Philips North America LLC v. Fitbit, Inc., 1:19-cv-11586, No. 46-2 (D.Mass. Mar. 19, 2020)

Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 1 of 28
`Case 1:19-cv-11586—IT Document 46-2 Filed 03/19/20 Page 1 of 28
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`EXHIBIT (cid:37)
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`EXHIBIT B
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`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 2 of 28
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`
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`PNA-FB0000042
`
`athlete's performance:
`The Accused Product provides a portable feedback system providing regular updates on an
`
`Fitbit Ionic
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`comprising:
`athlete's performance,
`regular updates on an
`system providing
`A portable feedback
`Elements of Claim 1:
`Claim 7
`
`U.S. Patent No.
`
`6,013,007
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 3 of 28
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`
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`2
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`PNA-FB0000185
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`
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`PNA-FB0000215
`
`that obtains a series of time-stamped waypoints:
`The system provided by the Accused Product comprises a global positioning system GPS receiver
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`waypoints;
`of time-stamped
`that obtains a series
`system GPS receiver
`a global positioning
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 4 of 28
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`
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`3
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`PNA-FB0002445
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`
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`PNA-FB0000185
`
`feedback data from the series of time-stamped waypoints obtained by said GPS receiver:
`The system provided by the Accused Product comprises means for computing athletic performance
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`receiver; and
`obtained by said GPS
`stamped waypoints
`the series of time-
`feedback data from
`athletic performance
`means for computing
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 5 of 28
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`4
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`PNA-FB0000235
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` PNA-FB0000232
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`
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`
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 6 of 28
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`5
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`
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`PNA-FB0000909
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`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 7 of 28
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`6
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`
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`PNA-FB0000132
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`performance feedback data to an athlete:
`The system provided by the Accused Product comprises means for presenting the athletic
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`athlete.
`feedback data to an
`performance
`the athletic
`means for presenting
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 8 of 28
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`7
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`PNA-FB0000236
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`
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`
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`PNA-FB0000235
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`
`
`
`
`
`
`PNA-FB0000232
`
`
`
`
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 9 of 28
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`8
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`
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`PNA-FB______
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`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 10 of 28
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`9
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`PNA-FB0000909
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`
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 11 of 28
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`10
`
`
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`PNA-FB0000905
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`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 12 of 28
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`13
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`
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`
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`PNA-FB0000042
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`of other athletes:
`The Accused Product provides a system for comparing the performance of an athlete with the performance
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`comprising:
`athletes, said system
`performance of other
`athlete with the
`the performance of an
`A system for comparing
`Claim 21
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 13 of 28
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`14
`
`
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`PNA-FB0000128-129
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`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 14 of 28
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`15
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`PNA-FB0000215
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`
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`
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`PNA-FB0000042
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`the Fitbit Ionic) for obtaining a series of time-stamped waypoints:
`The system provided by the Accused Product comprises a global positioning system GPS receiver (within
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`waypoints;
`time-stamped
`obtaining a series of
`system GPS receiver for
`a global positioning
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 15 of 28
`
`
`
`
`
`16
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`PNA-FB0000185
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`PNA-FB0000215
`
`feedback data from the series of time-stamped waypoints obtained by said GPS receiver:
`The system provided by the Accused Product provides means for computing athletic performance
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`said GPS receiver;
`waypoints obtained by
`series of time-stamped
`feedback data from the
`athletic performance
`means for computing
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 16 of 28
`
`17
`
`
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`PNA- FB0002445
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`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 17 of 28
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`18
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`PNA-FB0000235
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` PNA-FB0000232
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`
`
`
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`
`
`
`
`
`
`
`
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 18 of 28
`
`19
`
`
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`PNA-FB0000132
`
`feedback data to an athlete:
`The system provided by the Accused Product provides means for presenting the athletic performance
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`athlete; and
`feedback data to an
`athletic performance
`means for presenting the
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 19 of 28
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`20
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`PNA-FB0000236
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`PNA-FB0000235
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`
`
`
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`
`
`PNA-FB0000232
`
`
`
`
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 20 of 28
`
`21
`
`
`
`PNA- FB0002450
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`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 21 of 28
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`22
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`
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`PNA-FB0000908
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`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 22 of 28
`
`23
`
`
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`PNA-FB0002443
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 23 of 28
`
`24
`
`
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`PNA-FB0000905
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 24 of 28
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`
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`25
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`PNA-FB0000113
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`
`
`PNA-FB0000158
`
`for comparison with athletic performance data of other athletes:
`wireless modem to transmit the athletic performance feedback data to a remote computer (Fitbit’s servers)
`the Fitbit Ionic “syncs” with a device that has the Fitbit App, the device with the Fitbit App utilizes a
`feedback data to a remote computer for comparison with athletic performance data of other athletes. When
`The system provided by the Accused Product provides a modem for transmitting the athletic performance
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`other athletes.
`performance data of
`comparison with athletic
`computer for
`data to a remote
`performance feedback
`transmitting the athletic
`a modem for
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 25 of 28
`
`
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`26
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`
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`PNA-FB0000128-129
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`PNA-FB0000065
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 26 of 28
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`27
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`
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`PNA-FB0000235
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`
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`
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`PNA-FB0000234
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`
`
`
`
`PNA-FB0000232
`
`
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 27 of 28
`
`28
`
`
`
`PNA-FB0000236
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

`Case 1:19-cv-11586-IT Document 46-2 Filed 03/19/20 Page 28 of 28
`
`29
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`
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`PNA-FB0000909
`
`Phillips North America LLC v. Fitbit, Inc., No. 1:19-cv-11586-IT (D. Mass)
`
`Exhibit 1 - Infringement Claim Chart: U.S. Patent No. 6,013,007
`
`
`
`
`
`

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