Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 1 of 18
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`EXHIBIT D: INFRINGEMENT CLAIM CHART FOR
`APPLE ACCUSED PRODUCTS – U.S. PATENT NO. 8,792,454
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`No part of this exemplary chart construes, or is intended to construe, the specification, file history, or claims of the ’454 patent.
`Moreover, this exemplary chart does not limit, and is not intended to limit, Ericsson’s infringement positions or contentions.
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`1. A method for a mobile
`Apple iPhone 13 includes Wi-Fi Assist functionality which enables iPhone 13 to roam between Wi-Fi
`terminal to roam between a
`and cellular network. “Mobile terminal” corresponds to the Apple iPhone 13. “First network”
`first network and a second
`corresponds to the Wi-Fi network and “second network” corresponds to the cellular network including
`network comprising the
`5G NR/LTE/UMTS, etc.
`steps of:
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`Apple iPhone 13 Tech Specs1 at 1:
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`Apple iPhone 13 Tech Specs at 5:
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`1 https://www.apple.com/iphone-13/specs/
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`EXHIBIT D: INFRINGEMENT CLAIM CHART FOR
`APPLE ACCUSED PRODUCTS – U.S. PATENT NO. 8,792,454
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`No part of this exemplary chart construes, or is intended to construe, the specification, file history, or claims of the ’454 patent.
`Moreover, this exemplary chart does not limit, and is not intended to limit, Ericsson’s infringement positions or contentions.
`
`
`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`1. A method for a mobile
`Apple iPhone 13 includes Wi-Fi Assist functionality which enables iPhone 13 to roam between Wi-Fi
`terminal to roam between a
`and cellular network. “Mobile terminal” corresponds to the Apple iPhone 13. “First network”
`first network and a second
`corresponds to the Wi-Fi network and “second network” corresponds to the cellular network including
`network comprising the
`5G NR/LTE/UMTS, etc.
`steps of:
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`Apple iPhone 13 Tech Specs1 at 1:
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`Apple iPhone 13 Tech Specs at 5:
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`1 https://www.apple.com/iphone-13/specs/
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 2 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 3 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`About Wi-Fi Assist2 at 1:
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`About Wi-Fi Assist at 1:
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`2 https://support.apple.com/en-us/HT205296
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 4 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`Screenshots from an iPhone 13:
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 5 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`establishing a first network
`Apple iPhone 13 establishes a first network connection between Wi-Fi driver in iPhone 13, and the
`connection between a first
`Wi-Fi network. The “first network connection” corresponds to a Wi-Fi connection to a Wi-Fi Access
`network driver of said
`Point (AP). The “first network driver” corresponds to the Wi-Fi driver of the Apple iPhone 13. The
`mobile terminal and said
`“internal network” corresponds to a wireless local area network, WLAN. Network.framework API in
`first network, wherein the
`iPhone 13 enables establishment of network connection when NWConnection is called. The system
`first network comprises an
`implements Smart Connection Establishment, which evaluates the available networks, and prefers Wi-
`internal network;
`Fi over cellular, if both networks are available. After connection establishment, the packets are sent
`and received over the Wi-Fi interface via the Wi-Fi driver.
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`WWDC 2018 Introducing Network.framework: A modern alternative to Sockets3, video at 18:02:
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`3 https://developer.apple.com/videos/play/wwdc2018/715
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`5
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 6 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`WWDC 2018 Introducing Network.framework: A modern alternative to Sockets, Audio Transcript
`(annotated):
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 7 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
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`WWDC 2018 Introducing Network.framework: A modern alternative to Sockets, video at 47:31:
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 8 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`WWDC 2018 Introducing Network.framework: A modern alternative to Sockets, Audio Transcript
`(annotated):
`
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`detecting that a signal
`strength for the first
`network connection is
`below a threshold;
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`The “signal strength for the first network connection” corresponds to the signal strength of the Wi-Fi
`connection. The iPhone 13 detects whether a signal strength for the Wi-Fi connection is below a
`threshold because Wi-Fi Assist receives fine-grained signal quality information from the lower layers,
`including Wi-Fi and it also obtains information about how flows are making progress from the higher
`layer frameworks, including Network.framework.
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`About Wi-Fi Assist at 1:
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 9 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
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`AT&T Device Support > Apple iPhone 13 > View & Manage Data4 at 3:
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`WWDC2019 Advances in Networking, Part 15, Audio Transcript (annotated):
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`4 https://www.att.com/device-support/article/wireless/KM1358540/Apple/iPhone13
`5 https://developer.apple.com/videos/play/wwdc2019/712
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 10 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 11 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`WWDC2019 Advances in Networking, Part 1, video at 48:48:
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`WWDC2017 Advances in Networking, Part 16, Audio Transcript (annotated):
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`6 https://developer.apple.com/videos/play/wwdc2017/707/
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 12 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`What is Wi-Fi Assist and how to use it7 at 2:
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`The Apple iPhone 13 establishes, based on the signal quality (including signal strength) of the Wi-Fi
`network being below a threshold, a connection between the cellular driver of the mobile terminal and
`the cellular network. “Second network connection” corresponds to the cellular data connection to the
`mobile network. The “second network…compris[ing] an external network” corresponds to the cellular
`data network.
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`About Wi-Fi Assist at 1 (annotated):
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`establishing, based on the
`detected signal strength
`being below the threshold, a
`second network connection
`between second network
`driver of said mobile
`terminal and said second
`network, wherein the
`second network comprises
`an external network; and
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`AT&T Device Support > Apple iPhone 13 > View & Manage Data at 3 (annotated):
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`7 https://www.idownloadblog.com/2015/09/16/how-to-wi-fi-assist-ios-9/
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 13 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
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`WWDC2019 Advances in Networking, Part 1, audio transcript (annotated):
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 14 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`WWDC 2018 Introducing Network.framework: A modern alternative to Sockets, Audio Transcript
`(annotated):
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 15 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 16 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`WWDC 2018 Introducing Network.framework: A modern alternative to Sockets, video at 53:48:
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`What is Wi-Fi Assist and how to use it at 2:
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 17 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
`transitioning said
`Apple iPhone 13 transitions communication from Wi-Fi network to cellular network, upon detection of
`communications from said
`the Wi-Fi network strength being below a threshold.
`first network to said second
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`About Wi-Fi Assist at 1 (annotated):
`network.
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`AT&T Device Support > Apple iPhone 13 > View & Manage Data at 3 (annotated):
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`WWDC2019 Advances in Networking, Part 1, audio transcript (annotated):
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`Case 6:22-cv-00061-ADA Document 1-5 Filed 01/17/22 Page 18 of 18
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`U.S. Patent No. 8,792,454 Apple iPhone 13 and similar products (“Accused Products”)
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