Neodron LTD v. Hewlett Packard Enterprise Company

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

Exhibit 8

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5 Exhibit 8 5 U.S. Patent No. 9,372,580 ("'580 Patent") for HP 15-bw030nr Exemplary Accused Product The HP 15-bw030nr1 ("HP 15-bw030nr") infringes at least Claims 1, 5, and 9 of the '580 Patent. Claim 1 Claim 1 HP 15-bw030nr [pre] A method, performed by executing The preamble is not a limitation. logic embodied by one or more computer-readable non-transitory storage The HP 15-bw030nr has a touch controller that performs the claimed method by media, comprising: executing logic embodied by one or more computer-readable non-transitory storage media. The HP 15-bw030nr has an AMD A9-9420 processor that controls, among other things, the device's touch sensing capability: 1 Information in this chart is based on teardown analysis performed on behalf of Neodron. Page 1 5 Claim 1 HP 15-bw030nr Photograph of the AMD A9-9420 processor from a teardown of an HP 15-bw030nr; see http://www.cpu-world.com/CPUs/Bulldozer/AMD-A9- Series%20for%20Notebooks%20A9-9420.html (indicating the AM9420AYN23AC marking corresponds to the AMD A9-9420 processor); see also https://support.hp.com/us-en/document/c05528100; https://www.amd.com/en/product/2126. More specifically, the AMD A9-9420 processor works in conjunction with the HP 15- bw030nr's Elan touch controller (labeled ELAN eKTH5015SUS) to control the device's touch sensors, including performing measurements on signals from the touchscreen: Photograph of the Elan touch controller from a teardown of an HP 15-bw030nr. The HP 15-bw030nr's touch controller is connected to and controls a touchscreen: Page 2 5 Claim 1 HP 15-bw030nr Touchscreen Photograph of HP 15-bw030nr. The following image displays the setup for a series of tests performed on the HP 15- bw030nr to analyze the capacitive touch signals on the touchscreen, which includes sensor probes located near the surface of the touch sensor. Page 3 5 Claim 1 HP 15-bw030nr Photograph of test setup. Based on the tests, we have been able to visualize at least the signals generated by the touchscreen (touch sensor) drive lines across the entire touchscreen, as well as measure the effects various touch inputs have on these signals. One example of such signals is shown below. Page 4 5 Claim 1 HP 15-bw030nr Screenshot of oscilloscope measuring sensor probe signals on HP 15-bw030nr touchscreen. [a] sending a first set of signals to a first The HP 15-bw030nr sends a first set of signals to a first set of lines of a touch sensor, set of lines of a touch sensor, the first set the first set of lines arranged along a first axis, each line of the first set of lines of lines arranged along a first axis, each comprising electrodes. line of the first set of lines comprising electrodes; The HP 15-bw030nr has drive electrodes arranged in the axis along the long edge of the touchscreen, as shown below. Page 5 5 Claim 1 HP 15-bw030nr Red lines are a visual representation (not to scale) of the drive electrodes showing their orientation (first set of lines comprising electrodes) Photograph of test setup (annotated). Page 6 5 Claim 1 HP 15-bw030nr See, e.g., supra claim element 1[pre]. The following image shows signal measurements of two drive electrodes, a yellow (1st drive electrode) waveform and a purple waveform (2nd drive electrode). With respect to this claim limitation, an example of a "first set of signals to a first set of lines of a touch sensor" is shown below, occurring at the timeslot as shown. First set of signals to a first set of lines of a touch sensor (yellow and purple waveforms are superimposed) Page 7 5 Claim 1 HP 15-bw030nr Oscilloscope measurement of signals. [b] receiving a second set of signals on a The HP 15-bw030nr receives a second set of signals on a second set of lines of the second set of lines of the touch sensor in touch sensor in response to sending the first set of signals, the second set of lines response to sending the first set of arranged along a second axis that is different than the first axis, each line of the second signals, the second set of lines arranged set of lines comprising electrodes, the second set of lines capacitively coupled to the along a second axis that is different than first set of lines. the first axis, each line of the second set of lines comprising electrodes, the The HP 15-bw030nr has sense electrodes arranged in the axis along the short edge of second set of lines capacitively coupled the touchscreen, as shown below. to the first set of lines; Page 8 5 Claim 1 HP 15-bw030nr Blue lines are a visual representation (not to scale) of sense electrodes showing their orientation (second set of lines comprising electrodes) Red lines are a visual representation (not to scale) of the drive electrodes showing their orientation (first set of lines comprising electrodes) Photograph of test setup (annotated). Page 9 5 Claim 1 HP 15-bw030nr See, e.g., supra claim element 1[pre]. The touch controller of the HP 15-bw030nr receives signals that are in response to the first set of signals to a first set of lines. This is, for example, a second set of signals on a second set of lines of the touch sensor. Second set of signals on a second set of lines of a touch sensor are in response to this first set of signals (yellow and purple waveforms are superimposed) Page 10 5 Claim 1 HP 15-bw030nr Oscilloscope measurement of signals. The sense electrodes (second set of lines) are capacitively coupled to the drive electrodes (first set of lines) because they are separated by a dielectric material, as shown in the representative example below. Capacitive coupling Illustration of capacitive coupling. [c] in response to receiving the second The HP 15-bw030nr measures the second set of signals to determine a second set of set of signals, measuring the second set measured values corresponding to the second set of signals, in response to receiving the of signals to determine a second set of second set of signals. Page 11 5 Claim 1 HP 15-bw030nr measured values corresponding to the For example, measuring the second set of signals is based on measuring the voltage second set of signals; and/or shape of the waveform in the timeslot shown below, which determines a second set of measured values. Measurement is based on the waveform in this timeslot (yellow and purple waveforms are superimposed) Oscilloscope measurement of signals. Page 12 5 Claim 1 HP 15-bw030nr Though not required by the claim but for the sake of clarifying this example, upon information and belief, the measurements shown here are mutual capacitance measurements. [d] storing the second set of measured The HP 15-bw030nr stores the second set of measured values corresponding to the values corresponding to the second set of second set of signals. signals; For example, the HP 15-bw030nr stores this on a memory on the touch controller. See, e.g., supra claim element 1[pre]. [e] sending a third set of signals to the The HP 15-bw030nr sends a third set of signals to the first set of lines. first set of lines; For example, the HP 15-bw030nr sends a third set of signals to the first set of lines in the timeslot shown below. Page 13 5 Claim 1 HP 15-bw030nr Third set of signals to the first set of lines in this timeslot (yellow and purple waveforms are superimposed) Oscilloscope measurement of signals. [f] determining, after sending the third The HP 15-bw030nr determines, after sending the third set of signals to the first set of set of signals to the first set of lines, a lines, a fourth set of signals by measuring the first set of lines that received the third set fourth set of signals by measuring the of signals. first set of lines that received the third set of signals; Page 14 5 Claim 1 HP 15-bw030nr For example, determining a fourth set of signals is based on measuring the voltage and/or shape of the waveform of the third set of signals in the timeslot shown below. Measurement is based on the waveform in this timeslot (yellow and purple waveforms are superimposed) Oscilloscope measurement of signals. Though not required by the claim but for the sake of clarifying this example, upon information and belief, the measurements shown here are self capacitance measurements. Page 15 5 Claim 1 HP 15-bw030nr [g] in response to measuring the fourth The HP 15-bw030nr measures the fourth set of signals, and in response to that, set of signals, determining a fourth set of determines a fourth set of measured values corresponding to the fourth set of signals. measured values corresponding to the fourth set of signals; For example, the touch controller of the HP 15-bw030nr measures the fourth set of signals to determine a fourth set of measured values. See, e.g., supra claim element 1[f]. [h] storing the fourth set of measured The HP 15-bw030nr stores the fourth set of measured values corresponding to the values corresponding to the fourth set of fourth set of signals. signals; For example, the HP 15-bw030nr stores this on a memory on the touch controller. See, e.g., supra claim element 1[pre]. [i] determining a fifth set of signals by The HP 15-bw030nr determines a fifth set of signals by compensating the second set of compensating the second set of signals signals based on the fourth set of signals, wherein determining the fifth set of signals based on the fourth set of signals, comprises adjusting the second set of measured values corresponding to the second set wherein determining the fifth set of of signals with the fourth set of measured values corresponding to the fourth set of signals comprises adjusting the second signals. set of measured values corresponding to the second set of signals with the fourth For example, the HP 15-bw030nr compensates the second set of signals (mutual set of measured values corresponding to capacitance signals) based on the fourth set of signals (self capacitance signals) to the fourth set of signals; and determine a fifth set of signals. The fifth set of signals is determined, in part, by the touch controller adjusting the second set of measured values (values based on mutual capacitance signals) with the fourth set of measured values (values based on self capacitance signals). By way of a non-limiting example, a test involving water on the touchscreen provides evidence of this limitation, as shown below. In this example, despite the fact that water is present on the touchscreen of the HP 15- bw030nr, touch inputs are correctly registered by the controller, without false touches from the water, because a fifth set of signals is generated by compensating the second set of signals (mutual-capacitance measurement) based on the fourth set of signals Page 16 5 Claim 1 HP 15-bw030nr (drive electrode self-capacitance measurement), wherein determining the fifth set of signals comprises adjusting the second set of measured values corresponding to the second set of signals with the fourth set of measured values corresponding to the fourth set of signals. Touch inputs Water on touchscreen Photo of water droplet touchscreen testing. Page 17 5 Claim 1 HP 15-bw030nr Determination of a touch in the presence of water Photo of water droplet touchscreen testing. Water on touchscreen (no touch registered here) [j] determining whether a touch occurred The HP 15-bw030nr determines whether a touch occurred based on the fifth set of based on the fifth set of signals. signals. Page 18 5 Claim 1 HP 15-bw030nr For example, the touch controller of the HP 15-bw030nr uses the fifth set of signals to determine whether a touch occurred. This is shown in the example below by the fact that the touchscreen registers a touch in the presence of water on the surface of the touchscreen. See, e.g., supra claim element 1[i]. Claim 5 Claim 5 HP 15-bw030nr [pre] A system comprising: The preamble is not a limitation. The HP 15-bw030nr is a system. See, e.g., supra claim element 1[pre]. [a] a touch sensor comprising: a first set The HP 15-bw030nr has a touch sensor comprising a first set of lines, the first set of of lines, the first set of lines arranged lines arranged along a first axis, each line of the first set of lines comprising electrodes. along a first axis, each line of the first set of lines comprising electrodes; a second See, e.g., supra claim element 1[a]. set of lines, the second set of lines The HP 15-bw030nr has a touch sensor comprising a second set of lines, the second set arranged along a second axis that is of lines arranged along a second axis that is different than the first axis, each line of the different than the first axis, each line of second set of lines comprising electrodes, the second set of lines capacitively coupled to the second set of lines comprising the first set of lines. electrodes, the second set of lines capacitively coupled to the first set of See, e.g., supra claim element 1[b]. lines; and Page 19 5 Claim 5 HP 15-bw030nr [b] one or more computer-readable non- The HP 15-bw030nr has one or more computer-readable non-transitory storage media transitory storage media comprising logic comprising logic that, when executed is operable to perform the recited claim that, when executed is operable to: send a limitations. first set of signals to the first set of lines of the touch sensor; See, e.g., supra claim element 1[pre]. The HP 15-bw030nr sends a first set of signals to a first set of lines of a touch sensor, the first set of lines arranged along a first axis, each line of the first set of lines comprising electrodes. See, e.g., supra claim element 1[a]. [c] receive a second set of signals on the The HP 15-bw030nr receives a second set of signals on a second set of lines of the second set of lines of the touch sensor in touch sensor in response to sending the first set of signals, the second set of lines response to sending the first set of arranged along a second axis that is different than the first axis, each line of the second signals; set of lines comprising electrodes, the second set of lines capacitively coupled to the first set of lines. See, e.g., supra claim element 1[b]. [d] in response to receiving the second The HP 15-bw030nr measures the second set of signals to determine a second set of set of signals, measure the second set of measured values corresponding to the second set of signals, in response to receiving the signals to determine a second set of second set of signals. measured values corresponding to the second set of signals; See, e.g., supra claim element 1[c]. [e] store the second set of measured The HP 15-bw030nr stores the second set of measured values corresponding to the values corresponding to the second set of second set of signals. signals; See, e.g., supra claim element 1[d]. [f] send a third set of signals to the first The HP 15-bw030nr sends a third set of signals to the first set of lines. set of lines; See, e.g., supra claim element 1[e]. Page 20 5 Claim 5 HP 15-bw030nr [g] determine, after sending the third set The HP 15-bw030nr determines, after sending the third set of signals to the first set of of signals to the first set of lines, a fourth lines, a fourth set of signals by measuring the first set of lines that received the third set set of signals by measuring the first set of of signals. lines that received the third set of signals; See, e.g., supra claim element 1[f]. [h] in response to measuring the fourth The HP 15-bw030nr measures the fourth set of signals, and in response to that, set of signals, determining a fourth set of determines a fourth set of measured values corresponding to the fourth set of signals. measured values corresponding to the fourth set of signals; See, e.g., supra claim element 1[g]. [i] store the fourth set of measured values The HP 15-bw030nr stores the fourth set of measured values corresponding to the corresponding to the fourth set of signals; fourth set of signals. See, e.g., supra claim element 1[h]. [j] determine a fifth set of signals by The HP 15-bw030nr determines a fifth set of signals by compensating the second set of compensating the second set of signals signals based on the fourth set of signals, wherein determining the fifth set of signals based on the fourth set of signals, comprises adjusting the second set of measured values corresponding to the second set wherein determining the fifth set of of signals with the fourth set of measured values corresponding to the fourth set of signals comprises adjusting the second signals. set of measured values corresponding to the second set of signals with the fourth See, e.g., supra claim element 1[i]. set of measured values corresponding to the fourth set of signals; and [k] determine whether a touch occurred The HP 15-bw030nr determines whether a touch occurred based on the fifth set of based on the fifth set of signals. signals. See, e.g., supra claim element 1[j]. Page 21 5 Claim 9 Claim 9 HP 15-bw030nr [pre] One or more computer-readable The preamble is not a limitation. non-transitory storage media comprising logic that, when executed is operable to: The HP 15-bw030nr has one or more computer-readable non-transitory storage media comprising logic that, when executed is operable to perform the recited claim limitations. See, e.g., supra claim element 1[pre]. [a] send a first set of signals to a first set The HP 15-bw030nr sends a first set of signals to a first set of lines of a touch sensor, of lines of a touch sensor, the first set of the first set of lines arranged along a first axis, each line of the first set of lines lines arranged along a first axis, each line comprising electrodes. of the first set of lines comprising electrodes; See, e.g., supra claim element 1[a]. [b] receive a second set of signals on a The HP 15-bw030nr receives a second set of signals on a second set of lines of the second set of lines of the touch sensor in touch sensor in response to sending the first set of signals, the second set of lines response to sending the first set of arranged along a second axis that is different than the first axis, each line of the second signals, the second set of lines arranged set of lines comprising electrodes, the second set of lines capacitively coupled to the along a second axis that is different than first set of lines. the first axis, each line of the second set of lines comprising electrodes, the See, e.g., supra claim element 1[b]. second set of lines capacitively coupled to the first set of lines; [c] in response to receiving the second The HP 15-bw030nr measures the second set of signals to determine a second set of set of signals, measure the second set of measured values corresponding to the second set of signals, in response to receiving the signals to determine a second set of second set of signals. measured values corresponding to the second set of signals; See, e.g., supra claim element 1[c]. Page 22 5 Claim 9 HP 15-bw030nr [d] store the second set of measured The HP 15-bw030nr stores the second set of measured values corresponding to the values corresponding to the second set of second set of signals. signals; See, e.g., supra claim element 1[d]. [e] send a third set of signals to the first The HP 15-bw030nr sends a third set of signals to the first set of lines. set of lines; See, e.g., supra claim element 1[e]. [f] determine, after sending the third set The HP 15-bw030nr determines, after sending the third set of signals to the first set of of signals to the first set of lines, a fourth lines, a fourth set of signals by measuring the first set of lines that received the third set set of signals by measuring the first set of of signals. lines that received the third set of signals; See, e.g., supra claim element 1[f]. [g] in response to measuring the fourth The HP 15-bw030nr measures the fourth set of signals, and in response to that, set of signals, determining a fourth set of determines a fourth set of measured values corresponding to the fourth set of signals. measured values corresponding to the fourth set of signals; See, e.g., supra claim element 1[g]. [h] store the fourth set of measured The HP 15-bw030nr stores the fourth set of measured values corresponding to the values corresponding to the fourth set of fourth set of signals. signals; See, e.g., supra claim element 1[h]. [i] determine a fifth set of signals by The HP 15-bw030nr determines a fifth set of signals by compensating the second set of compensating the second set of signals signals based on the fourth set of signals, wherein determining the fifth set of signals based on the fourth set of signals, comprises adjusting the second set of measured values corresponding to the second set wherein determining the fifth set of of signals with the fourth set of measured values corresponding to the fourth set of signals comprises adjusting the second signals. set of measured values corresponding to the second set of signals with the fourth See, e.g., supra claim element 1[i]. set of measured values corresponding to the fourth set of signals; and Page 23 5 Claim 9 HP 15-bw030nr [j] determine whether a touch occurred The HP 15-bw030nr determines whether a touch occurred based on the fifth set of based on the fifth set of signals. signals. See, e.g., supra claim element 1[j]. Page 24