Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 1 of 14 PageID #:
` 1015
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`EXHIBIT L
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` 1015
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`EXHIBIT L
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`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 2 of 14 PageID #:
` 1016
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`CYWEE GROUP LTD,
`vs.
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.
`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`EXEMPLARY CLAIM CHART
`
`U.S. PATENT NO. 8,552,978 – Samsung Galaxy J7 V
`Infringement Contentions
`
`These contentions are disclosed to only provide notice of Plaintiff’s theories of infringement.
`These contentions do not constitute proof nor do they marshal Plaintiff’s evidence of
`infringement to be presented during trial.
`
`1
`
`
`
`Claim 10
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 3 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1017
`
`Claim 10 with claim constructions (text in brackets [] reflects the Court’s claim construction or the parties’ agreed claim construction).
`Construed terms and constructions are underlined.
`
`10. A method for compensating rotations of a 3D pointing device, comprising:
`
`generating an orientation output associated with an orientation of the 3D pointing device associated with three coordinate axes of a
`global reference frame associated with Earth;
`
`generatinq a first signal set comprising axial accelerations associated with movements and rotations of the 3D pointing device in the
`spatial reference frame;
`
`generating a second signal set associated with Earth's magnetism; generating the orientation output based on the first signal set, the
`second signal set and the rotation output or based on the first signal set and the second signal set;
`
`generating a rotation output associated with a rotation of the 3D pointing device associated with three coordinate axes of a spatial
`reference frame associated with the 3D pointing device; and
`
`using the orientation output and the rotation output to generate a transformed output associated with a fixed reference frame
`associated with a display device [Court’s construction: using the orientation output and the rotation output to generate a transformed
`output that corresponds to a two-dimensional movement in a plane that is parallel to the screen of a display device], wherein the
`orientation output and the rotation output is generated by a nine-axis motion sensor module; obtaining one or more resultant deviation
`including a plurality of deviation angles using a plurality of measured magnetisms Mx, My, Mz and a plurality of predicted
`magnetism Mx′, My′ and Mz′ for the second signal set.
`
`2
`
`
`
`Claim 10
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 4 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1018
`
`A method for compensating rotations of a 3D pointing device, comprising:
`
`Samsung Galaxy J7 V
`
`3
`
`
`
`Claim 10
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 5 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1019
`
`generating an orientation output associated with an orientation of the 3D pointing device associated with three coordinate axes of a
`global reference frame associated with Earth;
`
`See support for this element in Exhibit 2
`
`4
`
`
`
`Claim 10
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 6 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1020
`
`generating a first signal set comprising axial accelerations associated with movements and rotations of the 3D pointing device in the
`spatial reference frame;
`
`See support for this element in Exhibit 2
`
`5
`
`
`
`Claim 10
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 7 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1021
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`generating a second signal set associated with Earth's magnetism;
`
`See support for this element in Exhibit 2
`
`6
`
`
`
`Claim 10
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 8 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1022
`
`generating the orientation output based on the first signal set, the second signal set and the rotation output or based on the first signal
`set and the second signal set;
`
`See support for this element in Exhibit 2
`
`7
`
`
`
`Claim 10
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 9 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1023
`
`generating a rotation output associated with a rotation of the 3D pointing device associated with three coordinate axes of a spatial
`reference frame associated with the 3D pointing device; and
`
`See support for this element in Exhibit 2
`
`8
`
`
`
`Claim 10
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 10 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1024
`
`using the orientation output and the rotation output to generate a transformed output associated with a fixed reference frame
`associated with a display device [Court’s construction: using the orientation output and the rotation output to generate a transformed
`output that corresponds to a two-dimensional movement in a plane that is parallel to the screen of a display device],
`
`The fixed reference frame is defined by the horizontal and vertical axes of pixels on Samsung Galaxy J7 V’s display device.
`
`Source: http://developer.android.com/guide/topics/sensors/sensors_overview.html#sensors-coords
`
`9
`
`
`
`Claim 10
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 11 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1025
`
`using the orientation output and the rotation output to generate a transformed output associated with a fixed reference frame
`associated with a display device [Court’s construction: using the orientation output and the rotation output to generate a transformed
`output that corresponds to a two-dimensional movement in a plane that is parallel to the screen of a display device],
`
`See additional support for this element in
`Exhibit 2
`
`10
`
`
`
`Claim 10
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 12 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1026
`
`wherein the orientation output and the rotation output is generated by a nine-axis motion sensor module;
`
`See support for this element in Exhibit 2
`
`11
`
`
`
`Claim 10
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 13 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1027
`
`obtaining one or more resultant deviation including a plurality of deviation angles using a plurality of measured magnetisms Mx, My,
`Mz and a plurality of predicted magnetism Mx′, My′ and Mz′ for the second signal set.
`
`See support for this element in Exhibit 2
`
`12
`
`
`
`Claim 12
`
`Case 2:17-cv-00140-RWS-RSP Document 43-13 Filed 10/25/17 Page 14 of 14 PageID #:
`U.S. Patent No. 8,552,978 – Samsung Galaxy J7 V
` 1028
`
`The method of claim 10, wherein the orientation output is a rotation matrix, a quaternion, a rotation vector, or comprises three
`orientation angles.
`
`See support for this element in Exhibit 2
`
`13
`
`
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