Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 1 of 13
`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 1 of 13
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`EXHIBIT LL
`EXHIBIT LL
`
`

`

`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 2 of 13
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`Gentex Corporation and Indigo Technologies, LLC (collectively, “Gentex”) presently
`contend that Facebook, Inc. and Facebook Technologies, LLC (collectively, “Facebook”)
`infringe claims 1-2, 4-5, 7-9, 11-20, 23-33, 35, 41, 45-48, 50, and 54-59 (the “Asserted Claims”)
`of U.S. Patent No. 6,757,068, 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 ’068 patent, or further investigation reveals that other products or
`services infringe the ’068 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 ’068 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 ’068 patent discussed below, except for
`claim 18 and the contentions below regarding hand tracking, which is performed by the Oculus
`Quest and Oculus Quest 2, but based on present information, is not performed by the Oculus Rift
`S. 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 ’068 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 6,757,068
`
`Claim 1
`Claim Limitation
`(1pre) A method
`comprising
`
`
`Accused Products
`Facebook encourages, directs, or promotes users to carry out the claimed
`method, and Facebook performs the claimed method, as set forth below. 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).
`
`See, e.g., Oculus Quest 2 Instructions.
`
`2
`
`

`

`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 3 of 13
`
`See also Oculus Rift S, https://www.oculus.com/rift-s/.
`
`(1a) mounting a
`sourceless
`orientation tracker on
`a user’s head, and
`
`
`
`
`
`
`Facebook encourages, directs, or promotes users to mount a sourceless
`orientation tracker (e.g., a headset including sourceless orientation tracking
`functionality in inertial measurement units, or “IMUs,” and cameras) on a
`user’s head, and Facebook performs such step itself. For example, the
`Accused Products include a headset that Facebook and/or a user mounts on
`the head and which measures, for example, the orientation of a head. The
`headset measures orientation through multiple IMUs (e.g., accelerometers
`and gyroscopes), as well as multiple cameras. The headset is “sourceless,”
`e.g., it is marketed as “without external sensors.” 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).
`
`See, e.g., Oculus Quest 2 Instructions.
`
`
`7
`
`

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`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 4 of 13
`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 4 of 13
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`
`1.1.
`To put on your headset
`
`
`
`
`
`1. Loosen the side straps and then the top strap.
`
`2. Starting from the back, put on your headset.
`
`
`
`
`See also Oculus Quest Features,
`See also Oculus Quest Features,
`https://web.archive.org/web/20200901 154027if_/https://www.oculus.com/qu
`https://web.archive.org/web/20200901154027if_/https://www.oculus.com/qu
`est/features/ (“Oculus Quest Features”).
`
`est/features/ (“Oculus Quest Features’). Make your move.
`
`
`
`See also Tech@facebook, From the Lab to the living room: The story behind
`See also Tech@facebook, From the Lab to the living room: The story behind
`Facebook’s Oculus Insight technology and a new era ofconsumer VR (Aug.
`Facebook’s Oculus Insight technology and a new era of consumer VR (Aug.
`
`
`
`8
`
`

`

`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 5 of 13
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`22, 2019), https://tech.fb.com/the-story-behind-oculus-insight-technology/,
`Sensor Placement at 0:15 (“From the Lab”).
`
`
`
`
`
`
`
`
`See also Oculus Rift S, https://www.oculus.com/rift-s/?locale=en_US.
`
`
`9
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`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 6 of 13
`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 6 of 13
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`
`
`PC-Powered VR
`Gamin
`ir
`best
`VR game
`
`=a $399USD"
`
`View PC requirements
`
`pti
`
`rs
`
`ani
`
`Improved Optics o
`controller position drift caused by integrating multiple IMUs.
`
`Ergonomic Design
`
`
`@)thehalo s
`
`Oculus Touch Controll
`cul
`‘ouch
`Controllers
`
`Yourttuitive,
`
`slashes,realistic precisiorthrows and grabs
`
`appear in VRwith
`
`
`
`em
`@
`
`
`
`
`
`See also Oculus Blog, Powered by AI (Aug. 22, 2019),
`See also Oculus Blog, Powered by AI (Aug. 22, 2019),
`https://ai.facebook.com/blog/powered-by-ai-oculus-insight/ (“Powered by
`https://ai.facebook.com/blog/powered-by-ai-oculus-insight/ (“Powered by
`AT”).
`AI”).
`headset and controllers with respect to a 3D map that is generated and constantly updated by Insight. The
`data used for this process comes from three types of sensors built into the Quest and Rift S hardware:
`
`4. Linear acceleration and rotational velocity data from |MUs in the headset and controllers are integrated
`to track the orientation and position of each with low latency.
`
`2. Image data from cameras in the headset helps generate a 3D map of the room, pinpointing landmarks
`like the corners of furniture or the patterns on your floor. These landmarks are observed repeatedly,
`which enables Insight to compensatefordrift (a common challenge with IMUs, where eventiny
`measurementdiscrepancies build up over time, resulting in inaccurate location tracking).
`
`3. Infrared LEDsin the controllers are detected by the headset cameras,letting the system bound the
`
`
`
`
`See alsoid.
`See also id.
`At last year’s Oculus Connect event we shared some details about Oculus Insight, the cutting-edge
`technology that powers both Quest and Rift S. Now that both of thase productsare available, we're providing
`a deeper look at the Al systems and techniques that power this VR technology. Oculus Insight marksthefirst
`time that fully untethered six-degree-of-freedom (GDoF) headset and controller tracking has shipped in a
`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 Oculus for Developers, Oculus Device Specifications,
`See also Oculus for Developers, Oculus Device Specifications,
`https://developer.oculus.com/learn/oculus-device-specs/ (“Oculus for
`https://developer.oculus.com/learn/oculus-device-specs/ (“Oculus for
`Developers’).
`Developers”).
`
`10
`10
`
`

`

`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 7 of 13
`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 7 of 13
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`
`
`Oculus Quest 2
`
`e« Panel Type: Single Fast-Switch LCD, 1832*1920px per eye
`
`e« Supported Refresh Rate: 72Hz (default), can be configured to 60Hz in some cases
`
`e¢ Default SDK Color Space: Rec.2020 gamut, 2.2 gamma, D65 white point
`
`* CIE 1931 xy color-primary values:
`
`e Red: (0.708, 0.292)
`
`e Green: (0.17, 0.797)
`
`* Blue: (0.131, 0.046)
`
`e White: (0.3127, 0.3290)
`
`e USB Connector: 1x USB-C
`
`e Tracking: Inside out, (DOF
`
`
`
`
`See alsoid.
`See also id.
`3DOF vs 6DOF
`
`handsto interact with VR environments.
`
`The Oculus Go headset comes wiih 13 Degree-ofFreedom (DOF) controller to track controller orientations. However, the
`Oculus Go headsetwill not track controller positions in space. The Oculus Rift, Rift S, and Quest headsets are equipped with
`2 6DOFcontrollers that support both orientation and positional tracking. The 6DOF capabilities allow you to integrate virtual
`
`
`
`
`See also Ben Lang, Quest Teardown Shows How Oculus Crammed Cooling
`See also Ben Lang, Quest Teardown Shows How Oculus Crammed Cooling
`& Cameras Inside (July 17, 2019), https://www.roadtovr.com/oculus-quest-
`
`teardown-disassembly/ (“Lang’
`teardown-disassembly/ (“Lang”).
`
`& Cameras Inside (July 17, Om https://www.roadtovr.com/oculus-quest-
`
`11
`11
`
`

`

`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 8 of 13
`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 8 of 13
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`
`
`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 headsetand the controllers; their views are also merged together to allow a
`
`pass-through vision mode on the headsetwhich is used to trace the boundary of your
`
`
`
`
`See also Facebook AI, Powered by AI: Oculus Insight (Aug. 22, 2019),
`See also Facebook AI, Powered by AI: Oculus Insight (Aug. 22, 2019),
`https://ai.facebook.com/blog/powered-by-ai-oculus-insight/.
`https://ai.facebook.com/blog/powered-by-ai-oculus-insight/.
`To unlock the full potential of virtual reality (VR) and augmented reality (AR) experiences, the technology
`needs to work anywhere, adapting to the spaces where people live and how they move within those real-
`
`world environments. When we developed Oculus Quest, thefirst all-in-one, completely wire-free VR gaming
`system, we knew we needed positional tracking that wasprecise, accurate, and available in real time — within
`the confines of a standalone headset, meaning it had to be compact and energyefficient.
`
`
`
`
`See also Powered byAl.
`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 measurementunit (IMU) to track a phone's position and enable world-locked content — content that’s
`visually anchored to real objects in the world. OculusInsight is the second generationof this library, and it
`incorporatessignificantly more information from a combination of multiple IMUs and ultra-wide-angle
`cameras, as well as infrared LEDsto jointly track the 6DoF position of a VR headset and controllers.
`
`The Oculus Insight system uses a custom hardware architecture and advanced computer vision 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 asfloor location), and track the positions of the
`headsetand controllers with respect to a 3D map that is generated and constantly updated byInsight. The
`data used for this process comes from three types of sensors built into the Quest and Rift S hardware:
`
`See also Powered byAl.
`See also Powered by AI.
`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 thatfully untethered six-degree-of-freedom (6DoF) headset and controller tracking has shippedin a
`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.
`
`
`
`
`
`
`
`12
`12
`
`

`

`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 9 of 13
`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 9 of 13
`
`
`
`See also Tech@facebook, From the lab to the living room: The story behind
`See also Tech@facebook, From the lab to the living room: The story behind
`Facebook's Oculus Insight technology and a new era ofconsumer VR (Aug.
`Facebook’s Oculus Insight technology and a new era of consumer VR (Aug.
`22, 2019), https://tech.fb.com/the-story-behind-oculus-insight-technology/.
`22, 2019), https://tech.fb.com/the-story-behind-oculus-insight-technology/.
`“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 wasto 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
`to listen to music,” says Kozminski.
`
`
`
`
`See also From the Lab.
`See also From the Lab.
`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 order tofix the position of an object within a
`constantly updated digital map. SLAM has been usedin 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 unprecedentedlevel of precision and efficiency,
`and that meant adapting the latest research on tracking and computer vision.
`
`"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 camefrom Zurich Eye — a joint program from the prestigious ETH
`
`University and University of Zurich that researched self-navigating systems.
`
`
`
`
`See also From the Lab.
`See also From the Lab.
`There are other complications, too. The infrared LEDs in the two hand
`controllers drastically change appearance when they move closer 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 measurementunits (IMUs) located in the headset
`and controllers. The system must process all of these data pointsin real time
`and, in the case of Quest, on a mobile chipset.
`
`
`
`
`See also From the Lab.
`See also From the Lab.
`
`13
`13
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`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 10 of 13
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`
`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.
`
`
`
`
`See also Oculus Quest 2, https://www.oculus.com/quest-2/.
`See also Oculus Quest 2, https://www.oculus.com/quest-2/.
`(—}
`
`Introducing Oculus
`
`Wireless
`All-in-One VR
`
`
`
`
`See also Compare Headsets,
`See also Compare Headsets,
`https://www.oculus.com/compare/?products=quest%2Cquest-2.
`
`https://www.oculus.com/compare/?products=quest%2Cquest-2.
`
`Oculus Quest
`All-In-One VR Gaming
`
`
`
`14
`14
`
`

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`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 11 of 13
`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 11 of 13
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`
`
`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.
`
`
`
`Oculus Quest 2
`AdvancedAll-In-One VR Gaming
`
`Starting At $299 USD’
`
`cae
`
`
`
`15
`15
`
`

`

`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 12 of 13
`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 12 of 13
`
`
`
`TRACKING
`
`Six Degrees of Freedom
`
`With 6DOF, the headset tracks the movement of both your
`head and body, then translates them into VR with realistic
`precision. No external sensors required.
`
`
`
`
`See also David Heaney, Oculus Firmware Reveals New Touch Controllers,
`See also David Heaney, Oculus Firmware Reveals New Touch Controllers,
`Referencing Improvements to Tracking, Finger Sensing, Haptics (Apr. 16,
`Referencing Improvements to Tracking, Finger Sensing, Haptics (Apr. 16,
`2020), https://uploadvr.com/oculus-jedi-controller-driver-found/ (“Heaney”).
`2020), https://uploadvr.com/oculus-jedi-controller-driver-found/ (“Heaney”).
`
`optically tracked in the same wayas the current Touch- cameras on the
`headsetfollow the movementof the LED constellation, and this is fused with
`the accelerometerreadings to achieve sub-mm precision.
`
`Me)roe dee Erledire] A function for infrared LED calibration exists, suggesting this controlleris
`
`
`
`
`See also Heaney.
`See also Heaney.
`
`16
`16
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`

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`Case 6:21-cv-00755-ADA Document 70-5 Filed 06/10/22 Page 13 of 13
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`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, https://invensense.tdk.com/wp-
`See also ICM-20601 specification, https://invensense.tdk.com/wp-
`content/uploads/2015/12/DS-000191-ICM-20601-v1.0.pdf.
`content/uploads/2015/12/DS-000191-ICM-20601-v1.0.pdf.
`FEATURES
`
`ROHS and Green compliant
`
`3-Axis Gyroscope with Programmable FSR of
`+500dps, t100dps, +2000dps and +4000dps
`3-Axis Accelerometer with Programmable FSR of
`+4q, +8g, +16g, and +32g
`User-programmable interrupts
`Wake-on-motion interrupt for low poweroperation
`of applications processor
`512 byte FIFO buffer enables the applications
`processorto read the data in bursts
`On-Chip 16-bit ADCs and Programmable Filters
`Host interface: 8 MHz SPI or 400k Hz Fast Mode I7C
`
`
`
`
`
`Digital-output temperature sensor
`VDD operating range of 1.71 to 3.45V
`MEMS structure hermetically sealed and bonded at
`wafer level
`
`
`
`17
`17
`
`