Neodron LTD v. Hewlett Packard Enterprise Company

Western District of Texas, txwd-6:2019-cv-00319

Exhibit 4

Interested in this case?

Current View

Full Text

Exhibit 4 U.S. Patent No. 8,791,910 ("'910 Patent") Accused Products The HP X360 15-br095ms notebook1 ("HP X360 15-br095ms") infringes at least Claims 1, 13, and 25 of the '910 Patent. Claim 1 Claim 1 HP X360 15-br095ms [pre] 1. A method comprising, by one or The preamble is not a limitation. To the extent the preamble is construed as a limitation, more computing devices: the HP X360 15-br095ms is a computing device that process capacitive touch sensor signals. The HP X360 15-br095ms has a capacitive touchscreen: https://store.hp.com/us/en/mdp/laptops/hp-pavilion-x360-387003--1#!&tab=features (annotations added). [a] receiving two or more output signals The HP X360 15-br095ms can receive two or more output signals responsive to two or responsive to two or more capacitive more capacitive couplings, each of the capacitive couplings occurring between a couplings, each of the capacitive pointing object and one of two or more sensing areas within a sensing region, each of couplings occurring between a pointing the sensing areas having a position within the sensing region. 1 Information in this chart is based on teardown analysis and product evaluation performed on behalf of Neodron. Page 1 Claim 1 HP X360 15-br095ms object and one of two or more sensing The HP X360 15-br095ms, which runs Windows 10, can be used with an HP Pen. areas within a sensing region, each of the https://store.hp.com/us/en/mdp/laptops/hp-pavilion-x360-387003--1#!&tab=features. sensing areas having a position within the sensing region; and Windows 10 devices that support use of an active stylus have palm rejection functionality: Prior to Windows 10, upon receiving input from a pen device that was either in- range or in contact of the screen, the operating system would suppress all touch input (whether in inking or erase mode). In Windows 10, version 1607, the dead-zone is more compact to aid with simultaneous pen and touch interaction. The modified dead-zone captures almost 95% of inadvertent touches while still providing great end-user experience. For left-handed users, the dead-zone ranges from 100 - 270 degrees and spans up to 12 cm radially. For right-handed users, the dead-zone ranges from 280 - 30 degrees and spans up to 12 cm radially. Page 2 Claim 1 HP X360 15-br095ms The operating system accepts touch interactions either from the left or right of the pen tip, depending on the user's setting for handedness. For right handed users, touch interactions are accepted from the left of the pen tip (as shown in the preceding diagram) and vice-versa for left handed users. By default, the pen is configured for right-handed users but can easily be changed by opening Settings clicking Devices, and then opening the Pen dialog window. . . . https://docs.microsoft.com/en-us/windows-hardware/design/component- guidelines/windows-pen-states#palm-rejection. Two capacitive couplings result, for example, when a compatible active pen is in-range of or in contact with the capacitive touchscreen of a HP X360 15-br095ms, and one of a user's fingers touches the screen in the "dead zone" (one sensing area) and another of the user's fingers touches the screen outside the "dead zone" (another sensing area). Page 3 Claim 1 HP X360 15-br095ms [b] if two or more of the output signals If the two or more of the output signals each have an output-signal level that exceeds a each have an output-signal level that predefined activation level, the HP X360 15-br095ms selects a particular one of the exceeds a predefined activation level, sensing areas with output-signal levels exceeding the predefined activation level as an then selecting a particular one of the intended one of the sensing areas, the particular one of the sensing areas selected based sensing areas with output-signal levels on a predefined ranking scheme that prioritizes the two or more sensing areas based on exceeding the predefined activation level the positions of the two or more sensing areas within the sensing region. as an intended one of the sensing areas, the particular one of the sensing areas The HP X360 15-br095ms, which runs Windows 10, can be used with an HP Pen. selected based on a predefined ranking https://store.hp.com/us/en/mdp/laptops/hp-pavilion-x360-387003--1#!&tab=features. scheme that prioritizes the two or more sensing areas based on the positions of As explained above, Windows 10 devices that support use of an active stylus have palm the two or more sensing areas within the rejection functionality that defines certain "dead zones" when a compatible active pen is sensing region. in-range of or in contact with the device's screen. See supra claim element 1[a]. When a compatible active pen is in-range of or in contact with the capacitive touchscreen of a HP X360 15-br095ms, and one of a user's fingers touches the screen in the "dead zone" (one sensing area) and another of the user's fingers touches the screen outside the "dead zone" (another sensing area), the HP X360 15-br095ms selects the input from outside the "dead zone" as the intended sensing area. Claim 13 Claim 13 HP X360 15-br095ms [pre] 13. One or more computer-readable The preamble is not a limitation. To the extent the preamble is construed as a non-transitory storage media embodying limitation, the HP X360 15-br095ms has one or more computer-readable non-transitory logic that is operable when executed to: storage media embodying logic that is operable to process capacitive touch sensor signals. See supra claim element 1[pre]. Page 4 Claim 13 HP X360 15-br095ms [a] receive two or more output signals The HP X360 15-br095ms can receive two or more output signals responsive to two or responsive to two or more capacitive more capacitive couplings, each of the capacitive couplings occurring between a couplings, each of the capacitive pointing object and one of two or more sensing areas within a sensing region, each of couplings occurring between a pointing the sensing areas having a position within the sensing region. object and one of two or more sensing areas within a sensing region, each of the See supra claim element 1[a]. sensing areas having a position within the sensing region; and [b] if two or more of the output signals If the two or more of the output signals each have an output-signal level that exceeds a each have an output-signal level that predefined activation level, the HP X360 15-br095ms selects a particular one of the exceeds a predefined activation level, sensing areas with output-signal levels exceeding the predefined activation level as an then select a particular one of the sensing intended one of the sensing areas, the particular one of the sensing areas selected based areas with output-signal levels exceeding on a predefined ranking scheme that prioritizes the two or more sensing areas based on the predefined activation level as an the positions of the two or more sensing areas within the sensing region. intended one of the sensing areas, the particular one of the sensing areas See supra claim element 1[b]. selected based on a predefined ranking scheme that prioritizes the two or more sensing areas based on the positions of the two or more sensing areas within the sensing region. Claim 25 Claim 25 HP X360 15-br095ms [pre] 25. An apparatus comprising: The preamble is not a limitation. To the extent the preamble is construed as a limitation, the HP X360 15-br095ms is an apparatus that processed capacitive touch sensor signals. See supra claim element 1[pre]. Page 5 Claim 25 HP X360 15-br095ms [a] a touch-sensitive user interface; and The HP X360 15-br095ms has a touch-sensitive user interface (i.e., a touchscreen): https://store.hp.com/us/en/mdp/laptops/hp-pavilion-x360-387003--1#!&tab=features (annotations added). [b] one or more computer-readable non- The HP X360 15-br095ms has one or more computer-readable non-transitory storage transitory storage media coupled to the media embodying logic that is operable to process capacitive touch sensor signals. touch-sensitive user interface that embody logic operable when executed to: See supra claim element 13[pre]. [c] receive two or more output signals The HP X360 15-br095ms can receive two or more output signals responsive to two or responsive to two or more capacitive more capacitive couplings, each of the capacitive couplings occurring between a couplings, each of the capacitive pointing object and one of two or more sensing areas within a sensing region of the couplings occurring between a pointing touch-sensitive user interface, each of the sensing areas having a position within the object and one of two or more sensing sensing region. areas within a sensing region of the touch-sensitive user interface, each of the See supra claim element 1[a]. sensing areas having a position within the sensing region; and Page 6 Claim 25 HP X360 15-br095ms [d] if two or more of the output signals If the two or more of the output signals each have an output-signal level that exceeds a each have an output-signal level that predefined activation level, the HP X360 15-br095ms selects a particular one of the exceeds a predefined activation level, sensing areas with output-signal levels exceeding the predefined activation level as an then select a particular one of the sensing intended one of the sensing areas, the particular one of the sensing areas selected based areas with output-signal levels exceeding on a predefined ranking scheme that prioritizes the two or more sensing areas based on the predefined activation level as an the positions of the two or more sensing areas within the sensing region. intended one of the sensing areas, the particular one of the sensing areas See supra claim element 1[b]. selected based on a predefined ranking scheme that prioritizes the two or more sensing areas based on the positions of the two or more sensing areas within the sensing region. Page 7