Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 1 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 1 of 21
`
`EXHIBIT KK
`EXHIBIT KK
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 2 of 21
`
`Gentex Corporation and Indigo Technologies, LLC (collectively, “Gentex”) presently
`contend that Facebook, Inc. and Facebook Technologies, LLC (collectively, “Facebook”)
`infringe claim 1 (the “Asserted Claim”) of U.S. Patent No. 8,224,024, directly and/or indirectly,
`either literally or under the doctrine of equivalents. This chart sets forth Gentex’s preliminary
`infringement contentions relating to the Asserted Claims and the accused products, i.e., the
`Oculus Rift S, Oculus Quest, and Oculus Quest 2 (collectively, the “Accused Products”). In the
`event Facebook releases new products or services that infringe the ’024 patent, or further
`investigation reveals that other products or services infringe the ’024 patent, Gentex reserves the
`right to update these contentions as appropriate under the Order Governing Proceedings.
`
`
`These contentions articulate the structure and acts that constitute direct and/or indirect
`infringement of the ’024 patent and identify specifically where each element of each asserted
`claim is found within each Accused Product. Exemplary references to publicly available
`information concerning the Accused Products is provided where appropriate. Exemplary
`references to specific Accused Products are not intended and should not be read to exclude
`Accused Products not exemplified. On information and belief, the Accused Products are
`materially the same with respect to the claims of the ’024 patent discussed below. This
`disclosure is not intended to describe all acts of direct, induced, or contributory infringement
`Facebook has and continues to commit by making, using, selling, providing, developing,
`installing, testing, deploying, and/or directing the use of the Accused Products by customers and
`end users. The parties have not engaged in any discovery. The parties also have not discussed
`proposed constructions for, and the Court has not yet construed, any of the claims of the ’024
`patent. As a result, and consistent with the Order Governing Proceedings, Gentex reserves the
`right to modify, amend, or otherwise supplement these initial infringement contentions as
`discovery and the pre-trial phase of the litigation proceed and as additional information comes to
`light, including with respect to which claims Gentex is asserting, the infringement analysis for
`one or more of the claims, and whether and how limitations of one or more claims are met
`literally or under the doctrine of equivalents.
`
`
`U.S. Patent 8,224,024
`
`Claim 1
`Claim Limitation
`(1pre) A method
`comprising obtaining a
`camera image from a
`camera and processing
`said camera image in a
`data processor by
`computing the spatial
`location and azimuth of
`an object from the
`locations, in said camera
`image, of exactly two
`points on the object, and
`information about an
`orientation of the object,
`
`Accused Products
`Facebook encourages, directs, or promotes users to use the Accused Products to
`carry out the claimed method, and Facebook performs the claimed method, as
`set forth below. For example, Facebook obtains a camera image, and
`encourages users to use the Accused Products to obtain a camera image from a
`camera and process said camera image in a data processor (e.g., in the Oculus
`Quest or Quest 2 headset processor or in a desktop processor for the Oculus
`Rift S) by computing the spatial location and azimuth of an object from the
`locations, in said camera image, of exactly two points on the object (e.g., the
`locations of two LED markers on an Oculus Touch Controller), and
`information about an orientation of the object (e.g., information about
`orientation from an Oculus Touch Controller’s inertial measurement unit, or
`“IMU”), and generating one or more signals representative of the location and
`azimuth of the object, wherein computing the azimuth of the object comprises
`the steps below. The Accused Products are especially adapted to carry out this
`
`2
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 3 of 21
`
`
`See also From the Lab, Sensor Placement at 0:23.
`
`
`
`(1a) receiving coordinate
`information for images,
`on an imaging device of
`a camera, of two points
`on an object,
`
`
`
`
`
`Facebook encourages, directs, or promotes users to use the Accused Products to
`receive coordinate information for images, on an imaging device of a camera
`(e.g., the cameras on the headset), of two points on an object (e.g., two LED
`markers on an Oculus Touch Controller (for example, “it is fairly common for
`cameras to only see 3, 2 or even 1 LED(s) at a time,” LED Matching)), and
`Facebook performs such step itself. The Accused Products are especially
`adapted to carry out this method, which is a material part of the claimed
`invention, and have no substantial noninfringing uses. Further, on information
`
`13
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`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 4 of 21
`
`and belief, Facebook conditions a user’s use of the Accused Products, and
`therefore the user’s receipt of the benefits of the Accused Products, upon this
`method and establishes the manner or timing of that use (e.g., through its
`software and/or user instructions, which have not been provided at this stage of
`the litigation).
`
`To the extent this limitation is not met literally, the Accused Products also
`satisfy this limitation under the doctrine of equivalents. Any difference
`between the Accused Products and the claim element is insubstantial.
`
`See, e.g., Oculus Quest 2 Instructions.
`
`
`
`
`
`See also From the Lab.
`
`
`14
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 5 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 5 of 21
`
`
`
`FB Sensor Placement
`Tech@Facebook @ -
`
`eaetter
`Pegaenad
`
`
`See also Lang.
`See also Lang.
`
`Ty
`playspace.
`
`
`
`
`
`Image courtesy BadVR, Jad Meouchy
`
`Around the mainboard wecan also see the headset's four cameras mountedat very
`
`purposeful angles at the corners. The cameras are essential to enabling 6DOF tracking
`
`on both the headset and the controllers; their views are also merged together to allow a
`
`pass-through vision mode on the headset which is used to trace the boundary of your
`
`
`See also Heaney.
`See also Heaney.
`
`15
`15
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 6 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 6 of 21
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`
`
`Me)roe dee Erledire]
`
`ICM-20601 IMU from late 2015.
`
`A function for infrared LED calibration exists, suggesting this controlleris
`optically tracked in the same wayas the current Touch— camerason the
`headsetfollow the movementof the LED constellation, and this is fused with
`the accelerometerreadings to achieve sub-mm precision.
`
`
`See also Heaney.
`The driver also reveals the series model numberofthe controller'sinertial
`measurementunit (IMU)- the chip within all VR controllers which contains
`the accelerometer.
`
`Teardowns and the FCCfilings for the current Touch showedit uses TDK’s
`
`
`
`
`
`
`See also ICM-20601 Specification.
`See also ICM-20601 Specification.
`
`16
`16
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 7 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 7 of 21
`
`
`
`FEATURES
`
`e
`
`e
`
`3-Axis Gyroscope with Programmable FSR of
`+500dps, +100dps, +2000dps and +4000dps
`3-Axis Accelerometer with Programmable FSR of
`+4g, +8g, +16g, and +329
`e User-programmable interrupts
`e Wake-on-motion interrupt for low power operation
`of applications processor
`512 byte FIFO buffer enables the applications
`processorto read the datain bursts
`On-Chip 16-bit ADCs and Programmable Filters
`Host interface: 8 MHz SPI or 400k Hz Fast Mode I7C
`
`e
`
`Digital-output temperature sensor
`VDD operating range of 1.71 to 3.45V
`MEMS structure hermetically sealed and bonded at
`wafer level
`
`e
`
`ROHS and Green compliant
`
`
`
`
`
`See also LED Matching.
`See also LED Matching.
`Computing more with less data
`Theoretically, given only one camera image, you need at least three LEDs to be in view to solve
`for the controller's pose. However,utilizing only three points leads to multiple possible solutions,
`therefore we require at least four correct matches to robustly solve for the pose.
`
`It is fairly common for cameras to only see 3, 2 or even 1 LED(s) at a time, so we designed
`solvers that could use other information and work with fewer LEDsin view.In turn, this included
`the following new solvers whichallow us to track in those particularly challenging orientations:
`
`P2P pose solver
`+ Uses 2 matches and prior poseorientation information to solve for position componentof the pose.
`+ Reduces minimum matching requirement to 3 matches (2 hypothesis generating matches and 1 validating match)
`
`predicted pose as a hard constraint in solving the problem.
`
`P1P pose solver
`« Uses the predicted pose to validate matches directly, instead of validating via statistical or nearest neighbor predictions.
`+ Reduces minimum matching requirement to 2 matches (Ensurestranslation and scale is constrained properly for stereo-pose optimization)
`+ Uses position-only stereo-pose optimization in the case of = 4 LEDs to avoid under-constraining orientation.
`
`After extensive experimentation, we discovered that both P2P and P1P solvers require very
`accurate prior information (good tracking state and accurate prediction), as they rely on the
`
`
`See also Andrew Melim,Increasing Fidelity with Constellation-Tracked
`See also Andrew Melim, Increasing Fidelity with Constellation-Tracked
`Controllers, https://developer.oculus.com/blog/increasing-fidelity-with-
`Controllers, https://developer.oculus.com/blog/increasing-fidelity-with-
`constellation-tracked-controllers/ (Sept. 20, 2019).
`constellation-tracked-controllers/ (Sept. 20, 2019).
`
`17
`17
`
`
`
`

`

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`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 8 of 21
`
`
`
`Challenges
`
`The key underlying principle that drives Constellation tracking is the detection and
`
`triangulation of infrared LEDs within camera images which have extremely short
`
`exposure times. For each controller, the tracking system attempts to solve for the
`
`3D pose, which is the 3D position and orientation. Within each frame, the system
`
`executes the following steps:
`
`® Search camera images for bright volumesof infrared light
`
`® Determine a matching scheme between image projections and the underlying
`3D model of the controller
`
`® Compute the 3D poseof the controller with respect to the headset and fuse
`with inertial data
`
`
`
`See also From the Lab.
`See also From the Lab.
`
`
`on a mobile chipset.
`
`There are other complications, too. The infrared LEDs in the two hand controllers
`drastically change appearance when they movecloser or farther away from the
`headset as you swing a virtual sword or maneuvera virtual spaceship. Oculus
`Insight also uses other sensors, drawing acceleration and velocity data from the
`inertial measurement units (IMUs) located in the headset and controllers. The
`system must processall of these data pointsin real time and, in the case of Quest,
`
`
`
`
`
`
`See also From the Lab.
`See also From the Lab.
`
`18
`18
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 9 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 9 of 21
`
`
`
`efficient computer vision algorithms that work well on mobile devices.
`
`Taking SLAM technology...
`
`The foundation of Oculus Insight's inside-out tracking is simultaneous localization
`and mapping, or SLAM, which uses computer vision CV algorithms to essentially
`fuse incoming data from multiple sensors in orderto fix the position of an object
`within a constantly updated digital map. SLAM has beenused in robotics and in
`AR camera effects on smartphones and was demoedin the Oculus Santa Cruz VR
`headset prototype in 2016. But Oculus Insight required an unprecedented level of
`precision and efficiency, and that meant adapting the latest research on tracking
`and computervision.
`
`“A lot of these technologies really start in academia — inside the lab," Kozminski
`notes.
`It's no coincidence, then, that she’s part of Facebook's Zurich-based team
`of engineers, many of whom came from Zurich Eye — a joint program from the
`prestigious ETH University and University of Zurich that researchedself-
`navigating systems.
`
`To build a new, more advanced version of SLAM, the engineering team drew from
`Facebook's years of Al research and engineering work, building systems to
`understand the objects and actions that appear in videos and creating highly
`
`
`
`
`See also Compare Headsets,
`See also Compare Headsets,
`https:/Awww.oculus.com/compare/?products=quest%2Cquest-2.
`https://www.oculus.com/compare/?products=quest%2Cquest-2.
`
`19
`19
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 10 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 10 of 21
`
`
`
`Oculus Quest
`All-In-One VR Gaming
`
`
`
`TRACKING
`
`Six Degrees of Freedom
`
`With 6DOF, the headsettracks the movementof both your
`head and body, then translates them into VR with realistic
`precision. No external sensors required.
`
`
`
`
`20
`20
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 11 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 11 of 21
`
`
`
`CONTROLLERS
`
`
`
`PE
`
`Touch Controllers
`
`Oculus Touch controllers transport your hands, gestures and
`interactions into VR with intuitive accuracy.
`
`
`
`Oculus Quest 2
`AdvancedAll-In-One VR Gaming
`
`Starting At $299 USD’
`
`
`
`21
`21
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 12 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 12 of 21
`
`
`
`TRACKING
`
`Six Degrees of Freedom
`
`With 6DOF, the headsettracks the movement of both your
`head and body, then translates them into VR with realistic
`precision. No external sensors required.
`
`
`
`CONTROLLERS
`
`SS
`a)
`a)
`
`Redesigned Touch Controllers
`
`Quest 2 Touch controllers have been upgraded with improved
`ergonomics. Anew thumb rest adds stability when needed.
`
`
`
`
`
`See also OculusRift S.
`See also Oculus Rift S.
`
`
`22
`22
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 13 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 13 of 21
`
`
`
`PC-Powered VR
`Gaming
`ur best VR game
`
`=a $399USD"
`
`View PC requirements
`
`Improved opti
`d
`“scre
`
`Ergonomic Design
`halo
`t
`dbar
`re
`mfort
`
`4
`
`J
`
`4
`
`J
`
`Oculus Touch Controllers
`IR
`Your
`slashes,
`throws
`and grabs appearin VR with
`realistic precisior
`
`<>—
`
`¢
`uv
`
`Improved Optics Ss
`to listen to music,” says Kozminski.
`
`
`See also From the Lab.
`See also From the Lab.
`
`“We wanted to create a system that lets you move and explore a VR world just as
`naturally and easily as you would in real life,” says Kozminski.
`
`Kozminski joined a team whose mission was to create thefirst full-featured “inside-out”
`tracking system for a consumer VR device. The technology would have to track thefull
`range of a person’s movements (known as six degrees of freedom) and be able to
`pinpoint the location of the two handheld controllers as well as the headset.
`
`Previously, VR devices relied on external sensors to track these movements. These
`cameras attach to a PC, and while they work well, they make VR less portable and more
`complicated to set up.
`
`“With inside-out tracking in the headset, VR becomes as easy as putting on headphones
`
`
`
`
`
`
`See also Powered by Al.
`See also Powered by AI.
`
`23
`23
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 14 of 21
`
`
`See also From the Lab, Sensor Placement at 0:23.
`
`
`
`(1b) receiving pitch
`information from a
`sensor on the object,
`
`
`
`
`
`
`Facebook encourages, directs, or promotes users to use the Accused Products to
`receive pitch information from a sensor on the object (e.g., to receive pitch
`information from the Oculus Touch Controller IMU), and Facebook performs
`such step itself. The Accused Products are especially adapted to carry out this
`method, which is a material part of the claimed invention, and have no
`substantial noninfringing uses. Further, on information and belief, Facebook
`conditions a user’s use of the Accused Products, and therefore the user’s receipt
`of the benefits of the Accused Products, upon this method and establishes the
`
`24
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 15 of 21
`
`manner or timing of that use (e.g., through its software and/or user instructions,
`which have not been provided at this stage of the litigation).
`
`To the extent this limitation is not met literally, the Accused Products also
`satisfy this limitation under the doctrine of equivalents. Any difference
`between the Accused Products and the claim element is insubstantial.
`
`See, e.g., LED Matching.
`
`
`See also Andrew Melim, Increasing Fidelity with Constellation-Tracked
`Controllers, https://developer.oculus.com/blog/increasing-fidelity-with-
`constellation-tracked-controllers/ (Sept. 20, 2019).
`
`
`
`
`
`See also From the Lab.
`
`25
`
`
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 16 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 16 of 21
`
`
`There are other complications, too. The infrared LEDs in the two hand controllers
`drastically change appearance when they movecloser or farther away from the
`headset as you swing a virtual sword or maneuver a virtual spaceship. Oculus
`Insight also uses other sensors, drawing acceleration and velocity data from the
`inertial measurement units (IMUs) located in the headset and controllers. The
`system must processall of these data pointsin real time and,in the case of Quest,
`
`on a mobile chipset.
`
`
`
`
`See also Compare Headsets.
`See also Compare Headsets.
`
`
`Six Degrees of Freedom
`
`With 6DOF, the headsettracks the movementof both your
`head and body, then translates them into VR with realistic
`precision. No external sensors required.
`
`
`
`CONTROLLERS
`
`
`
`Touch Controllers
`
`Oculus Touch controllers transport your hands, gestures and
`interactions into VR with intuitive accuracy.
`
`
`
`
`
`26
`26
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 17 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 17 of 21
`
`
`
`TRACKING
`
`Six Degrees of Freedom
`
`With 6DOF, the headsettracks the movement of both your
`head and body, then translates them into VR with realistic
`precision. No external sensors required.
`
`
`
`CONTROLLERS
`
`SS
`a)
`a)
`
`Redesigned Touch Controllers
`
`Quest 2 Touch controllers have been upgraded with improved
`ergonomics. Anew thumb rest adds stability when needed.
`
`
`
`
`
`
`See also OculusRift S.
`See also Oculus Rift S.
`
`27
`27
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 18 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 18 of 21
`
`
`
`Controllers
`data usedfor this process comes from three types of sensors built into the Quest andRift S hardware:
`controller position drift caused by integrating multiple IMUs.
`
`OculusRift S
`
`Headset
`
`Two Touch
`
`
`
`
`See also Powered byAI.
`See also Powered by AI.
`Academic research has been done on SLAM techniques for several decades, but the technology has only
`recently become mature enough for consumerapplications, such as driverless cars and mobile AR apps.
`Facebook previously released a version of SLAM for AR on mobile devices which uses a single camera and
`inertial measurement unit (IMU) to track a phone's position and enable world-locked content — content that's
`visually anchored to real objects in the world. Oculus Insight is the second generationofthislibrary, and it
`incorporates significantly more information from a combination of multiple IMUs and ultra-wide-angle
`cameras, as well as infrared LEDstojointly track the 6DoF position of a VR headset and controllers.
`
`The Oculus Insight system uses a custom hardwarearchitecture and advanced computervision algorithms —
`including visual-inertial mapping, place recognition, and geometry reconstruction — to establish the location
`of objects in relation to other objects within a given space. This novel algorithm stack enables a VR device to
`pinpoint its location, identify aspects of room geometry (such as floor location), and track the positions of the
`headset and controllers with respect to a 3D mapthat is generated and constantly updated byInsight. The
`
`See also Powered by Al.
`See also Powered by AI.
`The Oculus Insight system uses a custom hardware architecture and advanced computervision algorithms —
`including visual-inertial mapping, place recognition, and geometry reconstruction — to establish the location
`of objects in relation to other objects within a given space.This novel algorithm stack enables a VR device to
`pinpointits location,identify aspects of room geometry (such as floor location), and track the positions of the
`headset and controllers with respect to a 3D mapthatis generated and constantly updated by Insight. The
`data usedfor this process comesfrom three types of sensors built into the Quest and Rift S hardware:
`
`4. Linear acceleration and rotational velocity data from IMUsin the headset and controllers are integrated
`to track the orientation and position of each with low latency.
`
`2. mage data from camerasin the headset helps generate a 3D map of the room, pinpointing landmarks
`like the corners of furniture or the patterns on yourfloor. These landmarks are observed repeatedly,
`which enables Insight to compensatefor drift (a common challenge with IMUs, where eventiny
`measurement discrepancies build up overtime, resulting in inaccurate location tracking).
`
`3. Infrared LEDsin the controllers are detected by the headset cameras,letting the system bound the
`
`
`
`
`
`
`
`28
`28
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 19 of 21
`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 19 of 21
`
`
`
`See alsoid.
`See also id.
`At last year’s Oculus Connect event we shared some details about OculusInsight, the cutting-edge
`technology that powers both Quest and Rift S. Now that both of those products are available, we're providing
`a deeperlook at the Al systems and techniques that power this VR technology. Oculus Insight marks thefirst
`time that fully untethered six-degree-of-freedom (6DoF) headset and controller tracking has shipped ina
`consumer AR/VR device. Built from the ground up, the Insight stack leverages state-of-the-art computer
`
`vision (CV) systems and visual-inertial simultaneous localization and mapping, or SLAM.
`
`
`
`
`See also From the Lab.
`See also From the Lab.
`
`“We wanted to create a system that lets you move and explore a VR world just as
`naturally and easily as you would in real life,” says Kozminski.
`
`to listen to music,” says Kozminski.
`
`Kozminski joined a team whose mission was to create thefirst full-featured "inside-out"
`tracking system for a consumer VR device. The technology would have to track the full
`range of a person’s movements (known as six degrees of freedom) and be able to
`pinpoint the location of the two handheld controllers as well as the headset.
`
`Previously, VR devices relied on external sensors to track these movements. These
`cameras attach to a PC, and while they work well, they make VR less portable and more
`complicated to set up.
`
`“With inside-out tracking in the headset, VR becomes as easy as putting on headphones
`
`
`
`
`See also Powered byAl.
`See also Powered by AI.
`Headsettracking compute architecture
`MAPPER THREAD
`
`Cesare
`
`TRACKER THREAD
`
`DSP
`
`El
`
`
`sar
`Convergedpoints
`Selectseedsasbackup a Newseeds
`|
`
`auUpdateMe
`
`coo=
`
` Veet ad
`
`IMU THREAD
`
`Ea:
`
`Update& reintegrate
`
`
`
`——-=Oculus Insight processes multiple threads of data at once, in real-time — the mapperthread modifies the map, sending updated copies to the
`tracker thread, which uses camera frames to estimate posesin the mapper-provided frames, while the IMU thread uses measurements from
`the IMU's to update the latest SLAM state.
`
`
`See also From the Lab, Sensor Placementat 0:30.
`See also From the Lab, Sensor Placement at 0:30.
`
`
`
`29
`29
`
`

`

`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 20 of 21
`
`
`
`FB Sensor Placement
`Tech@Facebook @ - Follow
`
`CRTemtlid
`Poegaten
`Controller IMU
`
`on@) & 2 O
`
`
`
`
`See also Heaney.
`The driver also reveals the series model numberofthe controller'sinertial
`measurementunit (IMU)- the chip within all VR controllers which contains
`the accelerometer.
`
`Teardowns and the FCCfilings for the current Touch showedit uses TDK’s
`
`ICM-20601 IMU from late 2015.
`
`
`
`
`See also ICM-20601 Specification.
`See also ICM-20601 Specification.
`
`30
`30
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`Case 6:21-cv-00755-ADA Document 70-4 Filed 06/10/22 Page 21 of 21
`
`(1c) using the coordinate
`information and the pitch
`information to obtain
`candidate values for the
`azimuth of the object,
`
`
`
`
`
`Facebook encourages, directs, or promotes users to use the Accused Products to
`use the coordinate information and the pitch information to obtain candidate
`values for the azimuth of the object, and Facebook performs such step itself.
`For example, on information and belief, and subject to discovery which has not
`yet occurred, the coordinate information from the LED markers and pitch
`information from the Oculus Touch Controller IMU are fused at the headset to
`obtain candidate values for the azimuth of the Oculus Touch Controller (e.g.,
`using the “P2P pose solver”). The Accused Products are especially adapted to
`carry out this method, which is a material part of the claimed invention, and
`have no substantial noninfringing uses. Further, on information and belief,
`Facebook conditions a user’s use of the Accused Products, and therefore the
`user’s receipt of the benefits of the Accused Products, upon this method and
`establishes the manner or timing of that use (e.g., through its software and/or
`user instructions, which have not been provided at this stage of the litigation).
`
`To the extent this limitation is not met literally, the Accused Products also
`satisfy this limitation under the doctrine of equivalents. Any difference
`between the Accused Products and the claim element is insubstantial.
`
`See, e.g., LED Matching.
`
`31
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`