Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 1 of 284
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`Plaintiff,
`
`OZMO LICENSING LLC,
`
`
`
`v.
`
`DELL TECHNOLOGIES INC. and
`DELL INC.,
`
`
`
`Defendants.
`
`Civil Action No. 6:22-cv-642
`
`
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff, Ozmo Licensing LLC (“Ozmo Licensing”), as and for its Complaint against
`
`defendants, Dell Technologies Inc. and Dell Inc. (together, “Dell” or “Defendants”), hereby alleges
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`as follows:
`
`THE PARTIES
`
`1.
`
`Ozmo Licensing is a Texas limited liability company having its principal place of
`
`business located at 1000 Heritage Center Circle, Suite 508, Round Rock, Texas 78664.
`
`2.
`
`Defendant Dell Technologies Inc. is a Delaware corporation with its principal place
`
`of business at One Dell Way, Round Rock, Texas 78682.
`
`3.
`
`Defendant Dell Inc. is a Delaware corporation with its principal place of business
`
`at One Dell Way, Round Rock, Texas 78682. Dell Inc. is a wholly-owned subsidiary of Dell
`
`Technologies Inc.
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`JURISDICTION AND VENUE
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`4.
`
`This is an action for patent infringement brought under the Patent Laws of the
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`United States, 35 U.S.C. §§ 271, et seq. This Court has jurisdiction over the subject matter of this
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`action under 28 U.S.C. §§ 1331 and 1338(a).
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`1
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`5.
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`This Court has general personal jurisdiction over Dell because Dell has a principal
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`place of business in Round Rock, Texas. This Court has specific personal jurisdiction over Dell
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`because: (1) Dell has purposely availed itself of the privileges of conducting business activities in
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`this judicial district; (2) Dell has committed acts of infringement in this judicial district; and (3)
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`exercising general personal jurisdiction over Dell would be fair and reasonable given Dell’s
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`contacts with, and business activities within, this judicial district and elsewhere in Texas.
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`Accordingly, this Court’s exercise of jurisdiction over Dell would not offend traditional notions of
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`fair play and substantial justice.
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`6.
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`Dell has committed acts of infringement in this District, directly and/or through
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`intermediaries, by, among other things, making, using, offering to sell, selling, and/or importing
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`products and/or services that infringe the Asserted Patents, as alleged herein.
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`7.
`
`Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391 and 1400(b)
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`because Dell has a regular and established place of business in Round Rock, Texas and has
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`committed acts of infringement within this judicial district and elsewhere in Texas. Dell is also
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`registered to do business in Texas.
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`FACTUAL BACKGROUND
`
`The Patents-in-Suit
`
`8.
`
`On February 16, 2016, the United States Patent and Trademark Office (“PTO”)
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`issued United States Patent No. 9,264,991 (“the ’991 patent”), titled APPARATUS AND
`
`METHOD FOR
`
`INTEGRATING SHORT-RANGE WIRELESS PERSONAL AREA
`
`NETWORKS FOR A WIRELESS LOCAL AREA NETWORK INFRASTRUCTURE. The ’991
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`patent is valid and enforceable. A copy of the ’991 patent is attached as Exhibit A.
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`2
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`9.
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`Ozmo Licensing is the owner and assignee of all rights, title and interest in and to
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`the ’991 patent and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’991 patent.
`
`10.
`
`On December 22, 2020, the PTO issued United States Patent No. 10,873,906 (“the
`
`’906 patent”), titled APPARATUS AND METHOD FOR INTEGRATING SHORT-RANGE
`
`WIRELESS PERSONAL AREA NETWORKS FOR A WIRELESS LOCAL AREA NETWORK
`
`INFRASTRUCTURE. The ’906 patent is valid and enforceable. A copy of the ’906 patent is
`
`attached as Exhibit B.
`
`11.
`
`Ozmo Licensing is the owner and assignee of all rights, title and interest in and to
`
`the ’906 patent and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’906 patent.
`
`12.
`
`On December 3, 2013, the PTO issued United States Patent No. 8,599,814 (“the
`
`’814 patent”), titled APPARATUS AND METHOD FOR INTEGRATING SHORT-RANGE
`
`WIRELESS PERSONAL AREA NETWORKS FOR A WIRELESS LOCAL AREA NETWORK
`
`INFRASTRUCTURE. The ’814 patent is valid and enforceable. A copy of the ’814 patent is
`
`attached as Exhibit C.
`
`13.
`
`Ozmo Licensing is the owner and assignee of all rights, title and interest in and to
`
`the ’814 patent and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’814 patent.
`
`14.
`
`On May 18, 2021, the PTO issued United States Patent No. 11,012,934 (“the ’934
`
`patent”), titled APPARATUS AND METHOD FOR INTEGRATING SHORT-RANGE
`
`WIRELESS PERSONAL AREA NETWORKS FOR A WIRELESS LOCAL AREA NETWORK
`
`3
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`INFRASTRUCTURE. The ’934 patent is valid and enforceable. A copy of the ’934 patent is
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`attached as Exhibit D.
`
`15.
`
`Ozmo Licensing is the owner and assignee of all rights, title and interest in and to
`
`the ’934 patent and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’934 patent.
`
`16.
`
`On September 14, 2021, the PTO issued United States Patent No. 11,122,504 (“the
`
`’504 patent”), titled APPARATUS AND METHOD FOR INTEGRATING SHORT-RANGE
`
`WIRELESS PERSONAL AREA NETWORKS FOR A WIRELESS LOCAL AREA NETWORK
`
`INFRASTRUCTURE. The ’504 patent is valid and enforceable. A copy of the ’504 patent is
`
`attached as Exhibit E.
`
`17.
`
`Ozmo Licensing is the owner and assignee of all rights, title and interest in and to
`
`the ’504 patent and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’504 patent.
`
`18.
`
`On February 15, 2022 the PTO issued United States Patent No. 11,252,659 (“the
`
`’659 patent”), titled APPARATUS AND METHOD FOR INTEGRATING SHORT-RANGE
`
`WIRELESS PERSONAL AREA NETWORKS FOR A WIRELESS LOCAL AREA NETWORK
`
`INFRASTRUCTURE. The ’659 patent is valid and enforceable. A copy of the ’659 patent is
`
`attached as Exhibit F.
`
`19.
`
`Ozmo Licensing is the owner and assignee of all rights, title and interest in and to
`
`the ’659 patent and holds all substantial rights therein, including the right to grant licenses, to
`
`exclude others, and to enforce and recover past damages for infringement of the ’659 patent.
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`4
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`The Inventors, Ozmo Devices, and Ozmo Licensing
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`20.
`
`The inventions of the ’991 patent, the ’906 patent, the ’814 patent, the ’934 patent,
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`the ’504 patent, and the ’659 patent (collectively, “the Ozmo Devices patents” or “the patents-in-
`
`suit”) were conceived at Ozmo Devices. Founded in 2004 by spouses Katelijn Vleugels and Roel
`
`Peeters, Ozmo Devices was a leading provider of low-power Wi-Fi Personal Area Network
`
`(“WPAN”) products that may be deployed in proximity to Wi-Fi Local Area Networks (“WLAN”)
`
`products without severe interference arising between the two.
`
`21.
`
`Named co-inventors of the patents-in-suit, Vleugels, with a Ph.D. in electrical
`
`engineering from Stanford University, and Peeters, with an MBA from The Wharton School, are
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`responsible for inventing a solution to integrate WPAN and WLAN functionalities in a way that
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`delivers cost savings to manufacturers, unprecedented performance to users, and solves the
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`interoperability problems that plagued existing methods of attempted WPAN-WLAN integrations.
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`These patented inventions gave rise to what has since been promulgated by the Wi-Fi Alliance as
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`the Wi-Fi Peer-to-Peer Technical Specification (“Wi-Fi Direct Standard”), which specification
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`Vleugels and Peeters helped draft. The Wi-Fi Alliance is headquartered in Austin, Texas.
`
`Vleugels and Peeters live in the greater Austin area of Texas.
`
`22.
`
`The Ozmo Devices patents relate to an apparatus for a WPAN that is seamlessly
`
`integrated with a WLAN, and methods for using such, to enable a WPAN device that can connect
`
`with other WPAN devices without losing connectivity to a WLAN, thereby enabling extended
`
`communication with WPAN devices from anywhere within the range of a WLAN infrastructure.
`
`23.
`
`Ozmo Licensing was founded in 2019. A significant aspect of Ozmo Licensing’s
`
`business is widely and reasonably licensing its current patent portfolio, including the Ozmo
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 6 of 284
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`Devices patents, with the support of the inventors. Ozmo Licensing is pursuing related patent
`
`applications with the support of inventors Katelijn Vleugels and Roel Peeters.
`
`Wireless Communication Technology
`
`24.
`
`Significant accomplishments of the Internet era included standardization of various
`
`forms of wireless connectivity, including WLANs and WPANs.
`
`25.
`
`An example of a WLAN is an 802.11x (x = a, b, g, n, etc.) network, whose operation
`
`is specified in a handful of versions of the Institute of Electrical and Electronics Engineers (IEEE)
`
`802.11x standard, including the IEEE Std. 802.11 (“IEEE 802.11-2012,” “802.11x,” or “IEEE
`
`802.11x”). Since its adoption, the 802.11x standard, commonly known as “Wi-Fi,” has been
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`widely deployed for wireless connectivity in a variety of settings, including in homes, offices, and
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`public establishments. 802.11x WLANs generally support two different configurations:
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`infrastructure mode and ad-hoc mode.
`
`26.
`
`An 802.11x WLAN operating in infrastructure mode requires at least one access
`
`point (“AP”) to provide connections between mobile stations (STAs), or to provide connections
`
`between an STA and other nodes on the Internet or other WLANs. 802.11x-compliant STAs, such
`
`as laptop computers, desktop computers, tablet computers, mobile phones, printers, smart
`
`televisions, and the like, are capable of joining 802.11x WLAN to participate in Wi-Fi
`
`communications with each other, with all such communications being routed through at least one
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`AP.
`
`27.
`
`Devices in a WPAN communicate directly with each other, in a peer-to-peer (also
`
`known as “P2P”) manner, without the need for an AP to provide connections between those WPAN
`
`devices. The most common example of a WPAN is a Bluetooth connection/network formed
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`6
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`between two Bluetooth-equipped devices. Both the range and the data transmission rates of a
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`Bluetooth WPAN are far smaller than those of an 802.11x WLAN.
`
`28.
`
`Bluetooth WPAN devices may operate in the same 2.4-GHz frequency band in
`
`which WLAN devices frequently operate. The co-existence of WPAN and WLAN communication
`
`protocols in a single frequency band often results in severe interference due to their varying
`
`methods of accessing the wireless medium and a lack of synchronization between WPAN and
`
`WLAN devices when accessing the wireless medium. Furthermore, a device that supports both
`
`Bluetooth WPAN and 802.11 WLAN often requires different hardware and software to support
`
`each standard, including different transceivers, and drivers for the transceivers and antennas, which
`
`can be functionally duplicative and thus wasteful of resources. While the disharmonious
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`coexistence of Bluetooth WPANs and 802.11x WLANs had long been tolerated, there remained a
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`need for a solution that could more seamlessly integrate WPAN and WLAN communication
`
`protocols.
`
`29.
`
`The “Background of the Invention” sections of the Ozmo Devices patents each
`
`describe some of the problems pertaining to then-contemplated integrations of WLANs and
`
`WPANs. Vleugels and Peeters addressed these problems with their inventions. For example, the
`
`Ozmo Devices patents describe the lack of synchronization that occurred with then-existing
`
`integrations of WLANs and WPANs, and resulting interference from such integrations. See, e.g.,
`
`Ex. A at 2:29-36.1
`
`30.
`
`The Ozmo Devices patents note that the prior art efforts to address these problems
`
`were insufficient. For example, one option was to simply implement WLAN protocols in WPAN
`
`
`1 The relevant portions of the specification of the patents-in-suit are identical, and so citations
`are just to the ’991 patent.
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`7
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 8 of 284
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`devices. Id. at 2:37-3:6. This led to power dissipation and/or low transmission rate problems, and
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`introduces undesirable amounts of latency in communications involving the WPAN devices.
`
`31.
`
`The Ozmo Devices patents describe noise, linearity and/or overhead protocol
`
`problems with integrating then-existing WPAN and WLAN networks. Id. at 3:6-19. For example,
`
`the patents point out that though WLANs typically operate at relatively high-speed data rates
`
`compared to WPANs, they cannot be operated at those faster rates when integrated with WPANs.
`
`This is because communication between an AP and its associated STAs occurs at the slowest
`
`common data rate supported by any of those associated STAs, and because a WLAN-associated
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`STA that is also capable of associating with a Bluetooth WPAN will typically support low-speed
`
`data rates that are typical of Bluetooth devices.
`
`32.
`
`Also, although the 802.11x standard specifies power-save modes that allow forms
`
`of power savings, there was still a need for other power save modes that were better optimized to
`
`meet the power-saving needs of WPAN devices operating over direct P2P connections.
`
`33.
`
`There was, thus, a recognized need for seamless integration of WPAN into WLAN
`
`infrastructure without the aforementioned problems one would encounter by then existing
`
`integrations such as those featuring Bluetooth WPAN devices operating inside an 802.11x WLAN
`
`network.
`
`34.
`
`35.
`
`COUNT I
`(Dell’s Infringement of U.S. Patent No. 9,264,991)
`
`Paragraphs 1-33 are incorporated by reference as if fully set forth herein.
`
`The invention of the ’991 patent represented a technical solution to an unsolved
`
`technological problem. The written description of the ’991 patent describes in technical detail
`
`each of the limitations of the claims, allowing a person of ordinary skill in the art to understand
`
`what the limitations cover and how the combination of claim elements differed markedly from and
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`8
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 9 of 284
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`improved upon what may have been considered conventional or generic. For example, the
`
`specification and incorporated references detail the inventors’ novel approach to seamlessly
`
`integrating a WPAN into a WLAN infrastructure.
`
`36.
`
`The elements claimed by the ’991 patent, taken alone or in combination, were not
`
`well-understood, routine or conventional to one of ordinary skill in the art at the time of the
`
`invention. Rather, the ’991 patent claims and teaches, inter alia, an improved network-enabled
`
`hub to facilitate communications between WLAN and WPAN wireless devices. The invention
`
`improved upon existing wireless communications, which were unable to integrate a WPAN into a
`
`WLAN infrastructure without suffering from one or more of the aforementioned problems, by
`
`allowing the network-enabled hub to initiate and maintain connections with nodes of an external
`
`wireless network via a first network connection using a first network WLAN protocol and, a
`
`second network connection using a second network WPAN protocol that is an overlay protocol
`
`with respect to the WLAN protocol, and that is partially consistent with respect to the WLAN
`
`protocol.
`
`37.
`
`Compared to the prior art, the claimed apparatus for integrating a WPAN into a
`
`WLAN is also more cost effective, since communications using the second network WPAN
`
`protocol impinge on at least some of the antennae used for communications using the first network
`
`WLAN protocol.
`
`38.
`
`Compared to the prior art, the claimed apparatus for integrating a WPAN into a
`
`WLAN allows the two to operate in the same frequency spectrum without causing excessive
`
`interference with each other.
`
`39.
`
`Compared to the prior art, the claimed apparatus for integrating a WPAN into a
`
`WLAN is also more energy efficient, which can extend the battery life of WPAN devices that are
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 10 of 284
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`battery powered or otherwise enable power-hungry WPAN devices to enter power-save modes
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`more readily.
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`40.
`
`Compared to the prior art, the claimed apparatus for integrating a WPAN into a
`
`WLAN, also enables lower latency communication involving WPAN devices, which enables a
`
`device serving as a hub between a WPAN and WLAN to more effectively forward video streams
`
`between the two.
`
`41.
`
`Participants in the communications industry chose to incorporate a subset of the
`
`claimed apparatus into the Wi-Fi Direct Standard to enjoy at least some of their aforementioned
`
`advantages.
`
`42.
`
`Dell has infringed, and continues to infringe, the ’991 patent by making, importing,
`
`using, offering for sale and selling in the United States numerous wireless devices, including laptop
`
`computers, desktop computers, tablets, and monitors, that implement the Wi-Fi Direct protocol
`
`(i.e., the “Accused Products”). A subset of these Accused Products comprise network-enabled
`
`hubs that can receive, for example, video from an IEEE 802.11x AP and forward such video to a
`
`Wi-Fi STA device using the Wi-Fi Direct protocol (i.e., the “Hub Accused Products”).
`
`43.
`
`Examples of the Hub Accused Products are Dell’s laptop computers (including, but
`
`not limited to, XPS Laptops, Inspiron Laptops, Alienware Gaming Laptops, Vostro Laptops, and
`
`Latitude Laptops); desktop computers (including, but not limited to, XPS Desktops, Inspiron
`
`Desktops, Alienware Gaming Desktops, OptiPlex Desktops, Vostro Desktops, and New Precision
`
`Workstations); and tablets (including, but not limited to, Latitude 2-in-1 devices and Latitude
`
`Rugged Extreme tablets), and all other Dell products that include Wi-Fi Direct circuitry and
`
`drivers.
`
`44.
`
`Claim 1 of the ’991 patent is reproduced below:
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`10
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 11 of 284
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`A network-enabled hub, usable for facilitating data communications
`1.
`between two or more wireless devices that are configured to communicate
`indirectly with each other via the network-enabled hub, comprising:
`
`an interface to a wireless radio circuit that can send and receive data
`wirelessly, providing
`the hub with bi-directional wireless data
`communication capability;
`
`a processor configured to:
`
`process data received via the wireless radio circuit;
`
`generate data to be transmitted by the wireless radio circuit;
`
`initiate and maintain network connections with nodes of a
`wireless network external to the network-enabled hub, maintaining
`at least a first network connection using a first network protocol and
`a second network connection using a second network protocol, that
`can be maintained, at times, simultaneously with each other,
`wherein the second network protocol is an overlay protocol with
`respect to the first network protocol in that communications using
`the second network protocol are partially consistent with the first
`network protocol and wherein at least some of the communications
`using the second network protocol impinge on at least some
`antennae used for communications using the first network protocol;
`and
`
`implement data forwarding logic, implemented in a network-
`enabled hub using hardware and/or software, that forwards data
`between an originating node and a destination node, wherein the
`originating node is a node in one of the first and second networks
`and the destination node is a node in the other of the first and second
`networks.
`
`45.
`
`The Hub Accused Products that infringe the ’991 patent include, inter alia, a
`
`network-enabled hub, usable for facilitating data communications between two or more wireless
`
`devices that are configured to communicate indirectly with each other via the network-enabled
`
`hub. For example, the Dell XPS 13 9310 Laptop (“XPS 13 Laptop”) is a Hub Accused Product
`
`comprising a network-enabled hub that implements the Wi-Fi and Wi-Fi Direct standards. It also
`
`supports applications such as Miracast, which is a standard that allows a user to “mirror” a video
`
`image being displayed at one STA onto the display of another STA, by having it communicated
`
`over a Wi-Fi Direct connection between the two STAs. The XPS 13 Laptop infringes the ’991
`
`11
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 12 of 284
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`patent because it comprises Wi-Fi and Wi-Fi Direct circuitry and drivers, and applications, such
`
`as Miracast, that enable the XPS 13 Laptop to act as a network-enabled hub that concurrently
`
`receives data from a node in a WLAN over an 802.11x connection (e.g., streamed video), and
`
`forwards that data to a node in a WPAN over a Wi-Fi Direct connection:
`
`
`Source: https://www.dell.com/en-us/shop/laptops/13-new/spd/xps-13-9310-laptop#tech-specs-
`anchor
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Source: https://dl.dell.com/topicspdf/xps-13-9310-laptop_reference-guide_en-us.pdf
`
`12
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 13 of 284
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`Source: https://www.dell.com/support/kbdoc/en-us/000155875/how-to-connect-a-computer-
`to-high-definition-television-hdtv-kb-article-347778
`
`
`
`
`
`Source: https://www.wi-fi.org/discover-wi-fi/miracast
`
`
`
`
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`13
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 14 of 284
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`Source: Wi-Fi Direct Standard, v. 1.7, Section 2.3, Fig. 4
`
`
`
`
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`14
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 15 of 284
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 16 of 284
`Case 6:22-cv-00642-ADA Document1 Filed 06/21/22 Page 16 of 284
`
`a Meas video, we show you how to connect
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`Connectwill open indicating that your Windows10 Dell PC supports Miracast,
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`Select Connect from the group oftiles.
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 17 of 284
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`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 18 of 284
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`Source: https://www.youtube.com/watch?v=kXBwdWp7sFM (“How to Connect a Wireless
`Monitor DELL (Official Dell Tech Support)”
`
`
`
`46.
`
`The XPS 13 Laptop includes an interface to a wireless radio circuit that can send
`
`
`
`and receive data wirelessly, providing the hub with bi-directional wireless data communication
`
`capability. For example, the XPS 13 Laptop, designed and manufactured by Dell, includes the
`
`Intel Killer AX1650 wireless module (wireless radio circuit that can send and receive data
`
`wirelessly), which includes Wi-Fi functionality (bi-directional wireless data communications).
`
`The XPS 13 Laptop can serve as the claimed hub when, for example, a video is streamed over a
`
`Wi-Fi connection from the Internet to the XPS 13 Laptop, and the XPS 13 Laptop’s Wi-Fi Direct-
`
`circuitry and drivers are used (e.g., under control of, for example, its Miracast application) to
`
`mirror that Internet-sourced video to a second device, such as a wireless display:
`
`18
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`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 19 of 284
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`
`Source: https://www.dell.com/en-us/shop/laptops/13-new/spd/xps-13-9310-laptop#tech-specs-
`anchor
`
`
`
`
`
`
`
`
`Source: https://dl.dell.com/topicspdf/xps-13-9310-laptop_setup-guide_en-us.pdf
`
`
`
`
`
`19
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`

`

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`
`
`
`
`
`
`
`Source: https://www.intel.com/content/www/us/en/products/sku/211609/intel-killer-wifi-6-
`ax1650-xw/specifications.html (& embedded Product Brief link:
`https://www.intel.com/content/dam/www/public/us/en/documents/product-briefs/wi-fi-6-
`ax200-module-brief.pdf)
`
`
`
`20
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 21 of 284
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`
`
`Source: https://dl.dell.com/topicspdf/xps-13-9310-laptop_reference-guide_en-us.pdf
`
`
`
`
`
`
`
`Source: https://www.dell.com/support/kbdoc/en-us/000155875/how-to-connect-a-computer-
`to-high-definition-television-hdtv-kb-article-347778
`
`
`
`Source: Wi-Fi Direct Standard, v. 1.7, Section 2.1
`
`47.
`
`The XPS 13 Laptop includes a processor. For example, the XPS 13 Laptop includes
`
`
`
`
`
`
`
`the Intel Core i3-1115G4 system processor:
`
`21
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`

`

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`
`
`
`
`
`
`
`
`
`Source: https://www.dell.com/en-us/shop/laptops/13-new/spd/xps-13-9310-laptop#tech-specs-
`anchor
`
`
`
`
`Source: https://dl.dell.com/topicspdf/xps-13-9310-laptop_setup-guide_en-us.pdf
`
`
`
`
`
`48.
`
`The processor in the XPS 13 Laptop is configured to process data received via the
`
`wireless radio circuit. For example, the XPS 13 Laptop includes the Intel Core i3-1115G4 system
`
`processor which is configured to process data received via the Intel Killer AX1650 wireless
`
`module (wireless radio circuit):
`
`22
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 23 of 284
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`
`
`
`
`
`
`
`
`Source: https://dl.dell.com/topicspdf/xps-13-9310-laptop_setup-guide_en-us.pdf
`
`
`
`
`
`49.
`
`The processor in the XPS 13 Laptop is configured to generate data to be transmitted
`
`by the wireless radio circuit. For example, the XPS 13 Laptop includes the Intel Core i3-1115G4
`
`system processor, which is configured to generate data to be transmitted by the Intel Killer AX1650
`
`wireless module (wireless radio circuit):
`
`23
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 24 of 284
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`
`
`
`
`
`
`
`
`Source: https://dl.dell.com/topicspdf/xps-13-9310-laptop_setup-guide_en-us.pdf
`
`
`
`
`
`Source: Wi-Fi Direct Standard, v. 1.7, Section 3.2.6.1
`
`
`
`
`
`50.
`
`The processor in the XPS 13 Laptop is configured to initiate and maintain network
`
`connections with nodes of a wireless network external to the network-enabled hub. For example,
`
`the XPS 13 Laptop (network-enabled hub) may initiate and maintain a connection (network
`
`connection) with an AP that is external to the XPS 13 Laptop. The XPS 13 Laptop may also, for
`
`24
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 25 of 284
`
`example, initiate and maintain a connection with an STA that is external to the XPS 13 Laptop,
`
`such as a wireless monitor or television:
`
`
`
`
`
`
`Source: Wi-Fi Direct Standard, v. 1.7, Section 2.3
`
`
`
`
`
`
`
`
`
`Source: https://dl.dell.com/topicspdf/xps-13-9310-laptop_setup-guide_en-us.pdf
`
`
`
`25
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 26 of 284
`
`
`
`
`
`
`Source: https://www.youtube.com/watch?v=kXBwdWp7sFM (“How to Connect a Wireless
`Monitor DELL (Official Dell Tech Support)”
`
`
`
`
`
`Source: https://www.dell.com/support/kbdoc/en-us/000155875/how-to-connect-a-computer-
`to-high-definition-television-hdtv-kb-article-347778
`
`
`
`26
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 27 of 284
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`
`
`Source: https://www.screenbeam.com/solutions/miracast/
`
`
`
`
`
`Source: Wi-Fi Direct Standard, v. 1.7, Sections 3.2.2, 3.2.3 & 3.2.7.
`
`
`
`
`
`
`
`51.
`
`The processor in the XPS 13 Laptop is configured to maintain at least a first
`
`network connection using a first network protocol and a second network connection using a second
`
`network protocol that can be maintained simultaneously with each other. For example, the XPS
`
`13 Laptop is configured to connect to an access point using 802.11x Wi-Fi (first network
`
`connection using a first network protocol) and to a receiver display screen using Wi-Fi Direct
`
`(second network connection using a second network protocol):
`
`
`
`
`
`
`Source: https://www.intel.com/content/www/us/en/products/sku/211609/intel-killer-wifi-6-
`ax1650-xw/specifications.html to embedded Product Brief link:
`https://www.intel.com/content/dam/www/public/us/en/documents/product-briefs/wi-fi-6-
`ax200-module-brief.pdf
`
`
`
`27
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 28 of 284
`
`Source: https://www.dell.com/support/kbdoc/en-us/000155875/how-to-connect-a-computer-
`to-high-definition-television-hdtv-kb-article-347778
`
`
`
`
`
`28
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 29 of 284
`Case 6:22-cv-00642-ADA Document1 Filed 06/21/22 Page 29 of 284
`
`a Meas video, we show you how to connect
`your Miracastdisplay to your Windows10 device.
`
`
`
`Best match
`
`od Connect
`App
`
`Settings
`
`Connect to a wireless display
`
`Access work or school
`
`= View network connections
`
`Add a VPN connection
`
`Duplicate or extend to a connected
`display
`Manage your account
`
`Projection settings
`
`Allow remote connectionsto this
`computer
`Search work and web
`
`P& connect - See work and web results
`
`vireiess Monitor
`AConnectin Windows10
`
`Seu.) USing Windowssearch, type Connect andclick the Connect App.
`
`
`
`
`
`Connect
`
`CI Open
`
`© Pin to Start
`© Pin to taskbar
`
`&3
`
`Appsettings
`
`29
`29
`
`

`

`Connectwill open indicating that your Windows10 Dell PC supports Miracast,
`
`Select Connect from the group oftiles.
`
`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 30 of 284
`
`i:
`
`W10ABC1234
`is ready for you to connect wirelessly.
`
`
`
`
`
`
`
`
`
`fa
`
`£3
`
`Network
`
`All settings
`
`ax
`
`oD
`
`se
`
`Location
`
`Mobile hotspot Night light
`
`Bluetooth
`
`a
`
`ao
`
`aD)
`
`Project
`
`los
`
`eelalata Ly
`
`Tablet mod
`
`Nearbysharing Screen snip
`
`-0-
`
`30
`30
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 31 of 284
`
`Source: https://www.youtube.com/watch?v=kXBwdWp7sFM (“How to Connect a Wireless
`Monitor DELL (Official Dell Tech Support)”
`
`
`
`
`
`
`
`
`Source: https://arxiv.org/ftp/arxiv/papers/1810/1810.06964.pdf
`
`31
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 32 of 284
`
`
`
`Source: Wi-Fi Direct Standard, v. 1.7, Section 2.3
`
`
`
`
`
`52.
`
`The following illustrations provided by Dell include step-by-step instructions,
`
`depictions of the user interface prompts as provided in Dell’s Hub Accused Products, and provide
`
`support to teach and instruct users how to set up a wireless connection to mirror a display, for
`
`example, on an XPS 13 Laptop:
`
`
`
`
`
`
`
`Source: https://dl.dell.com/topicspdf/xps-13-9310-laptop_reference-guide_en-us.pdf
`
`
`
`32
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 33 of 284
`
`Source: https://www.dell.com/support/kbdoc/en-us/000155875/how-to-connect-a-computer-
`to-high-definition-television-hdtv-kb-article-347778
`
`
`
`
`
`33
`
`

`

`Case 6:22-cv-00642-ADA Document 1 Filed 06/21/22 Page 34 of 284
`Case 6:22-cv-00642-ADA Document1 Filed 06/21/22 Page 34 of 284
`
`a Meas video, we show you how to connect
`your Miracastdisplay to your Windows10 device.
`
`
`
`Best match
`
`od Connect
`App
`
`Settings
`
`Connect to a wireless display
`
`Access work or school
`
`= View network connections
`
`Add a VPN connection
`
`Duplicate or extend to a connected
`display
`Manage your account
`
`Projection settings
`
`Allow remote connectionsto this
`computer
`Search work and web
`
`P& connect - See work and web results
`
`vireiess Monitor
`AConnectin Windows10
`
`Seu.) USing Windowssearch, type Connect andclick the Connect App.
`
`
`
`
`
`Connect
`
`CI Open
`
`© Pin to Start
`© Pin to taskbar
`
`&3
`
`Appsettings
`
`34
`34
`
`

`

`Connectwill open indicating that your Windows10 Dell PC supports Miracast,
`
`Select Connect from the group oftiles.
`
`Case 6:22-cv-00642-ADA Docum