Neodron LTD v. Hewlett Packard Enterprise Company

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

Exhibit 6

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9 Exhibit 6 9 U.S. Patent No. 9,024,790 ("'790 Patent") Accused Products The HP 15-bs289wm notebook1 ("HP 15-bs289wm") infringes at least Claims 1, 7, and 13 of the '790 Patent. Claim 1 Claim 1 HP 15-bs289wm [pre] An apparatus comprising: The preamble is not a limitation. To the extent the preamble is construed as a limitation, the HP 15-bs289wm is an apparatus as claimed. For example, the HP 15-bs289wm has a touchscreen and a touch keyboard, as shown below: https://support.hp.com/us-en/product/hp-15-bs200-laptop- pc/20395753/model/22909879. 1 Information in this chart is based on teardown analysis performed on behalf of Neodron. Page 1 9 Claim 1 HP 15-bs289wm https://support.hp.com/us-en/document/c06171852. Screenshot of a portion of the HP 15-bs289wm's touch keyboard. [a] plurality of keys; The HP 15-bs289wm includes a plurality of keys. For example, in its default configuration the HP 15-bs289wm includes a touch keyboard having numerous keys. Page 2 9 Claim 1 HP 15-bs289wm https://support.hp.com/us-en/product/hp-15-bs200-laptop- pc/20395753/model/22909879. https://support.hp.com/us-en/document/c06171852. Page 3 9 Claim 1 HP 15-bs289wm Screenshot of a portion of the HP 15-bs289wm's touch keyboard. [b] control logic operatively coupled to The HP 15-bs289wm includes control logic that is operatively coupled to the plurality the plurality of keys and configured to: of keys and configured as claimed. For example, the HP 15-bs289wm has an Intel Pentium Silver N5000 processor that controls, among other things, the device's touch sensing capability: Page 4 9 Claim 1 HP 15-bs289wm https://support.hp.com/us-en/document/c06171852. More specifically, the Intel Pentium Silver N5000 processor works in conjunction with the HP 15-bs289wm's touch controller (Elan chip labeled "eKTH5015SUS") to control the device's touch sensors, including performing measurements on signals from the touch keyboard: Page 5 9 Claim 1 HP 15-bs289wm Photograph of the Elan eKTH5015SUS touch controller from a teardown of a HP 15- bs289wm. [c] analyze, to determine a first active The HP 15-bs289wm's control logic analyzes respective first signal values of a plurality key, respective first signal values of the of keys to determine a first active key. plurality of keys; When a user touches the HP 15-bs289wm's touchscreen while the keyboard is active, the control logic determines a first active key based on signals indicative of the proximity between the user's touch and the plurality of keys. These signals derive from touch detection data associated with the device's touch controller. For example, if the user's touch is positioned sufficiently close to the "F" key of the HP 15-bs289wm's touchscreen keyboard, the control logic's analysis of the first signal values of the plurality of keys leads to the determination that the user intended to touch "F." The control logic then assigns "F" as the first active key. Page 6 9 Claim 1 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "F" key as the first active key). [d] assign, based at least on the respective The HP 15-bs289wm's control logic assigns a first key as the first active key, based at first sensor values of the plurality keys, a least on the respective first sensor values of the plurality of keys. first key as the first active key; and The control logic analyzes sensor values of the keys comprising the device's touch keyboard. Based at least on these sensor values, the device's control logic determines which key was intended to be touched and assigns it as the active key. For example, if the user's touch is positioned sufficiently close to the "F" key of the HP 15-bs289wm's touchscreen keyboard, the control logic will determine that the user intended to touch "F" and, based at least on the respective sensor values associated with "F" and the other keys, assign "F" as the first active key. Page 7 9 Claim 1 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "F" key as the first active key). [e] analyze, to determine a second active The HP 15-bs289wm's control logic analyzes respective second signal values of the key, respective second signal values of plurality of keys to determine a second active key, the analysis to determine the second the plurality of keys, the analysis, to active key of the respective second signal values of the plurality of keys being biased in determine the second active key, of the favor of the first key. respective second signal values of the plurality of keys being biased in favor of As a non-limiting illustration, assume that the user initially touched the "F" key of the the first key. HP 15-bs289wm's touchscreen keyboard, such that "F" is the first active key. Page 8 9 Claim 1 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "F" key as the first active key). The device's control logic analyzes second signal values of the plurality of keys to determine a second active key (e.g., "G" if the user is now intending to touch "G"). For example, if the user then slides the existing touch of the "F" key toward the "G" key (a currently inactive key), "G" will be assigned as the second active key if the control logic's analysis of the respective second signal values determines that "G" is now being touched. Page 9 9 Claim 1 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "G" key as the second active key). This second active key analysis is biased in favor of the first active key ("F" in this example). To illustrate this biasing, below is a photo showing the device's behavior if the user slides the initial touch of the "F" key toward the "G" key but does not slide far enough into the "G" key region to overcome the control logic's biasing. In that case, the control logic will not determine "G" to be the second active key. Page 10 9 Claim 1 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing that "G" is not determined to be the second active key despite the user touching part of the "G" key region). To further illustrate this biasing toward "F" as the first active key, below is a photo illustrating the device's behavior if the user—instead of first touching "F"—begins by touching the same left edge of the "G" key region. Page 11 9 Claim 1 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing that "G" would be determined to be an active key if the left edge of its key region were touched, so long as "F" is not already the first active key). Claim 7 Claim 7 HP 15-bs289wm [pre] A method comprising: The preamble is not a limitation. To the extent the preamble is construed as a limitation, the HP 15-bs289wm practices methods related to determining active keys. The HP 15- bs289wm has a touchscreen and a touch keyboard, as shown below: Page 12 9 Claim 7 HP 15-bs289wm https://support.hp.com/us-en/product/hp-15-bs200-laptop- pc/20395753/model/22909879. https://support.hp.com/us-en/document/c06171852. Page 13 9 Claim 7 HP 15-bs289wm Screenshot of a portion of the HP 15-bs289wm's touch keyboard. [a] analyzing, to determine a first active The HP 15-bs289wm analyzes respective first sensor values of a plurality of keys to key, respective first sensor values of a determine a first active key. plurality of keys; When a user touches the HP 15-bs289wm's touchscreen while the keyboard is active, the device determines a first active key based on sensor values indicative of the proximity between the user's touch and the plurality of keys. For example, if the user's touch is positioned sufficiently close to the "F" key of the HP 15-bs289wm's touchscreen keyboard, the device's analysis of the first sensor values of the plurality of keys leads to the determination that the user intended to touch "F." The device then assigns "F" as the first active key. Page 14 9 Claim 7 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "F" key as the first active key). [b] assigning, based at least on the The HP 15-bs289wm assigns a first key as the first active key, based at least on the respective sensor values of the plurality respective first sensor values of the plurality of keys. keys, a first key as the first active key; and The device analyzes sensor values of the keys comprising the device's touch keyboard. Based at least on these sensor values, the device determines which key was intended to be touched and assigns it as the active key. For example, if the user's touch is positioned sufficiently close to the "F" key of the HP 15-bs289wm's touchscreen keyboard, the device will determine that the user intended to touch "F" and, based at least on the respective sensor values associated with "F" and the other keys, assign "F" as the first active key. Page 15 9 Claim 7 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "F" key as the first active key). [c] analyzing, to determine a second The HP 15-bs289wm analyzes respective second signal values of the plurality of keys to active key, respective second signal determine a second active key, the analysis to determine the second active key of the values of the plurality of keys, the respective second signal values of the plurality of keys being biased in favor of the first analysis, to determine the second active key. key, of the respective second signal values of the plurality of keys being As a non-limiting illustration, assume that the user initially touched the "F" key of the biased in favor of the first key. HP 15-bs289wm's touchscreen keyboard, such that "F" is the first active key. Page 16 9 Claim 7 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "F" key as the first active key). The device analyzes second signal values of the plurality of keys to determine a second active key (e.g., "G" if the user is now intending to touch "G"). For example, if the user then slides the existing touch of the "F" key toward the "G" key (a currently inactive key), "G" will be assigned as the second active key if the device's analysis of the respective second signal values determines that "G" is now being touched. Page 17 9 Claim 7 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "G" key as the second active key). This second active key analysis is biased in favor of the first active key ("F" in this example). To illustrate this biasing, below is a photo showing the device's behavior if the user slides the initial touch of the "F" key toward the "G" key but does not slide far enough into the "G" key region to overcome the device's biasing. In that case, the device will not determine "G" to be the second active key. Page 18 9 Claim 7 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing that "G" is not determined to be the second active key despite the user touching part of the "G" key region). To further illustrate this biasing toward "F" as the first active key, below is a photo illustrating the device's behavior if the user—instead of first touching "F"—begins by touching the same left edge of the "G" key region. Page 19 9 Claim 7 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing that "G" would be determined to be an active key if the left edge of its key region were touched, so long as "F" is not already the first active key). Claim 13 Claim 13 HP 15-bs289wm [pre] Logic embodied in a non-transitory The preamble is not a limitation. To the extent the preamble is construed as a limitation, computer-readable medium, the logic the HP 15-bs289wm has a non-transitory computer-readable medium comprising logic configured when executed to perform configured to perform the recited claim limitations. operations comprising: For example, the HP 15-bs289wm has an Intel Pentium Silver N5000 processor that controls, among other things, the device's touch sensing capability: Page 20 9 Claim 13 HP 15-bs289wm https://support.hp.com/us-en/document/c06171852. More specifically, the Intel Pentium Silver N5000 processor works in conjunction with the HP 15-bs289wm's touch controller (Elan chip labeled "eKTH5015SUS") to control the device's touch sensors, including performing measurements on signals from the touch keyboard: Page 21 9 Claim 13 HP 15-bs289wm Photograph of the Elan eKTH5015SUS touch controller from a teardown of a HP 15- bs289wm. [a] analyzing, to determine a first active The HP 15-bs289wm's control logic analyzes respective first sensor values of a key, respective first sensor values of a plurality of keys to determine a first active key. plurality of keys; When a user touches the HP 15-bs289wm's touchscreen while the keyboard is active, the control logic determines a first active key based on sensor values indicative of the proximity between the user's touch and the plurality of keys. These sensor values derive from touch detection data associated with the device's touch controller. For example, if the user's touch is positioned sufficiently close to the "F" key of the HP 15-bs289wm's touchscreen keyboard, the control logic's analysis of the first sensor values of the plurality of keys leads to the determination that the user intended to touch "F." The control logic then assigns "F" as the first active key. Page 22 9 Claim 13 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "F" key as the first active key). [b] assigning, based at least on the The HP 15-bs289wm's control logic assigns a first key as the first active key, based at respective sensor values of the plurality least on the respective sensor values of the plurality of keys. keys, a first key as the first active key; and The control logic analyzes sensor values of the keys comprising the device's touch keyboard. Based at least on these sensor values, the device's control logic determines which key was intended to be touched and assigns it as the active key. For example, if the user's touch is positioned sufficiently close to the "F" key of the HP 15-bs289wm's touchscreen keyboard, the control logic will determine that the user intended to touch "F" and, based at least on the respective sensor values associated with "F" and the other keys, assign "F" as the first active key. Page 23 9 Claim 13 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "F" key as the first active key). [c] analyzing, to determine a second The HP 15-bs289wm's control logic analyzes, to determine a second active key, active key, respective second signal respective second signal values of the plurality of keys, the first key being biased during values of the plurality of keys, the first the analysis, the analysis, to determine the second active key, of the respective second key being biased during the analysis, the signal values of the plurality of keys being biased in favor of the first key. analysis, to determine the second active key, of the respective second signal As a non-limiting illustration, assume that the user initially touched the "F" key of the values of the plurality of keys being HP 15-bs289wm's touchscreen keyboard, such that "F" is the first active key. biased in favor of the first key. Page 24 9 Claim 13 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "F" key as the first active key). The device's control logic analyzes second signal values of the plurality of keys to determine a second active key (e.g., "G" if the user is now intending to touch "G"). For example, if the user then slides the existing touch of the "F" key toward the "G" key (a currently inactive key), "G" will be assigned as the second active key if the control logic's analysis of the respective second signal values determines that "G" is now being touched. Page 25 9 Claim 13 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing shading of "G" key as the second active key). This second active key analysis is biased in favor of the first active key ("F" in this example). To illustrate this biasing, below is a photo showing the device's behavior if the user slides the initial touch of the "F" key toward the "G" key but does not slide far enough into the "G" key region to overcome the control logic's biasing. In that case, the control logic will not determine "G" to be the second active key. Page 26 9 Claim 13 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing that "G" is not determined to be the second active key despite the user touching part of the "G" key region). To further illustrate this biasing toward "F" as the first active key, below is a photo illustrating the device's behavior if the user—instead of first touching "F"—begins by touching the same left edge of the "G" key region. Page 27 9 Claim 13 HP 15-bs289wm Screenshot from a HP 15-bs289wm (showing that "G" would be determined to be an active key if the left edge of its key region were touched, so long as "F" is not already the first active key). Page 28