Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 1 of 30 PageID #: 189
`
`EXHIBIT A
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`29 The Samsung Galaxy S6 includes a hous-
`ing.
`
`30 The Samsung Galaxy S6 includes a 3-
`axis accelerometer.
`
`31 The Samsung Galaxy S6 includes a 3-
`axis gyroscope.
`
`33 The Samsung Galaxy S6 includes a 3-
`axis accelerometer attached to a PCB.
`
`34 The Samsung Galaxy S6 includes a 3-
`axis gyroscope attached to a PCB.
`
`35 The Samsung Galaxy S6 includes a 3-
`axis accelerometer that is capable of
`measuring accelerations.
`
`36 The Samsung Galaxy S6 includes a 3-
`axis gyroscope that is capable of measur-
`ing rotation rates.
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 29 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`29.
`To the extent that the allegation of Par-
`agraph 30 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`30.
`To the extent that the allegation of Par-
`agraph 31 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`31.
`To the extent that the allegation of Par-
`agraph 33 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`33.
`To the extent that the allegation of Par-
`agraph 34 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`34.
`To the extent that the allegation of Par-
`agraph 35 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`35.
`To the extent that the allegation of Par-
`agraph 36 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`36.
`
`
`EXHIBIT A
`
`
`
`PAGE 1
`
`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 2 of 30 PageID #: 190
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`37 The Samsung Galaxy S6 includes a 3-
`axis accelerometer that is capable of
`measuring accelerations using a “Sensor
`Coordinate System” as described in the
`Android
`developer
`library.
`See
`https://developer.android.com/guide/to
`pics/sensors/sensor_overview.html#sens
`ors- cords (describing “Sensor Coordinate
`System”).
`38 The Samsung Galaxy S6 includes a 3-
`axis gyroscope that is capable of measur-
`ing rotation rates using a “Sensor Coor-
`dinate System.”
`
`39 The Samsung Galaxy S6 includes a pro-
`cessor that is capable of processing data
`associated with measurement from a 3-
`axis accelerometer.
`
`40 The Samsung Galaxy S6 includes a pro-
`cessor that is capable of processing data
`associated with measurement from a 3-
`axis gyroscope.
`
`42 The Android operating system that runs
`on the Samsung Galaxy S6 uses the
`measurement from the 3-axis accelerome-
`ter included in the device.
`
`43 The Android operating system that runs
`on the Samsung Galaxy S6 uses the
`measurement from a 3-axis gyroscope
`included in the device.
`
`44 The Android operating system that runs
`on the Samsung Galaxy S6 uses the
`measurement from a 3-axis accelerometer
`and the measurement from a 3-axis gyro-
`scope to calculate an attitude of the de-
`vice.
`46 The Samsung Galaxy S6 Edge includes a
`housing.
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 37 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`37.
`
`To the extent that the allegation of Par-
`agraph 38 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`38.
`To the extent that the allegation of Par-
`agraph 39 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`39.
`To the extent that the allegation of Par-
`agraph 40 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`40.
`To the extent that the allegation of Par-
`agraph 42 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`42.
`To the extent that the allegation of Par-
`agraph 43 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`43.
`To the extent that the allegation of Par-
`agraph 44 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`44.
`
`To the extent that the allegation of Par-
`agraph 46 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`46.
`
`
`EXHIBIT A
`
`
`
`PAGE 2
`
`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 3 of 30 PageID #: 191
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`47 The Samsung Galaxy S6 Edge includes a
`3-axis accelerometer.
`
`48 The Samsung Galaxy S6 Edge includes a
`3-axis gyroscope.
`
`50 The Samsung Galaxy S6 Edge includes a
`3-axis accelerometer attached to a PCB.
`
`51 The Samsung Galaxy S6 Edge includes a
`3-axis gyroscope attached to a PCB.
`
`52 The Samsung Galaxy S6 Edge includes a
`3-axis accelerometer that is capable of
`measuring accelerations.
`
`53 The Samsung Galaxy S6 Edge includes a
`3-axis gyroscope that is capable of meas-
`uring rotation rates.
`
`54 The Samsung Galaxy S6 Edge includes a
`3-axis accelerometer that is capable of
`measuring accelerations using a “Sensor
`Coordinate System” as described in the
`Android developer library. See https://
`developer.android.com/guide/topics/
`sensors/sensor_overview.html#sensors-
`cords (describing “Sensor Coordinate
`System”).
`55 The Samsung Galaxy S6 Edge includes a
`3-axis gyroscope that is capable of meas-
`uring rotation rates using a “Sensor Co-
`ordinate System.”
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 47 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`47.
`To the extent that the allegation of Par-
`agraph 48 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`48.
`To the extent that the allegation of Par-
`agraph 50 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`50.
`To the extent that the allegation of Par-
`agraph 51 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`51.
`To the extent that the allegation of Par-
`agraph 52 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`52.
`To the extent that the allegation of Par-
`agraph 53 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`53.
`To the extent that the allegation of Par-
`agraph 54 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`54.
`
`To the extent that the allegation of Par-
`agraph 55 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`55.
`
`
`EXHIBIT A
`
`
`
`PAGE 3
`
`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 4 of 30 PageID #: 192
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`56 The Samsung Galaxy S6 Edge includes a
`processor that is capable of processing
`data associated with measurement from a
`3-axis accelerometer.
`
`57 The Samsung Galaxy S6 Edge includes a
`processor that is capable of processing
`data associated with measurement from a
`3-axis gyroscope.
`
`59 The Android operating system that runs
`on the Samsung Galaxy S6 Edge uses the
`measurement from the 3-axis accelerome-
`ter included in the device.
`
`60 The Android operating system that runs
`on the Samsung Galaxy S6 Edge uses the
`measurement from a 3-axis gyroscope
`included in the device.
`
`61 The Android operating system that runs
`on the Samsung Galaxy S6 Edge uses the
`measurement from a 3-axis accelerometer
`and the measurement from a 3-axis gyro-
`scope to calculate an attitude of the de-
`vice.
`63 The Samsung Galaxy S6 Edge+ includes
`a housing.
`
`64 The Samsung Galaxy S6 Edge+ includes
`a 3-axis accelerometer.
`
`65 The Samsung Galaxy S6 Edge+ includes
`a 3-axis gyroscope.
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 56 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`56.
`To the extent that the allegation of Par-
`agraph 57 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`57.
`To the extent that the allegation of Par-
`agraph 59 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`59.
`To the extent that the allegation of Par-
`agraph 60 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`60.
`To the extent that the allegation of Par-
`agraph 61 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`61.
`
`To the extent that the allegation of Par-
`agraph 63 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`63.
`To the extent that the allegation of Par-
`agraph 64 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`64.
`To the extent that the allegation of Par-
`agraph 65 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`65.
`
`
`EXHIBIT A
`
`
`
`PAGE 4
`
`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 5 of 30 PageID #: 193
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`67 The Samsung Galaxy S6 Edge+ includes
`a 3-axis accelerometer attached to a PCB.
`
`68 The Samsung Galaxy S6 Edge+ includes
`a 3-axis gyroscope attached to a PCB.
`
`69 The Samsung Galaxy S6 Edge+ includes
`a 3-axis accelerometer that is capable of
`measuring accelerations.
`
`70 The Samsung Galaxy S6 Edge+ includes
`a 3-axis gyroscope that is capable of
`measuring rotation rates.
`
`71 The Samsung Galaxy S6 Edge+ includes
`a 3-axis accelerometer that is capable of
`measuring accelerations using a “Sensor
`Coordinate System” as described in the
`Android developer library. See https://
`developer.android.com/guide/topics/
`sensors/sensor_overview.html#sensors-
`cords (describing “Sensor Coordinate
`System”).
`72 The Samsung Galaxy S6 Edge+ includes
`a 3-axis gyroscope that is capable of
`measuring rotation rates using a “Sensor
`Coordinate System.”
`
`73 The Samsung Galaxy S6 Edge+ includes
`a processor that is capable of processing
`data associated with measurement from a
`3-axis accelerometer.
`
`74 The Samsung Galaxy S6 Edge+ includes
`a processor that is capable of processing
`data associated with measurement from a
`3-axis gyroscope.
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 67 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`67.
`To the extent that the allegation of Par-
`agraph 68 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`68.
`To the extent that the allegation of Par-
`agraph 69 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`69.
`To the extent that the allegation of Par-
`agraph 70 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`70.
`To the extent that the allegation of Par-
`agraph 71 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`71.
`
`To the extent that the allegation of Par-
`agraph 72 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`72.
`To the extent that the allegation of Par-
`agraph 73 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`73.
`To the extent that the allegation of Par-
`agraph 74 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`74.
`
`
`EXHIBIT A
`
`
`
`PAGE 5
`
`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 6 of 30 PageID #: 194
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`76 The Android operating system that runs
`on the Samsung Galaxy S6 Edge+ uses
`the measurement from the 3-axis accel-
`erometer included in the device.
`
`77 The Android operating system that runs
`on the Samsung Galaxy S6 Edge+ uses
`the measurement from a 3-axis gyroscope
`included in the device.
`
`78 The Android operating system that runs
`on the Samsung Galaxy S6 Edge+ uses
`the measurement from a 3-axis accel-
`erometer and the measurement from a 3-
`axis gyroscope to calculate an attitude of
`the device.
`80 The Samsung Galaxy S6 Active includes
`a housing.
`
`81 The Samsung Galaxy S6 Active includes
`a 3-axis accelerometer.
`
`82 The Samsung Galaxy S6 Active includes
`a 3-axis gyroscope.
`
`84 The Samsung Galaxy S6 Active includes
`a 3-axis accelerometer attached to a PCB.
`
`85 The Samsung Galaxy S6 Active includes
`a 3-axis gyroscope attached to a PCB.
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 76 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`76.
`To the extent that the allegation of Par-
`agraph 77 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`77.
`To the extent that the allegation of Par-
`agraph 78 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`78.
`
`To the extent that the allegation of Par-
`agraph 80 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`80.
`To the extent that the allegation of Par-
`agraph 81 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`81.
`To the extent that the allegation of Par-
`agraph 82 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`82.
`To the extent that the allegation of Par-
`agraph 84 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`84.
`To the extent that the allegation of Par-
`agraph 85 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`85.
`
`
`EXHIBIT A
`
`
`
`PAGE 6
`
`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 7 of 30 PageID #: 195
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`86 The Samsung Galaxy S6 Active includes
`a 3-axis accelerometer that is capable of
`measuring accelerations.
`
`87 The Samsung Galaxy S6 Active includes
`a 3-axis gyroscope that is capable of
`measuring rotation rates.
`
`88 The Samsung Galaxy S6 Active includes
`a 3-axis accelerometer that is capable of
`measuring accelerations using a “Sensor
`Coordinate System” as described in the
`Android developer library. See https://
`developer.android.com/guide/topics/
`sensors/sensor_overview.html#sensors-
`cords (describing “Sensor Coordinate
`System”).
`89 The Samsung Galaxy S6 Active includes
`a 3-axis gyroscope that is capable of
`measuring rotation rates using a “Sensor
`Coordinate System.”
`
`90 The Samsung Galaxy Active S6 includes
`a processor that is capable of processing
`data associated with measurement from a
`3-axis accelerometer.
`
`91 The Samsung Galaxy Active S6 includes
`a processor that is capable of processing
`data associated with measurement from a
`3-axis gyroscope.
`
`93 The Android operating system that runs
`on the Samsung Galaxy S6 Active uses
`the measurement from the 3-axis accel-
`erometer included in the device.
`
`94 The Android operating system that runs
`on the Samsung Galaxy S6 Active uses
`the measurement from a 3-axis gyroscope
`included in the device.
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 86 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`86.
`To the extent that the allegation of Par-
`agraph 87 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`87.
`To the extent that the allegation of Par-
`agraph 88 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`88.
`
`To the extent that the allegation of Par-
`agraph 89 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`89.
`To the extent that the allegation of Par-
`agraph 90 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`90.
`To the extent that the allegation of Par-
`agraph 91 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`91.
`To the extent that the allegation of Par-
`agraph 93 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`93.
`To the extent that the allegation of Par-
`agraph 94 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`94.
`
`
`EXHIBIT A
`
`
`
`PAGE 7
`
`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 8 of 30 PageID #: 196
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`95 The Android operating system that runs
`on the Samsung Galaxy Active S6 uses
`the measurement from a 3-axis accel-
`erometer and the measurement from a 3-
`axis gyroscope to calculate an attitude of
`the device.
`97 The Samsung Galaxy S7 includes a hous-
`ing.
`
`98 The Samsung Galaxy S7 includes a 3-
`axis accelerometer.
`
`99 The Samsung Galaxy S7 includes a 3-
`axis gyroscope.
`
`101 The Samsung Galaxy S7 includes a 3-
`axis accelerometer attached to a PCB.
`
`102 The Samsung Galaxy S7 includes a 3-
`axis gyroscope attached to a PCB.
`
`103 The Samsung Galaxy S7 includes a 3-
`axis accelerometer that is capable of
`measuring accelerations.
`
`104 The Samsung Galaxy S7 includes a 3-
`axis gyroscope that is capable of measur-
`ing rotation rates.
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 95 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`95.
`
`To the extent that the allegation of Par-
`agraph 97 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`97.
`To the extent that the allegation of Par-
`agraph 98 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`98.
`To the extent that the allegation of Par-
`agraph 99 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`99.
`To the extent that the allegation of Par-
`agraph 101 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`101.
`To the extent that the allegation of Par-
`agraph 102 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`102.
`To the extent that the allegation of Par-
`agraph 103 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`103.
`To the extent that the allegation of Par-
`agraph 104 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`104.
`
`
`EXHIBIT A
`
`
`
`PAGE 8
`
`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 9 of 30 PageID #: 197
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`105 The Samsung Galaxy S7 includes a 3-
`axis accelerometer that is capable of
`measuring accelerations using a “Sensor
`Coordinate System” as described in the
`Android
`developer
`library.
`See
`https://developer. android.com/guide/
`topics/sensors/sensor_overview.html
`#sensors-cords (describing “Sensor Co-
`ordinate System”).
`106 The Samsung Galaxy S7 includes a 3-
`axis gyroscope that is capable of measur-
`ing rotation rates using a “Sensor Coor-
`dinate System.”
`
`107 The Samsung Galaxy S7 includes a pro-
`cessor that is capable of processing data
`associated with measurement from a 3-
`axis accelerometer.
`
`108 The Samsung Galaxy S7 includes a pro-
`cessor that is capable of processing data
`associated with measurement from a 3-
`axis gyroscope.
`
`110 The Android operating system that runs
`on the Samsung Galaxy S7 uses the
`measurement from the 3-axis accelerome-
`ter included in the device.
`
`111 The Android operating system that runs
`on the Samsung Galaxy S7 uses the
`measurement from a 3-axis gyroscope
`included in the device.
`
`112 The Android operating system that runs
`on the Samsung Galaxy S7 uses the
`measurement from a 3-axis accelerometer
`and the measurement from a 3-axis gyro-
`scope to calculate an attitude of the de-
`vice.
`114 The Samsung Galaxy S7 Edge includes a
`housing.
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 105 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`105.
`
`To the extent that the allegation of Par-
`agraph 106 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`106.
`To the extent that the allegation of Par-
`agraph 107 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`107.
`To the extent that the allegation of Par-
`agraph 108 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`108.
`To the extent that the allegation of Par-
`agraph 110 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`110.
`To the extent that the allegation of Par-
`agraph 111 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`111.
`To the extent that the allegation of Par-
`agraph 112 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`112.
`
`To the extent that the allegation of Par-
`agraph 114 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`114.
`
`
`EXHIBIT A
`
`
`
`PAGE 9
`
`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 10 of 30 PageID #: 198
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`115 The Samsung Galaxy S7 Edge includes a
`3-axis accelerometer.
`
`116 The Samsung Galaxy S7 Edge includes a
`3-axis gyroscope.
`
`118 The Samsung Galaxy S7 Edge includes a
`3-axis accelerometer attached to a PCB.
`
`119 The Samsung Galaxy S7 Edge includes a
`3-axis gyroscope attached to a PCB.
`
`120 The Samsung Galaxy S7 Edge includes a
`3-axis accelerometer that is capable of
`measuring accelerations.
`
`121 The Samsung Galaxy S7 Edge includes a
`3-axis gyroscope that is capable of meas-
`uring rotation rates.
`
`122 The Samsung Galaxy S7 Edge includes a
`3-axis accelerometer that is capable of
`measuring accelerations using a “Sensor
`Coordinate System” as described in the
`Android developer library. See https://
`developer.android.com/guide/topics/
`sensors/sensor_overview.html#sensors-
`cords (describing “Sensor Coordinate
`System”).
`123 The Samsung Galaxy S7 Edge includes a
`3-axis gyroscope that is capable of meas-
`uring rotation rates using a “Sensor Co-
`ordinate System.”
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 115 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`115.
`To the extent that the allegation of Par-
`agraph 116 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`116.
`To the extent that the allegation of Par-
`agraph 118 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`118.
`To the extent that the allegation of Par-
`agraph 119 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`119.
`To the extent that the allegation of Par-
`agraph 120 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`120.
`To the extent that the allegation of Par-
`agraph 121 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`121.
`To the extent that the allegation of Par-
`agraph 122 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`122.
`
`To the extent that the allegation of Par-
`agraph 123 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`123.
`
`
`EXHIBIT A
`
`
`
`PAGE 10
`
`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 11 of 30 PageID #: 199
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`124 The Samsung Galaxy S7 Edge includes a
`processor that is capable of processing
`data associated with measurement from a
`3-axis accelerometer.
`
`125 The Samsung Galaxy S7 Edge includes a
`processor that is capable of processing
`data associated with measurement from a
`3-axis gyroscope.
`
`127 The Android operating system that runs
`on the Samsung Galaxy S7 Edge uses the
`measurement from the 3-axis accelerome-
`ter included in the device.
`
`128 The Android operating system that runs
`on the Samsung Galaxy S7 Edge uses the
`measurement from a 3-axis gyroscope
`included in the device.
`
`129 The Android operating system that runs
`on the Samsung Galaxy S7 Edge uses the
`measurement from a 3-axis accelerometer
`and the measurement from a 3-axis gyro-
`scope to calculate an attitude of the de-
`vice.
`131 The Samsung Galaxy S7 Active includes
`a housing.
`
`132 The Samsung Galaxy S7 Active includes
`a 3-axis accelerometer.
`
`133 The Samsung Galaxy S7 Active includes
`a 3-axis gyroscope.
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 124 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`124.
`To the extent that the allegation of Par-
`agraph 125 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`125.
`To the extent that the allegation of Par-
`agraph 127 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`127.
`To the extent that the allegation of Par-
`agraph 128 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`128.
`To the extent that the allegation of Par-
`agraph 129 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`129.
`
`To the extent that the allegation of Par-
`agraph 131 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`131.
`To the extent that the allegation of Par-
`agraph 115 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`115.
`To the extent that the allegation of Par-
`agraph 133 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`133.
`
`
`EXHIBIT A
`
`
`
`PAGE 11
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`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 12 of 30 PageID #: 200
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`135 The Samsung Galaxy S7 Active includes
`a 3-axis accelerometer attached to a PCB.
`
`136 The Samsung Galaxy S7 Active includes
`a 3-axis gyroscope attached to a PCB.
`
`137 The Samsung Galaxy S7 Active includes
`a 3-axis accelerometer that is capable of
`measuring accelerations.
`
`138 The Samsung Galaxy S7 Active includes
`a 3-axis gyroscope that is capable of
`measuring rotation rates.
`
`139 The Samsung Galaxy S7 Active includes
`a 3-axis accelerometer that is capable of
`measuring accelerations using a “Sensor
`Coordinate System” as described in the
`Android developer library. See https://
`developer.android.com/guide/topics/
`sensors/sensor_overview.html#sensors-
`cords (describing “Sensor Coordinate
`System”).
`140 The Samsung Galaxy S7 Active includes
`a 3-axis gyroscope that is capable of
`measuring rotation rates using a “Sensor
`Coordinate System.”
`
`141 The Samsung Galaxy S7 Active includes
`a processor that is capable of processing
`data associated with measurement from a
`3-axis accelerometer.
`
`142 The Samsung Galaxy S7 Active includes
`a processor that is capable of processing
`data associated with measurement from a
`3-axis gyroscope.
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 135 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`135.
`To the extent that the allegation of Par-
`agraph 136 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`136.
`To the extent that the allegation of Par-
`agraph 137 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`137.
`To the extent that the allegation of Par-
`agraph 138 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`138.
`To the extent that the allegation of Par-
`agraph 139 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`139.
`
`To the extent that the allegation of Par-
`agraph 140 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`140.
`To the extent that the allegation of Par-
`agraph 141 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`141.
`To the extent that the allegation of Par-
`agraph 142 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`142.
`
`
`EXHIBIT A
`
`
`
`PAGE 12
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`

`

`Case 2:17-cv-00140-RWS-RSP Document 24-1 Filed 06/23/17 Page 13 of 30 PageID #: 201
`
`CyWee’s Allegations (Dkt. 9)
`¶ #
`144 The Android operating system that runs
`on the Samsung Galaxy S7 Active uses
`the measurement from the 3-axis accel-
`erometer included in the device.
`
`145 The Android operating system that runs
`on the Samsung Galaxy S7 Active uses
`the measurement from a 3-axis gyroscope
`included in the device.
`
`146 The Android operating system that runs
`on the Samsung Galaxy S7 Active uses
`the measurement from a 3-axis accel-
`erometer and the measurement from a 3-
`axis gyroscope to calculate an attitude of
`the device.
`148 The Samsung Galaxy Note5 includes a
`housing.
`
`149 The Samsung Galaxy Note5 includes a 3-
`axis accelerometer.
`
`150 The Samsung Galaxy Note5 includes a 3-
`axis gyroscope.
`
`152 The Samsung Galaxy Note5 includes a 3-
`axis accelerometer attached to a PCB.
`
`153 The Samsung Galaxy Note5 includes a 3-
`axis gyroscope attached to a PCB.
`
`Samsung’s Responses (Dkt. 15)
`To the extent that the allegation of Par-
`agraph 144 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`144.
`To the extent that the allegation of Par-
`agraph 145 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`145.
`To the extent that the allegation of Par-
`agraph 146 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`146.
`
`To the extent that the allegation of Par-
`agraph 148 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`148.
`To the extent that the allegation of Par-
`agraph 149 sets forth a legal conclusion,
`no response is required. Samsung denies
`all remaining allegations of Paragraph
`149.
`To the extent that the allegation of Par-
`a