASUS_0002331 at ASUS_0002376
`
`
`
`
`https://www.youtube.com/watch?v=9W7FWNjMc3w&t=20s at 0:44
`
`39
`
`

`

`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Claim 9,880,715 Claims
`
`Zenbook Flip 13 (UX363)
`
`
` ASUS_0002331 at ASUS_0002377
`
`
`
`https://www.youtube.com/watch?v=9W7FWNjMc3w&t=20s at 0:31
`
`
`
`40
`
`

`

`20[b]
`
`20[c]
`
`Claim 9,880,715 Claims
`20[a] A customized user
`interface to display
`computer content on a
`display component of a
`computer system including a
`keyboard, the user interface
`comprising:
`at least one processor
`operatively connected to a
`memory of the computer
`system;
`a graphical user interface,
`executing on the at least one
`processor, configured to
`display the computer
`content on the display
`component of the computer
`system,
`the graphical user interface
`configured to: display a
`plurality of views of a
`plurality of visual
`representations of computer
`content, wherein the
`computer content includes
`at least one of selectable
`digital content, selectable
`computer operations and
`passive digital content;
`
`20[d]
`
`EXHIBIT F: INITIAL CLAIM CHARTS REGARDING ASUS’S INFRINGEMENT OF U.S. PATENT NO. 9,880,715
`
`Zenbook Flip 13 (UX363)
`The Zenbook Flip 13 (UX363) includes a customized user interface to display computer content on a display component of a computer system including a
`keyboard.
`
`For example, see limitation 1[a].
`
`
`
`
`The Zenbook Flip 13 (UX363) includes at least one processor operatively connected to a memory of the computer system.
`
`For example, see limitation 1[b].
`
`The Zenbook Flip 13 (UX363) includes a graphical user interface, executing on the at least one processor, configured to display the computer content on
`the display component of the computer system.
`
`For example, see limitation 1[c].
`
`
`
`The Zenbook Flip 13 (UX363) includes a graphical user interface configured to d

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