Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 1 of 22 PageID #: 1381
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
`
`
`The ‘425 Patent –
`Claims
`
`45. A wireless device
`for communicating
`information
`comprising:
`
`[a] a transceiver
`configured to receive,
`via a WiFi network, a
`first wireless signal
`corresponding to
`information directed to
`the wireless device, the
`information comprising
`a call,
`
`’425 Patent Accused Mobile Phone Instrumentalities
`
`Each of the HTC U11, U11 Life, U12+, and Exodus 1 (“the ’425 Patent Accused Mobile Phone
`Instrumentalities”) is a wireless device for communicating information.
`
`For example, each of the ’425 Patent Accused Mobile Phone Instrumentalities is a mobile phone that
`communicates information in many ways, such as placing and receiving phone calls, sending and receiving
`video or audio data signals, or controlling or monitoring smart home devices.
`
`
`Each of the ’425 Patent Accused Mobile Phone Instrumentalities has a transceiver configured to receive, via a
`WiFi network, a first wireless signal corresponding to information directed to the wireless device, the
`information comprising a call.
`
`For example, each of the ’425 Patent Accused Mobile Phone Instrumentalities is configured to make or receive
`WiFi calls. When each of the ’425 Patent Accused Mobile Phone Instrumentalities receives a wireless signal
`containing voice data as part of a WiFi call, regardless of whether each of the ’425 Patent Accused Mobile
`Phone Instrumentalities originally initiated the call, each of the ’425 Patent Accused Mobile Phone
`Instrumentalities is receiving, via a WiFi network, a first wireless signal corresponding to information directed
`to the wireless device, the information comprising a call.
`
`Alternatively, the Google Duo app comes pre-installed on each of the ’425 Patent Accused Mobile Phone
`Instrumentalities. Google Duo is a video calling app that can use a WiFi network for calls. Using the Google
`Duo app, each of the ’425 Patent Accused Mobile Phone Instrumentalities can initiate or receive video calls.
`When each of the ’425 Patent Accused Mobile Phone Instrumentalities receives a wireless signal containing
`video call data as part of a Google Duo video call, regardless of whether each of the ’425 Patent Accused
`Mobile Phone Instrumentalities originally initiated the call, each of the ’425 Patent Accused Mobile Phone
`Instrumentalities is receiving, via a WiFi network, a first wireless signal corresponding to information directed
`to the wireless device, the information comprising a call.
`
`1
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 2 of 22 PageID #: 1382
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
`
`
`
`
` https://blog.google/products/allo/allo-duo-apps-messaging-video/
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 3 of 22 PageID #: 1383
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
`
`
` https://blog.google/products/allo/allo-duo-apps-messaging-video/
`
`
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`
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`Each of the ’425 Patent Accused Mobile Phone Instrumentalities uses a Qualcomm Snapdragon Mobile
`Platform.
`
`Given each of the ’425 Patent Accused Mobile Phone Instrumentalities’s ability to make or receive WiFi calls
`or Google Duo video calls, a transceiver associated with the Qualcomm Snapdragon Mobile Platform is
`configured to receive, via a WiFi network, a first wireless signal corresponding to information directed to the
`wireless device, the information comprising a call.
`
`
`The first wireless signal is a compressed signal.
`
`For example, when the first wireless signal includes voice data corresponding to the call, at least that voice data
`is compressed.
`
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`3
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`[b] the first wireless
`signal being a
`compressed signal,
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 4 of 22 PageID #: 1384
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
`
`Alternatively, the Google Duo app uses H.265 video compression. Accordingly, when conducting a video call
`using the Google Duo app, each of the ’425 Patent Accused Mobile Phone Instrumentalities receives a first
`wireless signal that comprises a compressed video signal.
`
`
` https://support.google.com/duo/thread/737807?hl=en
`
`
`Each of the ’425 Patent Accused Mobile Phone Instrumentalities is configured to receive an instruction to make
`the call.
`
`More specifically, there are a number of methods for instructing each of the ’425 Patent Accused Mobile Phone
`Instrumentalities to make a call, including dialing of a number, or initiation of calls via short cuts for
`established contacts such as speed dial, as well as voice activated instructions or clicking on a link associated
`
`
`
`[c] wherein the
`wireless device is
`configured to receive
`an instruction to make
`the call; and
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 5 of 22 PageID #: 1385
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
`
`with a phone number. Moreover, the Google Duo app on each of the ’425 Patent Accused Mobile Phone
`Instrumentalities can be used to initiate a video call. When any of these methods of initiating calls is used, an
`instruction is generated that each of the ’425 Patent Accused Mobile Phone Instrumentalities receives to make
`the call.
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`5
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 6 of 22 PageID #: 1386
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 7 of 22 PageID #: 1387
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
`
`
` https://blog.google/products/allo/allo-duo-apps-messaging-video/
`
`[d] a wireless signal
`conversion unit
`including a decoder
`configured to perform a
`conversion of the first
`wireless signal to
`accommodate
`production of the
`information,
`
`[e] wherein the
`decoder is configured
`to decompress the first
`wireless signal, said
`conversion comprising
`decompressing the first
`wireless signal;
`
`
`
`
`
`
`Each of the ’425 Patent Accused Mobile Phone Instrumentalities has a wireless signal conversion unit including
`a decoder configured to perform a conversion of the first wireless signal to accommodate production of the
`information.
`
`More specifically, the Qualcomm Snapdragon Mobile Platform used in each of the ’425 Patent Accused Mobile
`Phone Instrumentalities has a number of codecs that are configured to decompress a wireless signal
`corresponding to a call so that the audio information (voice) corresponding to the call can be played for so that a
`user of each of the ’425 Patent Accused Mobile Phone Instrumentalities can hear the call. Each codec is a
`different example of the decoder.
`
`For Google Duo video calls, the Qualcomm Snapdragon Mobile Platform has a H.265 codec that is configured
`to decompress H.265 video signals so that the video call can be displayed on each of the ’425 Patent Accused
`Mobile Phone Instrumentalities. The H.265 codec is another example of the decoder.
`
`
`
`
`The decoder is configured to decompress the first wireless signal, said conversion comprising decompressing
`the first wireless signal.
`
`More specifically, the Qualcomm Snapdragon Mobile Platform used in each of the ’425 Patent Accused Mobile
`Phone Instrumentalities has a number of codecs that are configured to decompress a wireless signal
`corresponding to a call so that the audio information (voice) corresponding to the call can be played for so that a
`user of each of the ’425 Patent Accused Mobile Phone Instrumentalities can hear the call. Each codec is a
`different example of the decoder.
`
`
`7
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`[f] wherein the
`wireless device is
`further configured to
`communicate
`information for
`managing a status
`update via the WiFi
`network in connection
`with a second wireless
`signal regarding the
`status update,
`
`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 8 of 22 PageID #: 1388
`
`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
`
`For Google Duo video calls, the Qualcomm Snapdragon Mobile Platform has a H.265 codec that is configured
`to decompress H.265 video signals so that the video call can be displayed on each of the ’425 Patent Accused
`Mobile Phone Instrumentalities. The H.265 codec is another example of the decoder.
`
`
`Each of the ’425 Patent Accused Mobile Phone Instrumentalities is configured to communicate information for
`managing a status update via the WiFi network in connection with a second wireless signal regarding the status
`update.
`
`In order to manage a status update of an item, each of the ’425 Patent Accused Mobile Phone Instrumentalities
`is configured to communicate information through a communication channel established on each of the ’425
`Patent Accused Mobile Phone Instrumentalities’s Wi-Fi network connection.
`
`For example, each of the ’425 Patent Accused Mobile Phone Instrumentalities can send information over a Wi-
`Fi network to, for example, control smart home devices including, but not limited to, light bulbs, thermostats,
`locks, outlets, and dimmers. Information that is sent to control a smart home device is information for
`managing a status update.
`
`For example, using the HTC Alexa application, each of the HTC U11, U11 Life, and U12+ can receive a voice
`command from a user instructing each of the HTC U11, U11 Life, and U12+ to control a smart home device.
`Each of the HTC U11, U11 Life, and U12+ converts the voice command into digital information reflective of
`the command, which is then sent over Wi-Fi or a cellular network by each of the HTC U11, U11 Life, and
`U12+ to the Alexa cloud. The Alexa cloud, in turn, uses the information from each of the HTC U11, U11 Life,
`and U12+ to compose a message known as a directive. The directive is sent to a skill which controls the smart
`home device. The skill communicates with the smart device management cloud, which in turn tells a
`hub/bridge in the user’s home to control the smart home device to effectuate the action indicated by the voice
`command.
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 9 of 22 PageID #: 1389
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
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`9
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 10 of 22 PageID #: 1390
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
`
`
`
`
`
`
`
`
`
`
`
`
`https://developer.amazon.com/docs/smarthome/understand-the-smart-home-skill-api.html
`
`An example of an item whose status update is managed by each of the HTC U11, U11 Life, and U12+ is a
`Philips Hue lightbulb. Using the HTC Alexa application, each of the HTC U11, U11 Life, and U12+can
`receive a voice command from a user instructing each of the HTC U11, U11 Life, and U12+to control a Philips
`Hue lightbulb. For example, each of the HTC U11, U11 Life, and U12+ can instruct the lightbulb to dim to
`50%. Each of the HTC U11, U11 Life, and U12+ converts the voice command into digital information
`reflective of the command to dim the lightbulb to 50%, which is then sent over a Wi-Fi network by each of the
`HTC U11, U11 Life, and U12+ to the Alexa cloud. The Alexa cloud, in turn, uses the information from each of
`the HTC U11, U11 Life, and U12+ to compose a message known as a directive. The directive is sent to a skill
`which controls the Philips Hue lightbulb. The skill communicates with the Philips Hue cloud, which in turn
`tells a Philips Hue Bridge in the user’s home to control the smart home device to effectuate the action indicated
`by the voice command, in this case dim the lights to 50%. When the Philips Hue lightbulb successfully dims to
`50%, it sends a message to the Philips Hue Bridge that the lightbulb was successfully dimmed.
`
`The Philips Hue Bridge and Philips Hue lightbulb communicate with each other over a Zigbee network. As
`such, both the command from the Philips Hue Bridge to the lightbulb and the message from the lightbulb to the
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 11 of 22 PageID #: 1391
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
`
`Philips Hue Bridge are sent over a Zigbee channel. Accordingly, when each of the HTC U11, U11 Life, and
`U12+ communicates information over a Wi-Fi network to manage the status of the Philips Hue lightbulb, it is
`communicating information for managing a status update in connection with a second wireless signal regarding
`the status update.
`
`The information for managing a status update can be a control signal originating from each of the HTC U11,
`U11 Life, and U12+ that updates the status of the item. Because such a control signal changes the item status, it
`qualifies as information for managing a status update. For example, a control signal that sets a light to 50% or
`on or off is a communication regarding the status update of the item.
`
`Alternatively, a signal sent via WiFi to each of the HTC U11, U11 Life, and U12+ that indicates the device’s
`current status would qualify as a communication regarding the status update of the item (for example, a Philips
`Hue light bulb indicates that the light has been set to 50%). Because such a signal indicates that the item status
`has been changed, it qualifies as a communication regarding a status update of the item. This type of change in
`item status may be observed using the Amazon Alexa application, which is a companion application to the HTC
`Alexa application.
`
`
`https://developer.amazon.com/docs/smarthome/understand-the-smart-home-skill-api.html
`
`
`Alternatively, another way in which each of the ’425 Patent Accused Mobile Phone Instrumentalities is
`configured to communicate information for managing a status update via the WiFi network in connection with a
`second wireless signal regarding the status update, is using the Google Assistant that is built into it.
`
`Using the Google Assistant, each of the ’425 Patent Accused Mobile Phone Instrumentalities can control,
`monitor, or otherwise manage a status update of an item, such as a smart home device.
`
`
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 12 of 22 PageID #: 1392
`
`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
`
`Each of the ’425 Patent Accused Mobile Phone Instrumentalities can send information over Wi-Fi to, for
`example, control smart home devices including, but not limited to, light bulbs, thermostats, locks, outlets, and
`dimmers. Information that is sent to control a smart home device is information for managing a status update
`via the WiFi network.
`
`For example, using the Google Assistant, each of the ’425 Patent Accused Mobile Phone Instrumentalities can
`receive a voice command from a user instructing each of the ’425 Patent Accused Mobile Phone
`Instrumentalities to control a smart home device. Each of the ’425 Patent Accused Mobile Phone
`Instrumentalities converts the voice command into digital information reflective of the command, which is then
`sent over Wi-Fi by each of the ’425 Patent Accused Mobile Phone Instrumentalities to the Google Assistant
`cloud. The Google Assistant cloud, in turn, uses the information from each of the ’425 Patent Accused Mobile
`Phone Instrumentalities to compose a message known as an intent. The intent is sent to the smart device
`management cloud, which in turn tells a hub/bridge in the user’s home to control the smart home device to
`effectuate the action indicated by the voice command.
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`
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 13 of 22 PageID #: 1393
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 14 of 22 PageID #: 1394
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 15 of 22 PageID #: 1395
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
`
`
`
`
`
`https://developers.google.com/actions/smarthome/concepts/intents
`
`An example of an item whose status update is managed by each of the ’425 Patent Accused Mobile Phone
`Instrumentalities is a Philips Hue lightbulb. Using the Google Assistant, each of the ’425 Patent Accused
`Mobile Phone Instrumentalities can receive a voice command from a user instructing each of the ’425 Patent
`Accused Mobile Phone Instrumentalities to control a Philips Hue lightbulb. For example, each of the ’425
`Patent Accused Mobile Phone Instrumentalities can instruct the lightbulb to dim to 50%. Each of the ’425
`Patent Accused Mobile Phone Instrumentalities converts the voice command into digital information reflective
`of the command to dim the lightbulb to 50%, which is then sent over Wi-Fi by each of the ’425 Patent Accused
`Mobile Phone Instrumentalities to the Google Assistant cloud. The Google Assistant cloud, in turn, uses the
`information from each of the ’425 Patent Accused Mobile Phone Instrumentalities to compose a message
`known as an intent. The intent is sent to the smart device management cloud, which in turn tells a Philips Hue
`Bridge in the user’s home to control the smart home device to effectuate the action indicated by the voice
`command, in this case dim the lights to 50%. When the Philips Hue lightbulb successfully dims to 50%, it
`sends a message to the Philips Hue Bridge that the lightbulb was successfully dimmed.
`
`Ultimately, each of the ’425 Patent Accused Mobile Phone Instrumentalities may receive a message that the
`lightbulb has now been dimmed to 50% and inform the user via the Google Assistant. When each of the ’425
`Patent Accused Mobile Phone Instrumentalities receives this message and notifies the user, that is another
`example of communicating information for managing a status update via the WiFi network.
`
`Communicating information for managing a status update may also occur in response to a query from the user.
`For example, a user may ask the Google Assistant whether a particular light is on. In response, the device status
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`15
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 16 of 22 PageID #: 1396
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
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`(e.g., whether the particular light is on) is provided to each of the ’425 Patent Accused Mobile Phone
`Instrumentalities.
`
`
`
`
`
`Alternatively, a signal may be actively pushed from a smart home device indicating a status update for the
`device. If a signal is subsequently sent to each of the ’425 Patent Accused Mobile Phone Instrumentalities
`indicative of that status update, that operation would also qualify as communicating information for managing a
`
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 17 of 22 PageID #: 1397
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
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`status update via the WiFi network (for example, a Philips Hue light bulb indicates that the light has been set to
`50%).
`
`
`
`
`
`
`
`https://developers.google.com/actions/smarthome/concepts/intents
`
`
`Regardless of whether Alexa or Google Assistant is used to manage the status update of a smart home device,
`when the smart home device controlled or monitored by each of the ’425 Patent Accused Mobile Phone
`Instrumentalities is a device controlled or monitored over a short range wireless network such as Zigbee or Z-
`Wave, each of the ’425 Patent Accused Mobile Phone Instrumentalities communicates information for
`managing a status update in connection with a second wireless signal regarding the status update.
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 18 of 22 PageID #: 1398
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
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`The second wireless signal is transmitted from a sensing device via a short range wireless communication
`channel.
`
`When each of the ’425 Patent Accused Mobile Phone Instrumentalities is used to manage the status update of a
`smart home device controlled or monitored using a a Zigbee or Z-Wave connection, the second wireless signal
`is transmitted from a sensing device via a short range wireless communication channel. The Zigbee or Z-Wave
`connection is the short range communication channel.
`
`For example, when a Philips Hue lightbulb whose status update is being managed by each of the ’425 Patent
`Accused Mobile Phone Instrumentalities sends to each of the ’425 Patent Accused Mobile Phone
`Instrumentalities information reflective of the status update, the Philips Hue lightbulb (which is controlled using
`a Zigbee connection) is a sensing device that transmits the second wireless signal via a short range wireless
`communication channel.
`
`
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`The second wireless signal comprises information associated with an identifier for the sensing device.
`
`For example, when a sensing device that is controlled using a Zigbee or Z-Wave connection sends a signal
`reflecting a status update (for example, that the lightbulb has been dimmed to 50%), that signal also must
`include an identifier associated with the sensing device so that Alexa or Google Assistant on each of the ’425
`Patent Accused Mobile Phone Instrumentalities can be provided with accurate updated status information for
`informing the user of each of the ’425 Patent Accused Mobile Phone Instrumentalities.
`
`
`[g] the second wireless
`signal being transmitted
`from a sensing device
`via a short range
`wireless
`communication
`channel,
`
`[h] the second wireless
`signal comprising
`information associated
`with an identifier for
`the sensing device; and
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`
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 19 of 22 PageID #: 1399
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
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`p. 52 Zigbee spec
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`p. 54 Zigbee spec
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 20 of 22 PageID #: 1400
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
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`p. 55 Zigbee spec
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`p. 309 Zigbee spec
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 21 of 22 PageID #: 1401
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
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`p. 312 Zigbee spec
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`p. 312 Zigbee spec
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`Case 4:20-cv-00180-ALM Document 42-2 Filed 04/28/20 Page 22 of 22 PageID #: 1402
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`Exhibit 2 – Infringement Claim Chart for U.S. Patent No. 10,104,425
`Mobile Phone Instrumentalities
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`pp. 312-13 Zigbee spec
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`[i] wherein the WiFi
`network is separate
`from the short range
`wireless
`communication
`channel.
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`
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`p. 154, z-wave spec
`
`
`The Wi-Fi network used by each of the ’425 Patent Accused Mobile Phone Instrumentalities to manage the
`status update of an item is separate from the short range wireless communication channel.
`
`For example, the network communication channel over which each of the ’425 Patent Accused Mobile Phone
`Instrumentalities sends or receives information for managing a status update is a channel established on a WiFi
`network, whereas the short range wireless communication channel is established on one of a Zigbee or Z-Wave
`network. Because the WiFi network is separate from Zigbee or Z-Wave, it is separate from the claimed short
`range wireless communication channel.
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