`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`The Dyson V8 line1 (the “V8 Accused Products”) include each and every limitation of (at least) each of claims 1-13 of U.S. Patent No.
`10,327,607 (the “’607 Patent” and the “Asserted Claims,” respectively). The limitations of the Asserted Claims of the Asserted Patent
`are satisfied literally by the V8 Accused Products, although SharkNinja reserves the right to contend that any claim element found not
`to be literally embodied by the V8 Accused Products is present under the doctrine of equivalents because there are no substantial
`differences for each claim element, and the elements of the V8 Accused Products perform substantially the same function, in
`substantially the same way, to achieve substantially the same result as the claimed invention. SharkNinja reserves the right to amend
`these Infringement Contention charts or assert new theories of infringement, including without limitation by amending or asserting
`literal infringement or the doctrine of equivalents, in light of the Court’s claim construction or subsequent discovery. SharkNinja
`reserves the right to supplement, modify, or amend the following preliminary claim charts as discovery continues and in accordance
`with subsequent events in the litigation.
`SharkNinja’s decision to assert claims 1-13 of the ’607 Patent, but not other claims is not a concession that the V8 Accused Products do
`not infringe other unasserted claims.
`An inspection of physical samples of the V8 Accused Products, along with reviews of Dyson product literature, demonstrates
`infringement of each and every claim below but a physical sample is impossible to include in this chart; SharkNinja explicitly reserves
`the right to rely on physical samples, other photos and videos of same, the boxes and manuals included with the V8 Accused Products
`in any demonstration of infringement, including any demonstration of the presence of any of the limitations in the chart below. Discovery
`is just beginning; SharkNinja further explicitly reserves the right and ability to rely on materials yet to be produced by Dyson (or third
`parties) in order to demonstrate infringement.
`SharkNinja reserves the right to rely on the entirety of the material cited in this chart to show infringement. Citations presented for one
`claim limitation are expressly incorporated by reference into all other limitations for that claim as well as all limitations of all claims on
`which that claim depends.
`
`1 The Dyson Accused Products include the Dyson Cyclone V8™ line.
`
`1
`
`Dyson Ex1017
`Page 1
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`Claim 1
`1. A hand carriable surface cleaning
`apparatus comprising:
`
`U.S. Patent No. 10,327,607
`
`Dyson V8
`To the extent the preamble is limiting, each of the Dyson Accused Products is a hand
`carriable surface cleaning apparatus. See, e.g., https://www.dyson.com/vacuum-
`cleaners/cordless/v8.
`
`For example, the below images show a hand carriable surface cleaning apparatus.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8
`
`
`
`
`
`
`2
`
`
`
`
`
`Dyson Ex1017
`Page 2
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`a) a fluid flow path extending between
`a dirty air inlet and a clean air outlet;
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`Each of the Dyson Accused Products includes a fluid flow path extending between a dirty
`air inlet and a clean air outlet.
`
`For example, the below images show a fluid flow path extending between a dirty air inlet
`and a clean air outlet.
`
`
`
`
`
`
`3
`
`Dyson Ex1017
`Page 3
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com.mx/products/cord-free/sticks/dyson-v8/features
`
`
`
`
`4
`
`Dyson Ex1017
`Page 4
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`https://www.dyson.com.mx/products/cord-free/sticks/dyson-v8/features (annotated)
`
`
`
`
`
`
`5
`
`Dyson Ex1017
`Page 5
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8
`
`
`
`
`
`
`6
`
`Dyson Ex1017
`Page 6
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`b) a first cyclonic cleaning stage
`Each of the Dyson Accused Products includes a first cyclonic cleaning stage positioned in
`positioned in the fluid flow path
`the fluid flow path downstream from the dirty air inlet, the first cyclonic cleaning stage
`downstream from the dirty air inlet, the
`comprising an upper end, a bottom end spaced longitudinally below the upper end and a
`first cyclonic cleaning stage comprising
`side wall extending therebetween, the first cyclonic cleaning stage having a dirt collection
`an upper end, a bottom end spaced
`region with a bottom door that is openable to empty the dirt collection region.
`
`longitudinally below the upper end and
`For example, the below images show a first cyclonic cleaning stage positioned in the fluid
`a side wall extending therebetween, the
`flow path downstream from the dirty air inlet, the first cyclonic cleaning stage comprising
`first cyclonic cleaning stage having a
`an upper end, a bottom end spaced longitudinally below the upper end and a side wall
`dirt collection region with a bottom
`extending therebetween, the first cyclonic cleaning stage having a dirt collection region
`door that is openable to empty the dirt
`with a bottom door that is openable to empty the dirt collection region.
`collection region;
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`
`
`
`
`
`7
`
`Dyson Ex1017
`Page 7
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`
`
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/silver-nickel (annotated)
`
`
`
`
`8
`
`Dyson Ex1017
`Page 8
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`c) a second cyclonic cleaning stage
`positioned in the fluid flow path
`downstream from the first cyclonic
`cleaning stage, the second cyclonic
`cleaning stage having an upper end
`which is positioned above the upper
`end of the first cyclonic cleaning stage,
`the second cyclonic cleaning stage is
`longitudinally moveable relative to all
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`
`Each of the Dyson Accused Products includes a second cyclonic cleaning stage positioned
`in the fluid flow path downstream from the first cyclonic cleaning stage, the second
`cyclonic cleaning stage having an upper end which is positioned above the upper end of
`the first cyclonic cleaning stage, the second cyclonic cleaning stage is longitudinally
`moveable relative to all of the sidewall of the first cyclonic cleaning stage.
`
`For example, the below images show a second cyclonic cleaning stage positioned in the
`fluid flow path downstream from the first cyclonic cleaning stage and the second cyclonic
`cleaning stage having an upper end which is positioned above the upper end of the first
`cyclonic cleaning stage.
`
`
`
`9
`
`Dyson Ex1017
`Page 9
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`of the sidewall of the first cyclonic
`
`cleaning stage;
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`
`
`
`
`
`10
`
`Dyson Ex1017
`Page 10
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/silver-nickel (annotated)
`
`For example, the below image shows a second cyclonic cleaning stage that is
`longitudinally moveable relative to all of the sidewall of the first cyclonic cleaning stage.
`
`
`
`
`11
`
`Dyson Ex1017
`Page 11
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`d) a suction motor positioned in the
`fluid flow path downstream from the
`second cyclonic cleaning stage; and,
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`
`Each of the Dyson Accused Products includes a suction motor positioned in the fluid flow
`path downstream from the second cyclonic cleaning stage.
`
`For example, the below images show a suction motor positioned in the fluid flow path
`downstream from the second cyclonic cleaning stage.
`
`
`
`
`12
`
`Dyson Ex1017
`Page 12
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com.mx/products/cord-free/sticks/dyson-v8/features
`
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`
`
`
`
`13
`
`Dyson Ex1017
`Page 13
`
`
`
`e) a handle;
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`Each of the Dyson Accused Products includes a handle.
`
`For example, the below images show a handle.
`
`
`wherein the second cyclonic cleaning
`stage comprises a plurality of second
`cyclones connected fluidly in parallel
`with each other,
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`Each of the Dyson Accused Products includes a second cyclonic cleaning stage that
`comprises a plurality of second cyclones connected fluidly in parallel with each other.
`
`For example, the below images show a second cyclonic cleaning stage that comprises a
`plurality of second cyclones connected fluidly in parallel with each other.
`
`
`
`
`
`
`14
`
`Dyson Ex1017
`Page 14
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`
`
`
`
`
`15
`
`Dyson Ex1017
`Page 15
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`wherein the second cyclones are
`positioned around a central longitudinal
`axis that extends through the first
`cyclonic cleaning stage and the
`openable bottom door, and
`
`
`https://www.dyson.com.mx/products/cord-free/sticks/dyson-v8/features (annotated)
`
`Each of the Dyson Accused Products includes second cyclones that are positioned around
`a central longitudinal axis that extends through the first cyclonic cleaning stage and the
`openable bottom door.
`
`For example, the below images show second cyclones that are positioned around a central
`longitudinal axis that extends through the first cyclonic cleaning stage and the openable
`bottom door.
`
`
`
`
`16
`
`Dyson Ex1017
`Page 16
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com.mx/products/cord-free/sticks/dyson-v8/features
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`
`
`
`
`17
`
`Dyson Ex1017
`Page 17
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`
`
`
`18
`
`Dyson Ex1017
`Page 18
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`wherein the plurality of second
`cyclones includes a first set of second
`cyclones arranged in an inner ring and
`a second set of second cyclones
`arranged in an outer ring laterally
`surrounding the inner ring.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/silver-nickel (annotated)
`
`Each of the Dyson Accused Products includes a plurality of second cyclones that includes
`a first set of second cyclones arranged in an inner ring and a second set of second
`cyclones arranged in an outer ring laterally surrounding the inner ring.
`
`For example, the below images show a plurality of second cyclones that includes a first
`set of second cyclones arranged in an inner ring and a second set of second cyclones
`arranged in an outer ring laterally surrounding the inner ring.
`
`
`
`
`19
`
`Dyson Ex1017
`Page 19
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com.mx/products/cord-free/sticks/dyson-v8/features (annotated)
`
`
`
`
`20
`
`Dyson Ex1017
`Page 20
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`2. The hand carriable surface cleaning
`apparatus of claim 1, further
`comprising a housing containing the
`suction motor and the clean air outlet,
`wherein the bottom door is openable
`while the sidewall of the first cyclonic
`cleaning stage is connected to the
`housing.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`Each of the Dyson Accused Products includes a housing containing the suction motor and
`the clean air outlet, wherein the bottom door is openable while the sidewall of the first
`cyclonic cleaning stage is connected to the housing.
`
`For example, the below images show a housing containing the suction motor and the
`clean air outlet, wherein the bottom door is openable while the sidewall of the first
`cyclonic cleaning stage is connected to the housing.
`
`
`
`21
`
`Dyson Ex1017
`Page 21
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/silver-nickel (annotated)
`
`
`
`
`
`
`22
`
`Dyson Ex1017
`Page 22
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`3. The hand carriable surface cleaning
`apparatus of claim 1, wherein the upper
`end of the second cyclonic cleaning
`stage overlies the entire upper end of
`the first cyclonic cleaning stage.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`
`Each of the Dyson Accused Products includes an upper end of the second cyclonic
`cleaning stage that overlies the entire upper end of the first cyclonic cleaning stage.
`
`For example, the below images show an upper end of the second cyclonic cleaning stage
`that overlies the entire upper end of the first cyclonic cleaning stage.
`
`
`
`
`23
`
`Dyson Ex1017
`Page 23
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`4. The hand carriable surface cleaning
`apparatus of claim 1, wherein the
`second cyclonic cleaning stage is
`moveable relative to the sidewall while
`the bottom door is open.
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/silver-nickel (annotated)
`
`
`Each of the Dyson Accused Products includes a second cyclonic cleaning stage that is
`moveable relative to the sidewall while the bottom door is open.
`
`For example, the below images show a second cyclonic cleaning stage that is moveable
`relative to the sidewall while the bottom door is open.
`
`
`
`
`
`24
`
`Dyson Ex1017
`Page 24
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`
`
`
`
`25
`
`Dyson Ex1017
`Page 25
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`https://www.dyson.com/content/dam/dyson/maintenance/user-
`guides/en_anz/vacuums/dyson-v8-285l-user-manual-2022-ANZ-V2.pdf
`
`
`
`
`
`
`26
`
`Dyson Ex1017
`Page 26
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`5. The hand carriable surface cleaning
`Each of the Dyson Accused Products includes a pre-motor filter chamber positioned in the
`apparatus of claim 1, further
`fluid flow path between the second cyclonic cleaning stage and the suction motor,
`comprising a pre-motor filter chamber
`wherein each second cyclone has a respective air outlet that is in fluid communication
`positioned in the fluid flow path
`with the pre-motor filter chamber.
`
`between the second cyclonic cleaning
`For example, the below images show a pre-motor filter chamber positioned in the fluid
`stage and the suction motor, and
`flow path between the second cyclonic cleaning stage and the suction motor, wherein
`wherein each second cyclone has a
`each second cyclone has a respective air outlet that is in fluid communication with the
`respective air outlet that is in fluid
`pre-motor filter chamber.
`communication with the pre-motor
`
`filter chamber.
`
`
`
`27
`
`
`
`Dyson Ex1017
`Page 27
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`Photograph of Dyson V8™ vacuum (annotated)
`
`
`6. The hand carriable surface cleaning
`apparatus of claim 1, wherein each
`second cyclone comprises a respective
`cyclone axis about which air circulates
`within the second cyclone, wherein the
`cyclone axes are generally longitudinal.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`
`Each of the Dyson Accused Products includes a plurality of second cyclones, wherein
`each second cyclone comprises a respective cyclone axis about which air circulates within
`the second cyclone, wherein the cyclone axes are generally longitudinal.
`
`For example, the below images show a plurality of second cyclones, wherein each second
`cyclone comprises a respective cyclone axis about which air circulates within the second
`cyclone, wherein the cyclone axes are generally longitudinal.
`
`
`
`28
`
`Dyson Ex1017
`Page 28
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`7. The hand carriable surface cleaning
`apparatus of claim 1, wherein the dirty
`air inlet comprises a conduit extending
`forwardly from the first cyclonic
`cleaning stage, and wherein the second
`cyclonic cleaning stage is
`longitudinally moveable relative to the
`conduit.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`
`Each of the Dyson Accused Products includes a dirty air inlet that comprises a conduit
`extending forwardly from the first cyclonic cleaning stage, wherein the second cyclonic
`cleaning stage is longitudinally moveable relative to the conduit.
`
`For example, the below images show a dirty air inlet that comprises a conduit extending
`forwardly from the first cyclonic cleaning stage, wherein the second cyclonic cleaning
`stage is longitudinally moveable relative to the conduit.
`
`
`
`
`29
`
`Dyson Ex1017
`Page 29
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`8. The hand carriable surface cleaning
`apparatus of claim 7, wherein the dirty
`air inlet is located at a front end of the
`hand carriable surface cleaning
`apparatus and the upper end of the
`second cyclonic cleaning stage is
`located above the dirty air inlet.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`
`Each of the Dyson Accused Products includes a dirty air inlet that is located at a front end
`of the hand carriable surface cleaning apparatus and wherein the upper end of the second
`cyclonic cleaning stage is located above the dirty air inlet.
`
`For example, the below images show a dirty air inlet that is located at a front end of the
`hand carriable surface cleaning apparatus and wherein the upper end of the second
`cyclonic cleaning stage is located above the dirty air inlet.
`
`
`
`
`30
`
`Dyson Ex1017
`Page 30
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`9. The hand carriable surface cleaning
`apparatus of claim 7, wherein the
`conduit defines an axis that intersects
`the first cyclonic cleaning stage.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/silver-nickel (annotated)
`
`Each of the Dyson Accused Products includes a conduit that defines an axis that intersects
`the first cyclonic cleaning stage.
`
`For example, the below images show a conduit that defines an axis that intersects the first
`cyclonic cleaning stage.
`
`
`
`31
`
`Dyson Ex1017
`Page 31
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`10. The hand carriable surface cleaning
`apparatus of claim 1, further
`comprising an openable lid that is
`moveable between a closed position, in
`which the lid overlies the second
`cyclonic cleaning stage, and an open
`position in which the second cyclonic
`cleaning stage is accessible.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/silver-nickel (annotated)
`
`Each of the Dyson Accused Products includes an openable lid that is moveable between a
`closed position, in which the lid overlies the second cyclonic cleaning stage, and an open
`position in which the second cyclonic cleaning stage is accessible.
`
`For example, the below images show an openable lid that is moveable between a closed
`position, in which the lid overlies the second cyclonic cleaning stage, and an open
`position in which the second cyclonic cleaning stage is accessible.
`
`
`
`32
`
`Dyson Ex1017
`Page 32
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`Photograph of Dyson V8™ vacuum (annotated)
`
`
`
`
`
`
`33
`
`Dyson Ex1017
`Page 33
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`Photograph of Dyson V8™ vacuum (annotated)
`
`
`
`
`
`
`34
`
`Dyson Ex1017
`Page 34
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`11. The hand carriable surface cleaning
`apparatus of claim 1, wherein the
`second cyclonic cleaning stage is
`removable from the first cyclonic
`cleaning stage.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`Each of the Dyson Accused Products includes a second cyclonic cleaning stage that is
`removable from the first cyclonic cleaning stage.
`
`For example, the below images show a second cyclonic cleaning stage that is removable
`from the first cyclonic cleaning stage.
`
`
`
`35
`
`Dyson Ex1017
`Page 35
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`12. A hand carriable surface cleaning
`apparatus comprising:
`
`https://www.dyson.com/content/dam/dyson/maintenance/user-
`guides/en_anz/vacuums/dyson-v8-285l-user-manual-2022-ANZ-V2.pdf (annotated)
`
`To the extent the preamble is limiting, each of the Dyson Accused Products2 is a hand
`carriable surface cleaning apparatus. See, e.g., https://www.dyson.com/vacuum-
`cleaners/cordless/v8.
`
`
`
`
`2 The Dyson Accused Products include, but are not limited to, the Dyson Cyclone V8™ line.
`
`
`
`36
`
`Dyson Ex1017
`Page 36
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`See Claim 1.
`
`For example, the below images show a hand carriable surface cleaning apparatus.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8
`
`
`
`
`
`
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`37
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`Page 37
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`
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`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`a) a fluid flow path extending between
`a dirty air inlet and a clean air outlet;
`
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`Each of the Dyson Accused Products includes a fluid flow path extending between a dirty
`air inlet and a clean air outlet.
`
`See Claim 1.
`
`For example, the below images show a fluid flow path extending between a dirty air inlet
`and a clean air outlet.
`
`
`
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`38
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`Dyson Ex1017
`Page 38
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`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com.mx/products/cord-free/sticks/dyson-v8/features
`
`
`
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`39
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`Dyson Ex1017
`Page 39
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`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`https://www.dyson.com.mx/products/cord-free/sticks/dyson-v8/features (annotated)
`
`
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`40
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`Dyson Ex1017
`Page 40
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`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8
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`
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`41
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`Dyson Ex1017
`Page 41
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`
`
`b) a first cyclonic cleaning stage
`positioned in the fluid flow path
`downstream from the dirty air inlet, the
`first cyclonic cleaning stage comprising
`an upper end, a bottom end spaced
`longitudinally below the upper end and
`a side wall extending therebetween, the
`first cyclonic cleaning stage having a
`dirt collection region with a bottom
`door that is openable to empty the dirt
`collection region;
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`Each of the Dyson Accused Products includes a first cyclonic cleaning stage positioned in
`the fluid flow path downstream from the dirty air inlet, the first cyclonic cleaning stage
`comprising an upper end, a bottom end spaced longitudinally below the upper end and a
`side wall extending therebetween, the first cyclonic cleaning stage having a dirt collection
`region with a bottom door that is openable to empty the dirt collection region.
`
`See Claim 1.
`
`For example, the below images show a first cyclonic cleaning stage positioned in the fluid
`flow path downstream from the dirty air inlet, the first cyclonic cleaning stage comprising
`an upper end, a bottom end spaced longitudinally below the upper end and a side wall
`extending therebetween, the first cyclonic cleaning stage having a dirt collection region
`with a bottom door that is openable to empty the dirt collection region.
`
`
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`42
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`Dyson Ex1017
`Page 42
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`
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`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`
`
`
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`43
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`Dyson Ex1017
`Page 43
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`
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`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`https://www.dyson.com/vacuum-cleaners/cordless/v8/silver-nickel (annotated)
`
`
`c) a second cyclonic cleaning stage
`positioned in the fluid flow path
`downstream from the first cyclonic
`cleaning stage, the second cyclonic
`cleaning stage having an upper end
`which is positioned above the upper
`end of the first cyclonic cleaning stage,
`the second cyclonic cleaning stage is
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`
`Each of the Dyson Accused Products includes a second cyclonic cleaning stage positioned
`in the fluid flow path downstream from the first cyclonic cleaning stage, the second
`cyclonic cleaning stage having an upper end which is positioned above the upper end of
`the first cyclonic cleaning stage, the second cyclonic cleaning stage is longitudinally
`moveable relative to all of the sidewall of the first cyclonic cleaning stage.
`
`See Claim 1.
`
`
`
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`44
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`Dyson Ex1017
`Page 44
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`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`longitudinally moveable relative to all
`For example, the below images show a second cyclonic cleaning stage positioned in the
`of the sidewall of the first cyclonic
`fluid flow path downstream from the first cyclonic cleaning stage and the second cyclonic
`cleaning stage;
`cleaning stage having an upper end which is positioned above the upper end of the first
`cyclonic cleaning stage.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`
`
`
`
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`45
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`Dyson Ex1017
`Page 45
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`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/silver-nickel (annotated)
`
`For example, the below image shows a second cyclonic cleaning stage that is
`longitudinally moveable relative to all of the sidewall of the first cyclonic cleaning stage.
`
`
`
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`46
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`Dyson Ex1017
`Page 46
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`
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`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`d) a suction motor positioned in the
`fluid flow path downstream from the
`second cyclonic cleaning stage; and,
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`Each of the Dyson Accused Products includes a suction motor positioned in the fluid flow
`path downstream from the second cyclonic cleaning stage.
`
`See Claim 1.
`
`For example, the below images show a suction motor positioned in the fluid flow path
`downstream from the second cyclonic cleaning stage.
`
`
`
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`47
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`Dyson Ex1017
`Page 47
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`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com.mx/products/cord-free/sticks/dyson-v8/features
`
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`
`
`
`
`48
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`Dyson Ex1017
`Page 48
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`
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`e) a handle;
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`Each of the Dyson Accused Products includes a handle.
`
`See Claim 1.
`
`For example, the below images show a handle.
`
`
`wherein the first cyclonic cleaning
`stage has a first stage air inlet, each
`cyclone of the second cyclonic
`cleaning stage has a second stage air
`inlet downstream from the first stage
`air inlet and the hand carriable surface
`cleaning apparatus further comprises a
`
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`Each of the Dyson Accused Products includes a first cyclonic cleaning stage that has a
`first stage air inlet, wherein each cyclone of the second cyclonic cleaning stage has a
`second stage air inlet downstream from the first stage air inlet and the hand carriable
`surface cleaning apparatus further comprises a screen positioned in the fluid flow path
`between the first stage air inlet and the second stage air inlet, wherein the screen is
`longitudinally moveable relative to the sidewall.
`
`
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`49
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`Dyson Ex1017
`Page 49
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`
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`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`screen positioned in the fluid flow path
`For example, the below images show a first cyclonic cleaning stage that has a first stage
`between the first stage air inlet and the
`air inlet, wherein each cyclone of the second cyclonic cleaning stage has a second stage
`second stage air inlet, wherein the
`air inlet downstream from the first stage air inlet and the hand carriable surface cleaning
`screen is longitudinally moveable
`apparatus further comprises a screen positioned in the fluid flow path between the first
`relative to the sidewall.
`stage air inlet and the second stage air inlet, wherein the screen is longitudinally moveable
`relative to the sidewall.
`
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/silver-nickel (annotated)
`
`
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`50
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`Dyson Ex1017
`Page 50
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`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com.mx/products/cord-free/sticks/dyson-v8/features (annotated)
`
`
`
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`51
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`Dyson Ex1017
`Page 51
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`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/silver-nickel (annotated)
`
`
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`52
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`Dyson Ex1017
`Page 52
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`
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`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`13. A hand carriable surface cleaning
`apparatus comprising:
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver (annotated)
`
`To the extent the preamble is limiting, each of the Dyson Accused Products3 is a hand
`carriable surface cleaning apparatus. See, e.g., https://www.dyson.com/vacuum-
`cleaners/cordless/v8.
`
`See Claim 1.
`
`
`
`3 The Dyson Accused Products include, but are not limited to, the Dyson Cyclone V8™ line.
`
`
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`53
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`Dyson Ex1017
`Page 53
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`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`For example, the below images show a hand carriable surface cleaning apparatus.
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8
`
`
`
`
`
`
`
`
`54
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`Dyson Ex1017
`Page 54
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`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`a) a fluid flow path extending between
`a dirty air inlet and a clean air outlet;
`
`
`
`https://www.dyson.com/vacuum-cleaners/cordless/v8/absolute-hepa-silver
`
`Each of the Dyson Accused Products includes a fluid flow path extending between a dirty
`air inlet and a clean air outlet.
`
`See Claim 1.
`
`For example, the below images show a fluid flow path extending between a dirty air inlet
`and a clean air outlet.
`
`
`
`
`55
`
`Dyson Ex1017
`Page 55
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No. 10,327,607
`
`
`https://www.dyson.com.mx/products/cord-free/sticks/dyson-v8/features
`
`
`
`
`56
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`Dyson Ex1017
`Page 56
`
`
`
`Exhibit H-2
`Claim Chart Comparing the Dyson V8 line to U.S. Patent No.