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`Exhibit 5
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`
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 2 of 28
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`U.S. Patent No. 7,821,502 (“’502 Patent”)
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`Exemplary Accused Product
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`The Apple iPad Pro 3rd Gen 12.9” tablet (“iPad Pro”) infringes at least Claim 1 of the ’502 Patent.
`
`Claims
`
`iPad Pro
`
`[1pre] A position sensor comprising:
`
`The iPad Pro includes a position sensor (e.g., touchscreen).
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`Photograph of iPad Pro.
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`For example, the iPad Pro includes an A12X CPU and Broadcomm BCM15900B0
`touch controllers that controls the device’s touch sensing capability, including
`performing measurements on signals from the touch sensor (e.g., touchscreen).
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`
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`Page 1
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 3 of 28
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`Photograph of main circuit board of iPad Pro, showing A12X CPU.
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`
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`Page 2
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 4 of 28
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`[1a] a substrate having a surface with an
`arrangement of electrodes mounted
`thereon,
`
`
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`Photograph of touch sensor circuit board of an iPad Pro, showing Broadcomm
`BCM15900B0 touch controllers.
`
`The iPad Pro includes a substrate having a surface with an arrangement of electrodes
`mounted thereon.
`
`The iPad Pro includes a substrate having an arrangement of electrodes mounted on the
`two sides of a substrate. For example, an arrangement of electrodes (blue drive
`electrodes) on one side of the substrate of the iPad Pro is shown below.
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`Page 3
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 5 of 28
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`Top-down view of the arrangement of electrodes (blue drive electrodes run horizontally
`in the above photo, red sense electrodes run vertically in the above photo).
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`
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`Page 4
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 6 of 28
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`Top-down view of the arrangement of electrodes (blue drive electrodes run horizontally
`in the above photo, red sense electrodes not annotated).
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`
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`Page 5
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 7 of 28
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`
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`The blue drive electrodes are continuous and connect to the right side of the
`touchscreen at the pads shown. The red arrows indicate breaks between adjacent
`electrodes.
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`Page 6
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`
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 8 of 28
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`
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`The blue drive electrodes are continuous and connect to the left side of the touchscreen
`at the pads shown. The red arrow indicates a break between adjacent electrodes.
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`Page 7
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 9 of 28
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`Diagram of the drive electrodes, shown in blue, arranged on the substrate.
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`Page 8
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 10 of 28
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`Top-down view of the arrangement of electrodes (blue drive electrodes not annotated,
`red sense electrodes run vertically in the above photo).
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`
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`Page 9
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 11 of 28
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`
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`Diagram of the sense electrodes, shown in red, arranged on the substrate.
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`Page 10
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 12 of 28
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`Photograph of interior of iPad Pro, showing auxiliary FPC connecting the far end of the
`sense electrodes (red) to the main FPC.
`
`
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`[1b] wherein the electrodes define an
`array of sensing cells arranged in
`
`The iPad Pro includes a touchscreen, wherein the electrodes define an array of sensing
`cells arranged in columns and rows to form a capacitive sensing area of the sensor.
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`Page 11
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 13 of 28
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`columns and rows to form a capacitive
`sensing area of the sensor,
`
`An example of an array of sensing cells arranged in columns and rows, defined by the
`electrodes in the touchscreen of the iPad Pro, is shown below. These electrodes of the
`touch sensor of the iPad Pro define an array of sensing cells to form a capacitive
`sensing area of the sensor.
`
`
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`Page 12
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 14 of 28
`
`Top-down view of the arrangement of electrodes (blue drive electrodes run horizontally
`in the above photo, red sense electrodes run vertically in the above photo).
`
`
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`Page 13
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 15 of 28
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`Annotated photograph of portion of the iPad Pro touchscreen.
`
`
`
`
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`[1c] each sensing cell including a column
`sensing electrode and a row sensing
`electrode, the column sensing electrodes
`of sensing cells in the same column being
`electrically coupled together and the row
`sensing electrodes of sensing cells in the
`same row being electrically coupled
`together, and
`
`
`
`Illustration of capacitive coupling within a representative capacitive sensing area.
`
`In the iPad Pro’s touchscreen, each sensing cell includes a column sensing electrode
`and a row sensing electrode, the column sensing electrodes of sensing cells in the same
`column being electrically coupled together and the row sensing electrodes of sensing
`cells in the same row being electrically coupled together.
`
`For example, the sensing cells of the iPad Pro shown below include a column sensing
`electrode and a row sensing electrode.
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`Page 14
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`
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 16 of 28
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`Top-down view of the arrangement of electrodes (blue drive electrodes run horizontally
`in the above photo, red sense electrodes run vertically in the above photo).
`
`
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`Page 15
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`
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 17 of 28
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`The column sensing electrodes belonging to sensing cells that are in the same column
`are electrically coupled together. Also, the row sensing electrodes belonging to sensing
`cells that are in the same row are electrically coupled together.
`
`
`
`Diagram of the sense electrodes, shown in red, arranged on the substrate.
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`
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`Page 16
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 18 of 28
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`Diagram of the drive electrodes, shown in blue, arranged on the substrate.
`
`
`
`
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`[1d] wherein row sensing electrodes of
`sensing cells at opposing ends of at least
`one of the rows are electrically coupled
`to one another by respective row wrap-
`around connections made outside of the
`sensing area.
`
`The iPad Pro includes a touchscreen, wherein the row sensing electrodes of sensing
`cells at opposing ends of at least one of the rows are electrically coupled to one another
`by respective row wrap-around connections made outside of the sensing area.
`
`For example, the row sensing electrodes of sensing cells, as shown below, have their
`opposite ends coupled to one another by row wrap-around connections made outside of
`the sensing area.
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`Page 17
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`
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 19 of 28
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`Diagram of the drive electrodes, shown in blue, arranged on the substrate.
`
`
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`Page 18
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 20 of 28
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`Top-down view of the arrangement of electrodes (blue drive electrodes run horizontally
`in the above photo, red sense electrodes not annotated).
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`
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`Page 19
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`
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 21 of 28
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`
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`The blue drive electrodes are continuous and connect to the right side of the
`touchscreen at the pads shown (e.g., portion of wrap-around connections, which are
`outside the sensing area). The red arrows indicate breaks between adjacent electrodes.
`
`Page 20
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`
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 22 of 28
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`
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`The blue drive electrodes are continuous and connect to the left side of the touchscreen
`at the pads shown (e.g., portion of wrap-around connections, which are outside the
`sensing area). The red arrow indicates a break between adjacent electrodes.
`
`Page 21
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`
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 23 of 28
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`
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`Photograph of portion of edge traces (e.g., portion of wrap-around connections, which
`are outside the sensing area) that connect the drive electrodes to the connector, as
`shown.
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`
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`Page 22
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`
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 24 of 28
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`Photograph of portion of FPC (e.g., portion of wrap-around connections, which are
`outside the sensing area), showing connection areas for drive electrodes (blue) and
`sense electrodes (red).
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`Page 23
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 25 of 28
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`X-ray of portion of FPC (e.g., portion of wrap-around connections, which are outside
`the sensing area), showing select traces of drive electrodes (blue) and sense electrodes
`(red).
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`Page 24
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 26 of 28
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`Page 25
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 27 of 28
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`X-ray of portion of FPC (e.g., portion of wrap-around connections, which are outside
`the sensing area), showing short circuit connections of two select traces of drive
`electrodes (blue) and two select traces of sense electrodes (red).
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`
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`Photograph of resistance measurement confirming short circuit connection of select
`drive electrodes (blue).
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`Page 26
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`Case 6:20-cv-00212-ADA Document 1-5 Filed 03/23/20 Page 28 of 28
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`Page 27
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