EXHIBIT (cid:21)(cid:23)
`
`Google Exhibit 1033
`Google v. Ericsson
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`

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`Exhibit 24: Claim Chart Showing Infringement for U.S. Patent No. 9,313,178
`
`The Lenovo Mobile Phone Products (“Lenovo Mobile Phones”) are listed in Exhibit 12, including exemplary product Motorola Edge (2022),
`and infringe at least one claim of the ’178 Patent. No part of this exemplary chart construes, or is intended to construe, the specification, file
`history, or claims of the ’178 Patent. Moreover, this exemplary chart does not limit, and is not intended to limit, Ericsson’s infringement or
`domestic industry positions or contentions.
`
`Claims
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`1. A method for handling secure
`distribution of content comprising:
`
`Motorola Edge (2022) (“Accused Device”)
`
`When a user operates a Motorola Edge (2022), which implements the Google Widevine DRM system, the
`user is causing the device to implement “a method for handling secure distribution of content.” The
`Motorola Edge (2022) includes a Widevine Content Decryption Module (CDM), with a Security level L1,
`which is used to decrypt content for playback. A Widevine CDM with Security level L1 is incorporated into
`the Motorola Edge (2022) by the manufacturer. The “secure distribution of live video content” corresponds
`to live streaming content secured with encryption keys.
`
`The Motorola Edge (2022) is representative of the other Lenovo Mobile Phone Products for purposes of
`practice of the asserted claims because these products all implement the Google Widevine DRM system.
`
`Ex. 76 (https://www.gsmarena.com/motorola_edge_(2022)-11777.php) at 1:
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`

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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`
`
`The DRM Info app was installed to reveal the DRM software already loaded on the Accused Device, as
`follows. Ex. 77 (Screenshots from Motorola Edge (2022)) at 1-3:
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`INFRINGEMENT CLAIM CHART FOR
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`The following screenshot from the pre-installed Google Chrome browser pointing to the internal
`chrome://media-internals URL reveals the DRM software loaded on the Accused Device. Ex. 77 at 4:
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`INFRINGEMENT CLAIM CHART FOR
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`Ex. 79 (WIDEVINE Getting Started Widevine DRM on Devices Version 1.5 (2018)) at 6, 12:
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`Widevine Client Security Levels
`The following security level definitions are used by Widevine:
`Security Level 1 (L1)
`Widevine DRM keys and decrypted content are never exposed to the host CPU. Only security
`hardware or a protected security co-processor uses clear key values and the media content is
`decrypted by the secure hardware.
`Key requirements of this security level:
`● Device manufacturers must provide a secure bootloader. The chain of trust from the
`bootloader must extend through any software or firmware components involved in the
`security implementation, such as the ARM TrustZone protected application and any
`components involved in the enforcement of the secure video path.
`● The Widevine keybox must be encrypted with a device-unique secret key that is not
`visible to software or probing methods outside of the TrustZone. The Widevine key-box
`must be installed in the factory or delivered to the device using an approved secure
`delivery mechanism.
`● Device manufacturers must provide an implementation of the Widevine Level 1
`OEMCrypto API that performs all key processing and decryption in a trusted
`environment.
`All content processing, cryptography, and control is performed within the Trusted Execution
`Environment (TEE). In some implementation models, security processing may be performed in
`different chips.
`This level of security requires factory provisioning of the Widevine keybox or requires the
`Widevine keybox to be protected by a device key installed at the time of manufacturing.
`The Device Provisioning Models document provides additional information about Widevine
`device provisioning models.
`This is the recommended path for any device integration as it provides the highest level of
`security.
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`Ex. 80 (WIDEVINE Modular DRM Key Rotation Version 1 (2014)) at 2:
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`Introduction
`This document describes changes to the Widevine common encryption API to support key rotation.
`Key rotation allows the key used to encrypt the content to change midstream, typically for use in
`live streaming.
`When a user operates an Accused Device, which implements the Google Widevine DRM system, the user is
`causing the device to perform the steps of “initiating a media playback request and receiving a playback
`request response.” The Motorola Edge (2022) includes a media player, which receives media in response to
`a request to a Content Delivery Network (“CDN”) and, when the media is encrypted, issues a license request
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`initiating a media playback request
`and receiving a playback request
`response.
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`to the license server. The Motorola Edge (2022) media player receives the media from the CDN and a
`license from the license server. The “media playback request” corresponds to a request for media sent to the
`CDN and/or the license request. The “playback request response” corresponds to the media and related
`content received from the CDN and/or receipt of the license from the license server.
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`Ex. 81 (WIDEVINE DRM Architecture Overview Version 1.2 (March 6, 2017)) at 11:
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`INFRINGEMENT CLAIM CHART FOR
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`Ex. 79 at 6:
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`Ex. 80 at 3:
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`Generate License
`The license exchange protocol requires no changes. If the user tunes into the live stream
`described above, the client will issue a license request containing the ‘pssh’ box from the media
`segment at the playback starting point. The license server will then issue a license containing the
`keys for that media segment, as well as the keys for the previous key rotation period, and the
`following key rotation period. Fewer keys may be provided if playing the media near the start
`(previous period key omitted), or near the end (following period key omitted). This allows content
`for the following key rotation period to be decrypted while the license request for it is being
`processed, and for reverse trick-play.
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`parsing content from the playback
`request response, the content
`information including content
`encryption keys, content encryption
`key identifiers, and content encryption
`key expiration times;
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`When a user operates an Accused Device, which implements the Google Widevine DRM system, the user is
`causing the device to perform the step of “parsing content from the playback request response, the content
`information including content encryption keys, content encryption key identifiers, and content encryption
`key expiration times.” The Motorola Edge (2022) media player retrieves information from the CDN and
`from the license received from the license server. The information includes: keys for the media segment,
`keys for the previous key rotation period, and keys for the following rotation period; key_ids, which identify
`the keys; and the crypto periods, which identify the key rotation periods. The “content encryption keys”
`correspond to the keys for the current, previous, and following key rotation periods. The “content encryption
`key identifiers” correspond to the key_ids. The “content encryption key expiration times” correspond to the
`key rotation periods.
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`Ex. 79 at 6:
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`Ex. 80 at 3:
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`Generate License
`The license exchange protocol requires no changes. If the user tunes into the live stream
`described above, the client will issue a license request containing the ‘pssh’ box from the media
`segment at the playback starting point. The license server will then issue a license containing the
`keys for that media segment, as well as the keys for the previous key rotation period, and the
`following key rotation period. Fewer keys may be provided if playing the media near the start
`(previous period key omitted), or near the end (following period key omitted). This allows content
`for the following key rotation period to be decrypted while the license request for it is being
`processed, and for reverse trick-play.
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`retrieving content and manifest files
`from a content delivery server;
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`In addition to the 100 KIDs, 100 'pssh' data blobs are returned. Each 'pssh' data blob contains
`key Id, content Id, and track type. For key rotation, the 'pssh' will also contain the crypto period,
`which for the example above would be as follows:
`'pssh' (1) : crypto_period_index = 383517
`'pssh' (2) : crypto_period_index = 383518
`…
`'pssh' (100) : crypto_period_index = 383616
`Note that even without key_period, the pssh is sufficient to locate a key by key_id. Including
`key_period enables us to also prefetch adjacent keys in the same stream.
`When a user operates an Accused Device, which implements the Google Widevine DRM system, the user is
`causing the device to perform the step of “retrieving content and manifest files from a content delivery
`server.” The Motorola Edge (2022) media player retrieves premium video content, distributed in files, and
`manifest files (MPDs) from a Content Delivery Network. The “content” corresponds to the premium video
`content. The “manifest files” correspond to the manifest (MPD), which describe the different resolutions and
`bandwidth for each media file.
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`Ex. 81 at 5-6, 10-11:
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`Architecture Component Relationships
`The Widevine DRM components work together to create an end-to-end platform for protecting premium
`video content, and provides all the tools you need to go from the content preparation stage to the final
`delivery on any device. The flow process begins by preparing your media with Common Encryption and
`the Shaka Packager for adaptive streaming. Once prepared, the content is encrypted with licenses
`which are stored on the Widevine License Server. Later, when the encrypted content streams to the
`Player via a Content Delivery Network, the License Server provides license information to a supported
`media player. The encrypted content is then passed to the device's Content Decryption Module,
`enabling secure playback with the OEMCrypto Module.
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`Media Packaging
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`detecting content encryption key
`rotation boundaries between periods of
`use of different content encryption
`keys in decryption retrieved content;
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`issuing requests to a license server
`ahead of a key rotation boundary to
`retrieve a second content encryption
`key to be used after a content
`encryption key rotation boundary is
`reached; and
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`Widevine DRM provides a complete open-source DASH packaging system called Shaka
`Packager. The packager converts files of different resolutions and bandwidth to fragmented
`MP4, defining equal-length segments for all desired files. A manifest (MPD) is prepared that
`describes the different resolutions and bandwidth for each file. When a player receives
`encrypted content, it requests the appropriate segment that will provide optimal viewing at that
`moment, but can request different segments as bandwidth conditions change.
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`[…]
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`1. Receive Media from Content Delivery Network (CDN)
`The browser's media engine determines that the media is encrypted. The initialization data
`(InitData) is extracted from the content by the browser and sent to the Player as an event.
`When a user operates an Accused Device, which implements the Google Widevine DRM system, the user is
`causing the device to perform the step of “detecting content encryption key rotation boundaries between
`periods of use of different content encryption keys in decryption retrieved content.” The Motorola Edge
`(2022) media player detects key rotation boundaries between key rotation periods by encountering a new
`‘pssh’ box and issuing a new license request.
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`Ex. 80 at 3:
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`
`Rotation boundary
`The key rotation boundary occurs whenever the client encounters a new ‘pssh’ box, at which
`point it will issue a new license request, but can in the meantime continue to decrypt content, as
`it already has the keys required to decrypt the new key period, whether playing forwards or
`backwards.
`When a user operates an Accused Device, which implements the Google Widevine DRM system, the user is
`causing the device to perform the step of “issuing requests to a license server ahead of a key rotation
`boundary to retrieve a second content encryption key to be used after a content encryption key rotation
`boundary is reached.” The Motorola Edge (2022) media player issues license request ahead of a key rotation
`period to the license server for keys for the current, upcoming, and previous key rotation periods.
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`Ex. 80 at 3:
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`applying the second key for content
`decryption after the key rotation
`boundary is reached.
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`Generate License
`The license exchange protocol requires no changes. If the user tunes into the live stream
`described above, the client will issue a license request containing the ‘pssh’ box from the media
`segment at the playback starting point. The license server will then issue a license containing the
`keys for that media segment, as well as the keys for the previous key rotation period, and the
`following key rotation period. Fewer keys may be provided if playing the media near the start
`(previous period key omitted), or near the end (following period key omitted). This allows content
`for the following key rotation period to be decrypted while the license request for it is being
`processed, and for reverse trickplay.
`When a user operates an Accused Device, which implements the Google Widevine DRM system, the user is
`causing the device to perform the step of “applying the second key for content decryption after the key
`rotation boundary is reached.” The Motorola Edge (2022) media player applies keys from the license to
`continue to decrypt content after a key rotation boundary is reached, as the license from the license server
`included keys to decrypt content from the following key rotation period.
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`Ex. 80 at 3, 4:
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`Rotation boundary
`The key rotation boundary occurs whenever the client encounters a new ‘pssh’ box, at which
`point it will issue a new license request, but can in the meantime continue to decrypt content, as
`it already has the keys required to decrypt the new key period, whether playing forwards or
`backwards.
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`16. A computerized device operable as
`a client for handling secure
`distribution of content, comprising:
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`A Motorola Edge (2022), which implements the Google Widevine DRM system, is a “computerized device
`operable as a client for handling secure distribution of content.” A Motorola Edge (2022) is a client for live
`streaming content secured with encryption keys. The Motorola Edge (2022) includes a Widevine Content
`Decryption Module (CDM), with a Security level L1, which is used to decrypt content for playback. A
`Widevine CDM with Security level L1 is incorporated into the Motorola Edge (2022) by the manufacturer.
`The “computerized device operable as a client” corresponds to the Motorola Edge (2022). The “secure
`distribution of content” corresponds to live streaming content secured with encryption keys.
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`Ex. 76 at 1:
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`The DRM Info app was installed to reveal the DRM software already loaded on the Accused Device, as
`follows. Ex. 77 at 1-3:
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`The following screenshot from the pre-installed Google Chrome browser pointing to the internal
`chrome://media-internals URL also reveals the DRM software loaded on the Accused Device. Ex. 77 at 4:
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`
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`Ex. 79 at 6, 12:
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`Widevine Client Security Levels
`The following security level definitions are used by Widevine:
`Security Level 1 (L1)
`Widevine DRM keys and decrypted content are never exposed to the host CPU. Only security
`hardware or a protected security co-processor uses clear key values and the media content is
`decrypted by the secure hardware.
`Key requirements of this security level:
`● Device manufacturers must provide a secure bootloader. The chain of trust from the
`bootloader must extend through any software or firmware components involved in the
`security implementation, such as the ARM TrustZone protected application and any
`components involved in the enforcement of the secure video path.
`● The Widevine keybox must be encrypted with a device-unique secret key that is not
`visible to software or probing methods outside of the TrustZone. The Widevine key-box
`must be installed in the factory or delivered to the device using an approved secure
`delivery mechanism.
`● Device manufacturers must provide an implementation of the Widevine Level 1
`OEMCrypto API that performs all key processing and decryption in a trusted
`environment.
`All content processing, cryptography, and control is performed within the Trusted Execution
`Environment (TEE). In some implementation models, security processing may be performed in
`different chips.
`This level of security requires factory provisioning of the Widevine keybox or requires the
`Widevine keybox to be protected by a device key installed at the time of manufacturing.
`The Device Provisioning Models document provides additional information about Widevine
`device provisioning models.
`This is the recommended path for any device integration as it provides the highest level of
`security.
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`INFRINGEMENT CLAIM CHART FOR
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`Ex. 80 at 2:
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`Introduction
`This document describes changes to the Widevine common encryption API to support key rotation.
`Key rotation allows the key used to encrypt the content to change midstream, typically for use in
`live streaming.
`The Motorola Edge (2022) includes “memory operative to store computer program instructions;
`one or more processors; input/output interface circuitry; and interconnect circuitry coupling the memory,
`processors, and input/output interface circuitry together, wherein the processors are operative to execute the
`computer program instructions from the memory to cause the computerized device to” perform the functions
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`memory operative to store computer
`program instructions;
`one or more processors;
`input/output interface circuitry; and
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`interconnect circuitry coupling the
`memory, processors, and input/output
`circuitry together;
`wherein the processors are operative to
`execute the computer program
`instructions from the memory to cause
`the computerized device to:
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`described herein. The Motorola Edge (2022) includes 6 or 8 GB of RAM and 128 or 256 GB of internal
`memory storage (depending on model) and an Octa-core MediaTek Dimensity 1050 System-on-a-Chip
`(SoC). The Motorola Edge (2022) includes an Android Operating System and the Widevine CDM, both
`stored on the internal memory.
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`Ex. 76 at 1:
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`Ex. 77 at 1-3:
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`INFRINGEMENT CLAIM CHART FOR
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`initiate a media playback request and
`receive a playback request response;
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`The computer program instructions on the Accused Device will cause the device to “initiate a media
`playback request and receive a playback request response.” The Motorola Edge (2022) includes a media
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`player, which receives media in response to a request to a Content Delivery Network (“CDN”) and, when the
`media is encrypted, issues a license request to the license server. The Motorola Edge (2022) media player
`receives the media from the CDN and a license from the license server. The “media playback request”
`corresponds to a request for media sent to the CDN and/or the license request. The “playback request
`response” corresponds to the media and related content received from the CDN and/or receipt of the license
`from the license server.]
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`Ex. 81 at 11:
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`Ex. 79 at 6:
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`Ex. 80 at 3:
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`Generate License
`The license exchange protocol requires no changes. If the user tunes into the live stream described
`above, the client will issue a license request containing the ‘pssh’ box from the media segment at
`the playback starting point. The license server will then issue a license containing the keys for that
`media segment, as well as the keys for the previous key rotation period, and the following key
`rotation period. Fewer keys may be provided if playing the media near the start (previous period
`key omitted), or near the end (following period key omitted). This allows content for the following
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`parse content information from the
`playback request response, the content
`information including content
`encryption keys, content encryption
`key identifiers, and content encryption
`key expiration times;
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`key rotation period to be decrypted while the license request for it is being processed, and for
`reverse trick-play.
`The computer program instructions on the Accused Device will cause the device to “parse content
`information from the playback request response, the content information including content encryption keys,
`content encryption key identifiers, and content encryption key expiration times.” The Motorola Edge (2022)
`media player retrieves information from the CDN and from the license received from the license server. The
`information includes: keys for the media segment, keys for the previous key rotation period, and keys for the
`following rotation period; key_ids, which identify the keys; and the crypto periods, which identify the key
`rotation periods. The “content encryption keys” correspond to the keys for the current, previous, and
`following key rotation periods. The “content encryption key identifiers” correspond to the key_ids. The
`“content encryption key expiration times” correspond to the key rotation periods.
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`Ex. 79 at 6:
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`Ex. 80 at 3:
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`Generate License
`The license exchange protocol requires no changes. If the user tunes into the live stream
`described above, the client will issue a license request containing the ‘pssh’ box from the media
`segment at the playback starting point. The license server will then issue a license containing
`the keys for that media segment, as well as the keys for the previous key rotation period, and the
`following key rotation period. Fewer keys may be provided if playing the media near the start
`(previous period key omitted), or near the end (following period key omitted). This allows content
`for the following key rotation period to be decrypted while the license request for it is being
`processed, and for reverse trick-play.
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`INFRINGEMENT CLAIM CHART FOR
`LENOVO MOBILE PHONES – U.S. PATENT NO. 9,313,178
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`retrieve content and manifest files
`from a content delivery server;
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`[…]
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`In addition to the 100 KIDs, 100 'pssh' data blobs are returned. Each 'pssh' data blob contains
`key Id, content Id, and track type. For key rotation, the 'pssh' will also contain the crypto period,
`which for the example above would be as follows:
`'pssh' (1) : crypto_period_index = 383517
`'pssh' (2) : crypto_period_index = 383518
`…
`'pssh' (100) : crypto_period_index = 383616
`Note that even without key_period, the pssh is sufficient t