Exhibit A-138
`
`Claim Chart for Note 10+
`
`APPLE 1017
`
`1
`
`
`
`Claim Chart for Note 10+
`
`APPLE 1017
`
`1
`
`
`
`The Note 10+ (“Accused Device”) infringes all 18 claims of U.S. Patent No. 7,749,641 as addressed in further detail below:1
`
`Claim Element
`1. A method for
`improving the
`capacity, average
`operating voltage and
`specific energy of a
`secondary lithium ion
`cell or battery,
`characterized in that
`
`Identification of Element in Accused Device
`To the extent the preamble is limiting, each element recited in the preamble is practiced in the infringing method.
`
`The Accused Device is designed and operates in such manner that Samsung Electronics Co. Ltd. and Samsung
`Electronics America, Inc. (“Defendants” or “Samsung”), and Defendants’ customers and/or other product end users of
`the Accused Device directly infringe this claim when they use the Accused Device as it is designed to operate and/or
`follow the instructions described in various materials with which Samsung induces its users to use the Accused Device.
`
`For example, by using the Accused Device—which includes a secondary (i.e., rechargeable) lithium ion cell or battery,
`as shown below—in the manner induced by Samsung, Samsung and Samsung’s customers and/or other end users of the
`Accused Device practice a method by which they improve the capacity, operating voltages, and specific energy of the
`lithium ion battery of the Accused Device.
`
`1 Plaintiff’s contentions are based on publicly available information concerning Defendants’ Accused Devices. Discovery has not
`begun as of the date that these contentions were served on Defendants. Therefore, as Plaintiff expects evidence to come to light in fact
`and expert discovery, Plaintiff reserves the right to amend its infringement contentions to reflect such evidence and expert opinions
`obtained and/or developed through fact and expert discovery, as provided for by the Court’s scheduling order.
`
`2
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`
`https://www.ebay.com/itm/402658592659
`
`the charge cut-off
`voltage of the
`secondary lithium ion
`cell or battery is
`greater than 4.2V but
`less than 5.8 V
`
`The Accused Device is designed and operates in such manner that Defendants, Defendants’ customers, and/or other end
`users of the Accused Device, practice a method in which the charge cut-off voltage of the secondary lithium ion battery
`of the Accused Device is greater than 4.2V but less than 5.8V when they use the product as it is designed to operate
`and/or follow the instructions described in various materials with which Samsung induces its users to use the
`aforementioned product.
`
`Upon information and belief, the charging of the secondary lithium ion cell or battery of the Accused Device is regulated
`by a combination of (a) circuitry within the device (including one or more of the battery management system, circuitry
`external to the battery, and/or circuitry within housing of the battery component of the Accused Device) (which is
`connected to a power supply), in combination with (b) software (including one or more of the operating system, battery
`management software and relevant firmware, some of which may be implemented in hardware), such that the charge cut-
`off voltage recited in the claim is within the claimed range.
`
`2
`
`3
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`
`For example, the batteries in the Accused Device are used in such manner as to have a charging voltage of 4.4V.
`
`https://www.ebay.com/itm/402658592659
`
`
`and a ratio of positive
`electrode material to
`negative electrode
`material of the
`secondary lithium ion
`cell or battery is from
`1:1.0 to 1:2.5 as
`calculated by a
`specific capacity with
`
`The Accused Device is designed and operates in such manner that Samsung, Samsung’s customers, and/or other end
`users of the Accused Device, use a battery in which the ratio of positive electrode material to negative electrode material
`in the secondary lithium ion battery included in the Accused Device is from 1:1.0 to 1:2.5, as calculated by a specific
`capacity with a charge voltage limited to 4.2V. In other words, the secondary lithium ion cell or battery in the Accused
`Device includes positive and negative electrodes for which the ratio of positive electrode material to negative electrode
`material is from 1:1.0 to 1:2.5, as calculated by a specific capacity with a charge voltage limited to 4.2V.
`
`Plaintiff expects that materials produced by Samsung and/or otherwise obtained through discovery will establish that the
`ratio of positive electrode material to negative electrode material is from 1:1.0 to 1:2.5, as calculated by a specific
`
`3
`
`4
`
`
`
`Claim Element
`a charge voltage
`limited to 4.2 V
`2. A method according
`to claim 1,
`characterized in that
`the charge cut-off
`voltage of the
`secondary lithium ion
`cell or battery is
`within a range from
`4.3 V to 5.2 V.
`
`Identification of Element in Accused Device
`capacity with a charge voltage limited to 4.2V.
`
`The Accused Device is designed and operates in such manner that Defendants, Defendants’ customers, and/or other
`product end users infringe claim 1, as set forth above, and also claim 2, as the charge cut-off voltage of the secondary
`lithium ion cell or battery is within a range from 4.3V to 5.2V.
`
`Upon information and belief, the charging of the secondary lithium ion cell or battery of the Accused Device is regulated
`by a combination of (a) circuitry within the device (including one or more of the battery management system, circuitry
`external to the battery, and/or circuitry within housing of the battery component of the Accused Device) (which is
`connected to a power supply), in combination with (b) software (including one or more of the operating system, battery
`management software and relevant firmware, some of which may be implemented in hardware), such that the charge cut-
`off voltage recited in the claim is within the claimed range.
`
`For example, the batteries in the Accused Device are used in such manner as to have a charging voltage of 4.4V.
`
`4
`
`5
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`https://www.ebay.com/itm/402658592659
`
`3. A method according
`to claim 1,
`characterized in that
`the charge cut-off
`voltage of the
`secondary lithium ion
`cell or battery is
`within a range from
`4.3 V to 4.8 V.
`
`The Accused Device is designed and operates in such manner that Defendants, Defendants’ customers, and/or other
`product end users infringe claim 1, as set forth above, and also claim 3, as the charge cut-off voltage of the secondary
`lithium ion cell or battery is within a range from 4.3V to 4.8V.
`
`Upon information and belief, the charging of the secondary lithium ion cell or battery of the Accused Device is regulated
`by a combination of (a) circuitry within the device (including one or more of the battery management system, circuitry
`external to the battery, and/or circuitry within housing of the battery component of the Accused Device) (which is
`connected to a power supply), in combination with (b) software (including one or more of the operating system, battery
`management software and relevant firmware, some of which may be implemented in hardware), such that the charge cut-
`off voltage recited in the claim is within the claimed range.
`
`For example, the batteries in the Accused Device are used in such manner as to have a charging voltage of 4.4V.
`
`5
`
`6
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`
`https://www.ebay.com/itm/402658592659
`
`
`The Accused Device is designed and operates in such manner that Defendants, Defendants’ customers, and/or other
`product end users infringe claim 1, as set forth above, and also claim 4, as the ratio of positive electrode material to
`negative electrode material in the secondary lithium ion cell or battery used by the Accused Device is from 1:1.15 to
`1:2.5, as calculated by a specific capacity with a charge voltage limited to 4.2V. In other words, the secondary lithium
`ion cell or battery in the Accused Device includes positive and negative electrodes for which the ratio of positive
`electrode material to negative electrode material is from 1:1.15 to 1:2.5, as calculated by a specific capacity with a
`charge voltage limited to 4.2V.
`
`Plaintiff expects that materials produced by Samsung and/or otherwise obtained through discovery will establish that the
`ratio of positive electrode material to negative electrode material is between 1:1.15 and 1:2.5.
`
`4. A method according
`to claim 1,
`characterized in that
`the
`ratio of positive
`electrode material to
`negative electrode
`material of the
`secondary lithium ion
`cell or battery is from
`1:1.15
`to 1:2.5.
`
`6
`
`7
`
`
`
`Claim Element
`5. A secondary lithium
`ion cell or battery,
`characterized in that
`
`Identification of Element in Accused Device
`To the extent the preamble is limiting, each element recited in the preamble is present in the Accused Device.
`Samsung, by making, using, selling, importing into the United States, and/or offering for sale the Accused Device,
`infringes claim 5 of the Asserted Patent.
`
`The Accused Device includes a secondary lithium ion cell or battery.
`
`https://www.ebay.com/itm/402658592659
`
`
`the secondary lithium
`ion cell or battery has
`a charge cut-off
`voltage of greater than
`4.2V but less than 5.8
`V
`
`The secondary lithium ion cell or battery in the Accused Device, further, has a charge cut-off voltage that is greater than
`4.2V but less than 5.8V.
`
`Upon information and belief, the charging of the secondary lithium ion cell or battery of the Accused Device is regulated
`by a combination of (a) circuitry within the device (including one or more of the battery management system, circuitry
`external to the battery, and/or circuitry within housing of the battery component of the Accused Device) (which is
`
`7
`
`8
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`connected to a power supply), in combination with (b) software (including one or more of the operating system, battery
`management software and relevant firmware, some of which may be implemented in hardware), such that the charge cut-
`off voltage recited in the claim is within the claimed range.
`
`For example, the batteries in the Accused Device are used in such manner as to have a charging voltage of 4.4V.
`
`https://www.ebay.com/itm/402658592659
`
`
`and a ratio of positive
`electrode material to
`negative electrode
`material of the
`secondary lithium ion
`cell or battery is from
`
`The secondary lithium ion cell or battery in the Accused Device has a ratio of positive electrode material to negative
`electrode material from 1:1.0 to 1:2.5, as calculated by a theoretic capacity with a charge voltage cut-off set at 4.2V. In
`other words, the secondary lithium ion cell or battery in the Accused Device includes positive and negative electrodes for
`which the ratio of positive electrode material to negative electrode material is from 1:1.0 to 1:2.5, as calculated by a
`theoretic capacity with a charge cut-off voltage set at 4.2V.
`
`8
`
`9
`
`
`
`Claim Element
`1:1.0 to 1:2.5, as
`calculated by a
`theoretic capacity with
`a charge
`cut-off voltage set at
`4.2 V
`
`6. A secondary lithium
`ion cell or battery
`according to claim 5,
`characterized in that
`the secondary lithium
`ion cell or battery has
`a charge cut-off
`voltage within a range
`from 4.3 V to 5.2 V.
`
`Identification of Element in Accused Device
`Plaintiff expects that materials produced by Samsung and/or otherwise obtained through discovery will establish that the
`ratio of positive electrode material to negative electrode material is from 1:1.0 to 1:2.5, as calculated by a theoretic
`capacity with a charge cut-off voltage set at 4.2V.
`
`Samsung, by making, using, selling, importing into the United States, and/or offering for sale the Accused Device,
`infringes claim 6 of the Asserted Patent because the Accused Device satisfies every limitation in claim 5, as set forth
`above, and further, claim 6, as the secondary lithium ion cell or battery has a charge cut-off voltage within a range from
`4.3V to 5.2V.
`
`Upon information and belief, the charging of the secondary lithium ion cell or battery of the Accused Device is regulated
`by a combination of (a) circuitry within the device (including one or more of the battery management system, circuitry
`external to the battery, and/or circuitry within housing of the battery component of the Accused Device) (which is
`connected to a power supply), in combination with (b) software (including one or more of the operating system, battery
`management software and relevant firmware, some of which may be implemented in hardware), such that the charge cut-
`off voltage recited in the claim is within the claimed range.
`
`For example, as shown in the image below, the batteries in the Accused Device are used in such manner as to have a
`charging voltage of 4.4V.
`
`9
`
`10
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`
`https://www.ebay.com/itm/402658592659
`
`
`7. A secondary lithium
`ion cell or battery
`according to claim 5,
`characterized in that
`the secondary lithium
`ion cell or battery has
`a charge cut-off
`voltage within a range
`from 4.3V to 4.8 V.
`
`Samsung, by making, using, selling, importing into the United States, and/or offering for sale the Accused Device,
`infringes claim 7 of the Asserted Patent because the Accused Device satisfies every limitation in claim 5, as set forth
`above, and further, claim 7, as the secondary lithium ion cell or battery has a charge cut-off voltage within a range from
`4.3V to 4.8V.
`
`Upon information and belief, the charging of the secondary lithium ion cell or battery of the Accused Device is regulated
`by a combination of (a) circuitry within the device (including one or more of the battery management system, circuitry
`external to the battery, and/or circuitry within housing of the battery component of the Accused Device) (which is
`connected to a power supply), in combination with (b) software (including one or more of the operating system, battery
`management software and relevant firmware, some of which may be implemented in hardware), such that the charge cut-
`off voltage recited in the claim is within the claimed range.
`
`10
`
`11
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`For example, as shown in the image below, the batteries in the Accused Device are used in such manner as to have a
`charging voltage of 4.4V.
`
`https://www.ebay.com/itm/402658592659
`
`
`8. A secondary lithium
`ion cell or battery
`according to claim 5,
`characterized in that
`the ratio of positive
`electrode material to
`negative electrode
`material of the
`secondary lithium ion
`
`Samsung, by making, using, selling, importing into the United States, and/or offering for sale the Accused Device,
`infringes claim 8 of the Asserted Patent because the Accused Device satisfies every limitation in claim 5, as set forth
`above, and further, claim 8, as the ratio of positive electrode material to negative electrode material in the secondary
`lithium ion cell or battery as implemented and used by the Accused Device is from 1:1.15 to 1:2.5, as calculated by a
`theoretic capacity with a charge cut-off voltage set at 4.2V, thereby infringing this claim as well. In other words, the
`secondary lithium ion cell or battery in the Accused Device includes positive and negative electrodes for which the ratio
`of positive electrode material to negative electrode material is from 1:1.15 to 1:2.5, as calculated by a theoretic capacity
`with a charge cut-off voltage set at 4.2V.
`
`11
`
`12
`
`
`
`Claim Element
`cell or battery is from
`1:1.15 to 1:2.5.
`
`Identification of Element in Accused Device
`Plaintiff expects that materials produced by Samsung and/or otherwise obtained through discovery will establish that the
`ratio of positive electrode material to negative electrode material is from 1:1.15 to 1:2.5.
`
`9. A secondary lithium
`ion cell or battery
`according to claim 5,
`characterized in that
`
`the secondary lithium
`ion cell or battery has
`a first overcharging
`protection voltage of
`greater than 4.35V
`
`Samsung, by making, using, selling, importing into the United States, and/or offering for sale the Accused Device,
`infringes claim 9 of the Asserted Patent because the Accused Device satisfies every limitation in claim 5, as set forth
`above, and the Accused Device also satisfies the additional limitations in claim 9, as set forth below.
`
`The Accused Device includes a secondary lithium ion cell or battery that has a first overcharging protection voltage of
`greater than 4.35V.
`
`
`Upon information and belief, the Accused Device features overcharging protection implemented in a combination of (a)
`circuitry within the device (including one or more of the battery management system, circuitry external to the battery,
`and/or circuitry within housing of the battery component of the Accused Device) (which is connected to a power supply),
`in combination with (b) software (including one or more of the operating system, battery management software and
`relevant firmware, one or more of which may be implemented in hardware), such that the overcharging protection
`voltage is greater than 4.35V.
`
`The battery used in the Accused Device operates with a charging voltage of 4.4V during normal operation. This is more
`than the overcharging protection voltage of this claim.
`
`12
`
`13
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`
`https://www.ebay.com/itm/402658592659
`
`
`and an overcharging
`protection release
`voltage of greater than
`4.15 V
`
`Therefore, upon information and belief, the battery used in the Accused Device has an overcharge protection voltage of
`more than 4.35V.
`
`The Accused Device includes a battery that has an overcharging protection release voltage of greater than 4.15V.
`
`Upon information and belief, the Accused Device features overcharging protection implemented in a combination of (a)
`circuitry within the device (including one or more of the battery management system, circuitry external to the battery,
`and/or circuitry within housing of the battery component of the Accused Device) (which is connected to a power supply),
`in combination with (b) software (including one or more of the operating system, battery management software and
`relevant firmware, one or more of which may be implemented in hardware), such that the overcharging protection
`release voltage is greater than 4.15V.
`
`
`13
`
`14
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`The battery used in the Accused Device operates with a charging voltage of 4.4V, during normal operation. This is more
`than the overcharge protection voltage and far more than the overcharge release voltage of this claim.
`
`https://www.ebay.com/itm/402658592659
`
`
`10. A secondary
`lithium ion cell or
`battery according to
`claim 9, characterized
`in that
`the secondary lithium
`ion cell or battery has
`
`Therefore, upon information and belief, the battery used in the Accused Device has an overcharge protection release
`voltage of more than 4.15V.
`Samsung, by making, using, selling, importing into the United States, and/or offering for sale the Accused Device,
`infringes claim 10 of the Asserted Patent because the Accused Device satisfies every limitation in claims 5 and 9, as set
`forth above, and the Accused Device also satisfies the additional limitations in claim 10, as set forth below.
`
`The Accused Device includes a secondary lithium ion cell or battery that has a first overcharging protection voltage of
`greater than 4.45V.
`
`14
`
`15
`
`
`
`Claim Element
`a first overcharging
`protection voltage of
`greater than 4.45 V
`
`Identification of Element in Accused Device
`
`Upon information and belief, the Accused Device features overcharging protection implemented in a combination of (a)
`circuitry within the device (including one or more of the battery management system, circuitry external to the battery,
`and/or circuitry within housing of the battery component of the Accused Device) (which is connected to a power supply),
`in combination with (b) software (including one or more of the operating system, battery management software and
`relevant firmware, one or more of which may be implemented in hardware), such that the overcharging protection
`voltage is greater than 4.45V.
`
`The battery used in the Accused Device operates with a charging voltage of 4.4V, during normal operation. This is
`approximately the overcharging protection voltage of this claim.
`
`https://www.ebay.com/itm/402658592659
`
`
`Therefore, upon information and belief, the battery used in the Accused Device has an overcharge protection voltage of
`
`15
`
`16
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`more than 4.45V.
`
`and an overcharge
`protection release
`voltage of greater than
`4.25 V
`
`The Accused Device includes a secondary lithium ion cell or battery that has a first overcharging protection release
`voltage of greater than 4.25V.
`
`Upon information and belief, the Accused Device features overcharging protection implemented in a combination of (a)
`circuitry within the device (including one or more of the battery management system, circuitry external to the battery,
`and/or circuitry within housing of the battery component of the Accused Device) (which is connected to a power supply),
`in combination with (b) software (including one or more of the operating system, battery management software and
`relevant firmware, one or more of which may be implemented in hardware), such that the overcharging protection
`release voltage is greater than 4.25V.
`
`The battery used in the Accused Device operates with a charging voltage of 4.4V, during normal operation. This is far
`more than the overcharge release voltage of this claim.
`
`16
`
`17
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`https://www.ebay.com/itm/402658592659
`
`
`Therefore, upon information and belief, the battery used in the Accused Device has an overcharge protection release
`voltage of more than 4.25V.
`
`Samsung, by making, using, selling, importing into the United States, and/or offering for sale the Accused Device,
`infringes claim 11 of the Asserted Patent because the Accused Device satisfies every limitation in claim 5, as set forth
`above, and further, claim 11, as the secondary lithium ion cell or battery in the Accused Device maintains at least 75% of
`capacity after 400 cycles.
`
`For example, as can be seen from Samsung’s warranty, excerpted below, the battery used in the Accused Device is
`warranted to maintain at least 80% capacity for at least one year.
`
`11. A secondary
`lithium ion cell or
`battery according to
`claim 5, wherein the
`secondary lithium ion
`cell or battery
`maintains at least 7500
`of capacity after 400
`cycles.
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty
`
`17
`
`18
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty-for-repair-parts
`
`
`12. A secondary
`lithium ion cell or
`battery according to
`claim 5, wherein the
`secondary lithium ion
`cell or battery
`maintains at least
`75.83% of capacity
`after 400 cycles.
`
`Samsung, by making, using, selling, importing into the United States, and/or offering for sale the Accused Device,
`infringes claim 12 of the Asserted Patent because the Accused Device satisfies every limitation in claim 5, as set forth
`above, and further, claim 12, as the secondary lithium ion cell or battery in the Accused Device maintains at least
`75.83% of capacity after 400 cycles.
`
`For example, as can be seen from Samsung’s warranty, excerpted below, the battery used in the Accused Device is
`warranted to maintain at least 80% capacity for at least one year.
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty-for-repair-parts
`
`
`13. A secondary
`
`Samsung, by making, using, selling, importing into the United States, and/or offering for sale the Accused Device,
`
`18
`
`19
`
`
`
`Claim Element
`lithium ion cell or
`battery according to
`claim 5, wherein the
`secondary lithium ion
`cell or battery
`maintains at least 80%
`of capacity after 400
`cycles.
`
`Identification of Element in Accused Device
`infringes claim 13 of the Asserted Patent because the Accused Device satisfies every limitation in claim 5, as set forth
`above, and further, claim 13, as the secondary lithium ion cell or battery in the Accused Device maintains at least 80% of
`capacity after 400 cycles.
`
`For example, as can be seen from Samsung’s warranty, excerpted below, the battery used in the Accused Device is
`warranted to maintain at least 80% capacity for at least one year.
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty-for-repair-parts
`
`
`14. A secondary
`lithium ion cell or
`battery according to
`claim 5, wherein the
`secondary lithium ion
`
`Samsung, by making, using, selling, importing into the United States, and/or offering for sale the Accused Device,
`infringes claim 14 of the Asserted Patent because the Accused Device satisfies every limitation in claim 5, as set forth
`above, and further, claim 14, as the secondary lithium ion cell or battery in the Accused Device maintains at least
`80.72% of capacity after 400 cycles.
`
`19
`
`20
`
`
`
`Claim Element
`cell or battery
`maintains at least
`80.72% of capacity
`after 400 cycles.
`
`Identification of Element in Accused Device
`For example, as can be seen from Samsung’s warranty, excerpted below, the battery used in the Accused Device is
`warranted to maintain at least 80% capacity for at least one year.
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty-for-repair-parts
`
`
`15. A method
`according to claim 1,
`wherein the secondary
`lithium ion cell or
`battery maintains at
`least 75% of capacity
`after 400 cycles.
`
`The Accused Device is designed and operates in such manner that Defendants, Defendants’ customers, and/or other
`product end users infringe claim 1, as set forth above, and also claim 15, as the secondary lithium ion cell or battery in
`the Accused Device maintains at least 75% of capacity after 400 cycles, thereby infringing this claim.
`
`For example, as can be seen from Samsung’s warranty, excerpted below, the battery used in the Accused Device is
`warranted to maintain at least 80% capacity for at least one year.
`
`
`20
`
`21
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty-for-repair-parts
`
`
`16. A method
`according to claim 1,
`wherein the secondary
`lithium ion cell or
`battery maintains at
`least 75.83% of
`capacity after 400
`cycles.
`
`The Accused Device is designed and operates in such manner that Defendants, Defendants’ customers, and/or other
`product end users infringe claim 1, as set forth above, and also claim 16, as the secondary lithium ion cell or battery in
`the Accused Device maintains at least 75.83% of capacity after 400 cycles, thereby infringing this claim.
`
`For example, as can be seen from Samsung’s warranty, excerpted below, the battery used in the Accused Device is
`warranted to maintain at least 80% capacity for at least one year.
`
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty
`
`21
`
`22
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty-for-repair-parts
`
`
`17. A method
`according to claim 1,
`wherein the secondary
`lithium ion cell or
`battery maintains at
`least 80% of capacity
`after 400 cycles.
`
`The Accused Device is designed and operates in such manner that Defendants, Defendants’ customers, and/or other
`product end users infringe claim 1, as set forth above, and also claim 17, as the secondary lithium ion cell or battery in
`the Accused Device maintains at least 80% of capacity after 400 cycles, thereby infringing this claim.
`
`For example, as can be seen from Samsung’s warranty, excerpted below, the battery used in the Accused Device is
`warranted to maintain at least 80% capacity for at least one year.
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty
`
`22
`
`23
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty-for-repair-parts
`
`
`18. A method
`according to claim 1,
`wherein the secondary
`lithium ion cell or
`battery maintains at
`least 80.72% of
`capacity after 400.
`
`The Accused Device is designed and operates in such manner that Defendants, Defendants’ customers, and/or other
`product end users infringe claim 1, as set forth above, and also claim 18, as the secondary lithium ion cell or battery in
`the Accused Device maintains at least 80.72% of capacity after 400 cycles, thereby infringing this claim.
`
`For example, as can be seen from Samsung’s warranty, excerpted below, the battery used in the Accused Device is
`warranted to maintain at least 80% capacity for at least one year.
`
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty
`
`23
`
`24
`
`
`
`Claim Element
`
`Identification of Element in Accused Device
`
`https://www.samsung.com/us/support/legal/mobile/#standard-limited-warranty-for-repair-parts
`
`
`24
`
`25
`
`
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