Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 1 of 10 PageID #: 261
`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 1 of 10 PageID #: 261
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`EXHIBIT K
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`EXHIBIT K
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`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 2 of 10 PageID #: 262
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`Analysis of Infringement of U.S. Patent No. 6,907,305 by Huawei Device USA Inc., Huawei Device Co., Ltd., and HiSilicon Technologies Co., Ltd.
`(Based on Public Information Only)
`
`
`Plaintiff Ocean Semiconductor LLC (“Ocean Semiconductor”), provides this preliminary and exemplary infringement analysis with respect to
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`infringement of U.S. Patent No. 6,907,305 entitled “AGENT REACTIVE SCHEDULING IN AN AUTOMATED MANUFACTURING ENVIRONMENT”
`(the “’305 patent”) by Huawei Device USA Inc., Huawei Device Co., Ltd., and HiSilicon Technologies Co., Ltd. (“Huawei”). The following chart illustrates
`an exemplary analysis regarding infringement by Defendant Huawei’s semiconductor products, systems, devices, components, and integrated circuits, and
`products containing such circuits, fabricated or manufactured using camLine GmbH’s (“camLine”) semiconductor fabrication or manufacturing equipment,
`platforms, and/or framework, including camLine’s software and APC system, including the LineWorks factory advanced/automation process control (“APC”)
`platform hardware and/or software (collectively, “LineWorks”) and/or other APC system and platform hardware and/or software. Such products include,
`without limitation, SoC chipsets and solutions (e.g., Hi3559A V100, Hi3519A V100, Hi3516D V300, Hi3556A V100, Hi3559 V200, Hi3559A V100, Hi3559C
`V100, Hi3559 V100, Hi3716M V430, Hi3716M V430, Hi3798C V200, Hi3798M V200H, Hi3798M V300, Hi3798M V310, Hi3796M V200, Hi3798M V200,
`Hi3796M V100, Hi3798M V100, Hi3716M V420, Hi3716M V410, and Hi3751 V553), processors (e.g., Hi3536, Hi3536C, Hi3536D V100, Hi3531D V100,
`Hi3521D V100, Hi3520D V400, Hi3520D V300, and Hi3520D V200), TV solutions (e.g., Hi3731 V201, Hi3731 V101, Hi3751 V811, HI3751 V810, Hi3751
`V551, Hi3751 V730, Hi3751 V620, Hi3751 V510, Hi3751 V310, Hi3751 V320, and Hi3751 V600), Kirin solutions (e.g., Kirin 9000/E, Kirin 1020, Kirin 990,
`Kirin 980, Kirin 970, Kirin 960, Kirin 950, Kirin 930, Kirin 920, Kirin 910, and Kirin 710); Ascend solutions (e.g., Ascend 310 and Ascend 910); Kunpeng
`solutions (e.g., Kunpeng 920); and Balong solutions (e.g., Balong 5000, Balong 5G01, Balong 765, Balong 750, Balong 720, Balong 710, and Balong 700),
`systems, products, or devices containing these solutions, and similar systems, products, devices, and integrated circuits (collectively, the “’305 Infringing
`Instrumentalities”).
`
`The analysis set forth below is based only upon information from publicly available resources regarding the ’305 Infringing Instrumentalities, as
`Huawei has not yet provided any non-public information.
`
`Unless otherwise noted, Ocean Semiconductor contends that Huawei directly infringes the ’305 patent in violation of 35 U.S.C. § 271(g) by using,
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`selling, and/or offering to sell in the United States, and/or importing into the United States, the ’305 Infringing Instrumentalities. The following exemplary
`analysis demonstrates that infringement. Unless otherwise noted, Ocean Semiconductor further contends that the evidence below supports a finding of indirect
`infringement under 35 U.S.C. § 271(b) in conjunction with other evidence of liability.
`
`Unless otherwise noted, Ocean Semiconductor believes and contends that each element of each claim asserted herein is literally met through Huawei’s
`
`provision or importation of the ’305 Infringing Instrumentalities. However, to the extent that Huawei attempts to allege that any asserted claim element is not
`literally met, Ocean Semiconductor believes and contends that such elements are met under the doctrine of equivalents. More specifically, in its investigation
`and analysis of the ’305 Infringing Instrumentalities, Ocean Semiconductor did not identify any substantial differences between the elements of the patent
`claims and the corresponding features of the ’305 Infringing Instrumentalities, as set forth herein. In each instance, the identified feature of the ’305 Infringing
`Instrumentalities performs at least substantially the same function in substantially the same way to achieve substantially the same result as the corresponding
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`

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`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 3 of 10 PageID #: 263
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`claim element.
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`Ocean Semiconductor notes that the present claim chart and analysis are necessarily preliminary in that Ocean Semiconductor has not obtained
`substantial discovery from Huawei nor has Huawei disclosed any detailed analysis for its non-infringement position, if any. Further, Ocean Semiconductor
`does not have the benefit of claim construction or expert discovery. Ocean Semiconductor reserves the right to supplement and/or amend the positions taken in
`this preliminary and exemplary infringement analysis, including with respect to literal infringement and infringement under the doctrine of equivalents, if and
`when warranted by further information obtained by Ocean Semiconductor, including but not limited to information adduced through information exchanges
`
`between the parties, fact discovery, claim construction, expert discovery, and/or further analysis.
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`

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`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 4 of 10 PageID #: 264
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`USP 6,907,305
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`
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`Infringement by the ’305 Accused Instrumentalities
`
`1. A method for scheduling in an automated
`manufacturing environment, comprising:
`
`
`To the extent that the preamble of Claim 1 is a limitation, the camLine LineWorks system, which is
`used to fabricate or manufacture the ’305 Infringing Instrumentalities, provides a method for
`scheduling in an automated manufacturing environment.
`
`For example, camLine’s LineWorks system provides for scheduling in an automated manufacturing
`environment, as shown below.
`
`
`See camLine LineWorks MaiMa online product description, available at
`https://www.camline.com/products/lineworks/lineworks-maima-pulse/ (last visited October 18,
`2020) (“MaiMa Webpage”).
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`

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`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 5 of 10 PageID #: 265
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`detecting an occurrence of a predetermined event
`in a process flow;
`
`The camLine LineWorks system detects an occurrence of a predetermined event in a process flow.
`
`For example, the camLine LineWorks EcoFrame module collects data related to a process flow, as
`shown below:
`
`
`
`See LineWorks ECoFrame Webpage, available at
`https://www.camline.com/products/lineworks/lineworks-ecoframe/ (last visited October 18, 2020)
`(“ECoFrame Webpage”).
`
`As another example, the LineWorks Master Process Monitor (MPM) module detects events in a
`process flow. MPM can be used according to “configurable parameters” (e.g., to detect the
`occurrence of a predetermined event), as shown below:
`
`
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`

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`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 6 of 10 PageID #: 266
`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 6 of 10 PageID #: 266
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`
`LineWorks MPM (Master Process Monitor) provides manufacturing; operators and
`
`Cl igir'it_‘-(,:rs with a real-tii‘ne overview of their production i'(1)si,Ilts.
`
`inforrriatidn about passed or failed operations is collected by LineWorks WIP foreach unit (such as lot] and forwarded to the MPM server which evaluates
`the results according to defined rules and initiates escalations as required. in case of violation of one of these rules, a notification via e mail. SMS‘ etc, is
`sent to the responsible group of people with the request torconfirrnation, At such events, production facilities can synchronously be locked or unlocked
`All incidents are precisely documented, These records are available for re ports and further analysis
`
`Technical Details
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`0 Monitoring of the production ime
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`O Corltrololshop floor equrprrient based on 10 rules with
`configurable parameters
`
`O tmeWorlcs iGate Reports (Channel Overview. Trent:I Report
`Compare Repait}
`
`0 Web-based administration client fWebUll
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`0 Keeping long-term records of the data collected
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`0 Notification client for violations on selected channels
`
`
`
`
`See LineWorks MPM Webpage, available at
`See LineWorks MPM Webpage, available at
`ttps://WWW.camline.com/products/lineworks/lineworks—mpm/ (last Visited October 18, 2020)
`https://www.camline.com/products/lineworks/lineworks-mpm/ (last visited October 18, 2020)
`(“MPM Webpage”).
`(“MPM Webpage”).
`
`
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`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 7 of 10 PageID #: 267
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`notifying a software scheduling agent of the
`occurrence; and
`
`
`The camLine LineWorks system notifies a software scheduling event of the occurrence of a
`predetermined event.
`
`For example, LineWorks MaiMa, a software scheduling agent, can be notified of the occurrence of
`a predetermined event through its connection to the LineWorks PULSE or LineWorks SPACE
`modules, as shown below.
`
`
`
`See MaiMa webpage.
`
`As shown below, the LineWorks PULSE module receives information regarding a process event
`from the LineWorks ECoFrame module:
`
`
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`

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`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 8 of 10 PageID #: 268
`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 8 of 10 PageID #: 268
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`LineWorks ECoFrame (Equipment Connection Framework) offers efficient methods for
`
`equipment integration including equipment data collection. data routing. and remote
`
`equipment control. Due to the automatic data acquisition, the highest data quality and
`
`granularity is guaranteed.
`
`It allows process data. alarms. or events to be routed to other LineWorks modules and /
`
`or third—party solutions. The framework supports international communication standard
`
`protocols. eg. SECS/GEM. PROFIBUS, OPC.
`
`O Broad range of equipment connections via e. g. SECS, HSMS.
`OPC. Profibus OPC. CORBA. Digital I/O
`
`0 SEC (Statistical Equipment Control) in combination with
`LineWorks SPACE or other SPC systems
`
`0 lnformation forwarding and control of production line actions
`
`0 Monitoring of throughput and Off via LineWarks PULSE
`
`0 Handling of alarms and process data logging enables the
`generation of event reports
`
`0 Configurable data routing of alarms, events. or process data to
`other LineWorks modules or third party solutions
`
`0 Integrated database for Process Data Collection (P00
`
`0 Webvbased reporting with LineWorks iGate {or collected PDC
`data
`
`
`0 Extending the equipment interface by an operator screen
`
`0 Recipe download. upload. or select
`
`0 Optional equipment control
`
`
`See ECoFrame Webpage.
`See ECoFrame Webpage.
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`
`
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`

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`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 9 of 10 PageID #: 269
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`reactively scheduling an action from the software
`scheduling agent responsive to the detection of
`the predetermined event.
`
`
`The camLine LineWorks system reactively schedules an action from the software scheduling agent
`responsive to the detection of the predetermined event.
`
`For example, as shown below, the LineWorks PULSE module receives information regarding a
`process event from the LineWorks ECoFrame module:
`
`
`
`See ECoFrame Webpage.
`
`As a further example, LineWorks MaiMa “schedule[s] maintenance tasks” and is “integrat[ed] with
`LineWorks PULSE to synchronize the equipment status,” as shown below:
`
`
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`

`

`Case 4:20-cv-00991-ALM
`Case 4:20-cv-00991-ALM Document 1-11 Filed 12/31/20 Page 10 of 10 PageID #: 270
`Document 1—11 Filed 12/31/20 Page 10 of 10 PageID #: 270
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