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Roku v. Universal Electronics - Complaint
Roku v. Universal Electronics - Complaint
1 COMPLAINT
2 1. Plaintiff Roku, Inc. (“Roku” or “Plaintiff”) brings this action against
3 Universal Electronics, Inc., Gemstar Technology (Qinzhou) Co. Ltd., Gemstar
4 Technology (Yangzhou) Co. Ltd., C.G. Development Ltd., Universal Electronics BV,
5 UEI Brasil Controles Remotos Ltda., and CG México Remote controls, S. de R.L. de
6 C.V. (collectively, “UEI” or “Defendants”) and alleges as follows.
7
8 NATURE OF THE ACTION
1 Civil Procedure § 410.10. UEI has a principal place of business in the state of
2 California, and, as a result, UEI is subject to general jurisdiction here. UEI has
3 infringed Roku’s asserted patents in California, and, as a result, UEI is subject to
4 specific jurisdiction here. In particular, UEI sells, licenses, and offers to sell and
5 license hardware and software relating to remote control devices and associated
6 products that infringe Roku’s asserted patents in California, and specifically in this
7 judicial district. UEI does business in this judicial district relating to UEI’s accused
8 products, and has an office located in this district at 201 E. Sandpointe Ave., Santa
9 Ana, CA 92707. On information and belief, each of UEI’s foreign subsidiaries is
10 subject to specific jurisdiction in this district at least because each of them
11 manufactures for import and imports into the United States and particularly into this
12 District, remote control devices and associated products that infringe Roku’s patents,
13 and, on information and belief, each of them conducts business with parent company
14 UEI related to the infringing technology at UEI’s offices at 201 E. Sandpointe Ave.,
15 Santa Ana, CA 92707.
16 14. Venue is proper in this district pursuant to 28 U.S.C. §§ 1391(b),
17 1391(c) and 1400(b).
18 THE PATENTS-IN-SUIT
19 15. On February 19, 2013, United States Patent No. 8,378,875, entitled
20 “Method of Programming a Universal Remote Control,” was duly and legally issued
21 by the United States Patent and Trademark Office. A copy of the ’875 Patent is
22 attached hereto as Exhibit A.
23 16. On June 17, 2008, United States Patent No. 7,388,511, entitled “System
24 for Remote Control of Identical Devices,” was duly and legally issued by the United
25 States Patent and Trademark Office. A copy of the ’511 Patent is attached hereto as
26 Exhibit B.
27 17. Roku is the owner of all right, title and interest in and to the ’875
28 and ’511 Patents, including the right to all remedies for infringement thereof.
4
COMPLAINT FOR PATENT INFRINGEMENT Case No. 8:21-cv-00658
Case 8:21-cv-00658 Document 1 Filed 04/08/21 Page 5 of 10 Page ID #:5
1 controls that need to be set up by the user in order to be operable to control the target
2 devices. The ’875 Accused Products contain components, including executable code,
3 that specifically implement the claimed methods for setting up the remote controls.
4 Indeed, these components are especially built to perform the accused functionalities.
5 23. Representative claim charts demonstrating UEI’s infringement of the
6 ’875 Patent is attached hereto as Exhibits C through F.
7 24. The ’875 Accused Products include at least the following remote
8 controls: URC 6420 OFA Simple 2; URC 7140 OFA Essence 4; URC 8200 Slate;
9 Videotron Illico Remote; URC 6820 OFA Zapper+; URC 7115 OFA Evolve TV; URC
10 7125 OFA Evolve 2; URC 7145 OFA Evolve 4; URC 7880 OFA Smart Control 8
11 (US); URC 7980 OFA Smart Control 8; URC 7935 OFA Streamer Remote; URC 7955
12 OFA Smart Control 5; URC 6410 OFA Simple TV; URC 2020BC2 Champ; URC
13 2020B0 Champ; URC 2025B1 Champion; URC 2025B2 Champion; URC 2025B1-
14 BB Eclypse; URC 2025B2-BB Eclypse; URC 2060 Charter; URC 2060B0 Royal;
15 URC 2068 Pulse RF; URC 2069 Pulse IR; URC 2125 Champion Plus; URC 2125
16 Rogers; URC 2135 Experience; URC 2135 UEI WOW! Experience Remote; URC
17 2464 Optimum; URC 6800 Proton; URC 6810 Neutron; URC 7110 OFA Essence TV;
18 URC 7120 OFA Essence 2; URC 7130 OFA Essence 3; URC 8820 Cox; URC 1160
19 Charter Spectrum; URC 2220 Cox Mini IR; URC 3220 Cox Mini RF; URC 1035
20 Universal A/C Remote.
21 25. UEI has been on notice of the ’875 Patent and of its infringing conduct
22 since at least the filing of this Complaint and the filing of the Complaint in In re
23 Certain Televisions, Remote Controls, and Components Thereof in the U.S.
24 International Trade Commission on April 8, 2021.
25 26. Roku has been, is being, and will continue to be injured and has
26 suffered, is suffering, and will continue to suffer injury and damages for which it is
27 entitled to relief.
28
6
COMPLAINT FOR PATENT INFRINGEMENT Case No. 8:21-cv-00658
Case 8:21-cv-00658 Document 1 Filed 04/08/21 Page 7 of 10 Page ID #:7
1
2 COUNT II: INFRINGEMENT OF THE ’511 PATENT
3 27. The foregoing paragraphs are incorporated by reference as if fully
4 restated herein.
5 28. On information and belief, UEI infringes the ’511 patent directly and
6 indirectly, literally and/or under the doctrine of equivalents.
7 29. On information and belief, UEI directly infringes at least claim 5 of the
8 ’511 patent when UEI or those acting on UEI’s behalf perform the claimed method
9 during testing or demonstration of products, including LG and Samsung televisions,
10 that incorporate UEI’s QuickSet technology (“the ’511 Accused Products”).
11 30. UEI also induces infringement of the ’511 Patent under 35 U.S.C.
12 § 271(b) since at least the date of service of this Complaint by actively aiding and
13 abetting others (including, for example, LG and Samsung, and their respective
14 customers and end users) whose use of the ’511 Accused Products constitutes direct
15 infringement. UEI has engaged in these actions with either the specific intent to cause
16 infringement or with willful blindness to the infringement that it is causing. For
17 example, UEI actively induces its customers, including at least LG and Samsung, to
18 directly infringe at least claim 5 of the ‘511 Patent by selling or licensing UEI’s
19 QuickSet technology for use with its customers’ products and associated remote
20 controls and providing instructions and technical support regarding use of the
21 QuickSet technology, where the use of those products infringes at least claim 5 of the
22 ‘511 Patent.
23 31. Representative claim charts demonstrating UEI’s infringement of the
24 ’511 Patent are attached hereto as Exhibits G and H.
25 32. The ’511 Accused Products include at least the following LG
26 televisions that incorporate UEI’s QuickSet technology and their associated remote
27 controls: LG NanoCell 80 Series 2020; LG NanoCell 81 Series 2020; LG NanoCell
28 85 Series 2020; LG NanoCell 90 Series 2020; LG NanoCell 91 Series 2020; LG
7
COMPLAINT FOR PATENT INFRINGEMENT Case No. 8:21-cv-00658
Case 8:21-cv-00658 Document 1 Filed 04/08/21 Page 8 of 10 Page ID #:8
1 35. Roku has been, is being, and will continue to be injured and has
2 suffered, is suffering, and will continue to suffer injury and damages for which it is
3 entitled to relief.
4 PRAYER FOR RELIEF
5 WHEREFORE, Roku prays for judgment in its favor against UEI granting
6 Roku the following relief:
7 A. Entry of judgment in favor of Roku that UEI has directly and/or
8 indirectly infringed the ’875 and ’511 Patents;
9 B. An award of compensatory damages in an amount to be determined,
10 amounting to no less than reasonable royalties, prejudgment interest, and/or any other
11 available damages based on any form of recoverable economic injury sustained by
12 Roku as a result of UEI’s infringement, as provided by 35 U.S.C. § 284;
13 C. An award of UEI’s profits from its patent infringements pursuant at
14 least to 35 U.S.C. § 289, together with prejudgment interest and costs and reasonable
15 attorney fees, pursuant at least to 35 U.S.C. §§ 284 and 285;
16 D. A permanent injunction against UEI and its officers, directors,
17 employees, agents, consultants, contractors, suppliers, distributors, and all others
18 acting in concert or privity with UEI from further infringement of the Patents-in-Suit;
19 E. If an injunction is denied, an order that UEI pay an ongoing royalty in
20 an amount to be determined for any continued infringement after the date judgment
21 is entered;
22 F. Treble damages to the extent permissible by law, as provided by 35
23 U.S.C. § 284;
24 G. To the extent it is determined that this is an exceptional case, an award
25 to Roku for its expenses, disbursements, and reasonable attorney’s fees, as provided
26 by 35 U.S.C. § 285 and all other applicable statutes, rules, and common law;
27 H. Roku’s costs of suit;
28 I. An award of pre-judgment and post-judgment interest at the maximum
9
COMPLAINT FOR PATENT INFRINGEMENT Case No. 8:21-cv-00658
Case 8:21-cv-00658 Document 1 Filed 04/08/21 Page 10 of 10 Page ID #:10
EXHIBIT A
Case 8:21-cv-00658 Document 1-1 Filed 04/08/21 Page 2 of 13 Page ID #:12
US008378875B2
ENERENE:Fisc
-3
st Offes to
ry URC buttons
TERAKNTRAL COOSETS
INSE
Select a 2Leval"Set of
Does the 3 Code-Sets arid Re-Start
Iteratic of 12 tefatiis.
CodeSets
Being {: a
"Tsvei
tsaics?
DVD
Philips: 0392, 1253, 5547, Sanyo: 5661
2236,
4587, 4566, Sony: 0023,0024, 2566,
5689, 6588 4456
Philco: 5689, 4566
FIG. 1
FIG. 2
Case 8:21-cv-00658 Document 1-1 Filed 04/08/21 Page 4 of 13 Page ID #:14
FIG. 3
Philips 9375 (an actual pointer to a Samsung 9973 (an actual pointer to a
list of codesets) list of CodeSets)
Pioneer 9376 (an actual pointer to a Sony 9876 (an actual pointer to a
list of Codesets) list of COdesets)
FIG. 4
Case 8:21-cv-00658 Document 1-1 Filed 04/08/21 Page 5 of 13 Page ID #:15
FIG. 6
Case 8:21-cv-00658 Document 1-1 Filed 04/08/21 Page 7 of 13 Page ID #:17
KEYECAR
RCESSCR aris fitter
ECRY
(including
jatabase
2O
RECE
CNRC
FIG. 7
Case 8:21-cv-00658 Document 1-1 Filed 04/08/21 Page 8 of 13 Page ID #:18
US 8,378,875 B2
1. 2
METHOD OF PROGRAMMINGA continuing auto-scan when it finds a Sub-optimal code-set, i.e.
UNIVERSAL REMOTE CONTROL Some functions/codes are missing or not working properly, is
tedious.
BACKGROUND OF THE INVENTION The methods 1 and 2 are disclosed in U.S. Pat. No. 6,344,
817 B1.
1. Technical Field 3. Brand-search (further referred to as method 3).
The present invention generally relates to a Universal Using Brand-search the user has to enter a brand-id (in
remote control (URC). Moreover the present invention relates stead of a code-set-id) and choose the device-type he wants to
to a method of programming an URC, e.g., by using brand find IR-codes for. There is a magic key-press to start this
and code-set identifiers. 10 procedure. Then the user types the ID of the brand of his CE
2. Description of Related Art equipment and presses the device-button (TV, DVD. Sat,
Multiple ways exist how a user can configure a Universal AMP). Then an auto-scan starts, but only for the code-sets for
Remote Control (URC) or another device with URC func that certain brand (not for all brands as in auto-scan).
tionality to work with his CE equipment (like TV. Amps, The main advantage is that this is a lot quicker then auto
DVD-players, ...). Most URCs actually offer a multitude of 15 Scan. The drawback is that a manual is needed to look up the
ways to do this. The goal of all these methods is to help the brand-ids, although it is briefer than the manual needed for
user to easily find the best-matching IR code-set (set of IR method 1. Another big drawback is that for all brands the
codes) for the URC to control the CE equipment. Finding that URC needs to keep a reference to all the code-sets for a certain
best-matching code-set is not easy due to the high number of brand/device-type combination. This consumes a lot of Stor
possible code-sets for a certain Brand/Device combination. age space. For that reason often only the bigger brands are
E.g. for Philips TVs a user has to pick one of 10-15 code-sets. supported for this mechanism. If the right brand is not in this
The most popular ways of configuring that URC are listed list, the user is referred to method 1 or 2. As explained herein
below. All have drawbacks as described. above, in case of method 1, a bigger manual is needed. Also
1. Enter a code-set from the manual (further referred to as the user has to try multiple methods that all work different and
method 1). 25 therefore needs to read through many pages of the manual
The user uses the manual to look up a combination of before he successfully can configure his URC. The user has to
Brand and Device-type (e.g.TV, DVD, ...). It is possible that select the correct method to be used, which may be confusing.
the universal aspect of the remote is limited to just one Another disadvantage is that brands that are not in the list
Device-type, often TV. There he finds a list of code-set-ids he of supported-brands will never work. Users will have to revert
needs to punch in on his URC. Often these code-set-ids con 30 to method 1. FIG. 2 shows a part of the manual that the user
sist of 3 to 5 digits (seemingly random). Before entering the uses to look up the brand-ids. This table is much shorter than
first code-set-id, the user needs to press some magic’ com the table for method 1 since it only contains the brand-ids for
bination of keys (or a special) key to go to programming the top brands. The Philco and Sanyo brands are not inhere to
mode. After having entered the first code-set-id, the user can save space on the URC's storage. Inside this storage there is
try out the codes of the installed IR code-set to verify if that 35 another table that links the brand-ids per device-type to the
works on his CE equipment. If the user isn't happy (since list of code-sets that brand-search will iterate through. This is
Some codes are not working, or he sent the wrong code), he shown in FIG. 3. Brands that are introduced after the produc
can use the programming mechanism to enter another code tion of the remote will never be covered using brand-search.
set-id and try again. When new brands appear on the market, a software update of
The main drawback of this scenario is that it’s tedious for 40 the URC is needed. Also in case there is a new code-set-id for
a user to enter the code-set-id digits and try to find a code-set a given brand/device-type combination brand search does not
that works. Many will not have any effect on the equipment at work. Furthermore, brand-search assumes all brand and cor
all. Also this requires a pretty extensive list, that contains all responding brand-ids are fixed.
combinations of Brand/Device-types and their list of code It is an object of the invention to provide a URC with an
set-ids to be tried. This list may be in a manual or on a web site 45 easy setup while requiring limited memory resources. More
in the case that users get web support. The above is illustrated over it is an object of the invention to provide a setup method
in FIG. 1 that shows part of the URC's manual that a user uses for a URC that is easy for a user.
to look-up the Code-set-ids for the Brand/Device-type com
binations. SUMMARY OF THE INVENTION
2. Auto-scan (also known as auto-search, further referred to as 50
method 2) According to an aspect of the invention, a method is pro
Auto-scan makes it simpler for a user to find a code-set that vided for setting up a Remote Control. It comprises the steps
works. Here the user presses another magic combination of of entering a configuration mode, accepting an identifier
keys, optionally selects the device-type he wants to search entry, and Scanning though remote control code-sets. The step
for (i.e. By pressing the TV, or DVD button on his URC). 55 of scanning comprises: in case that the identifier entry is a
Then he presses a key to start auto-scan. In some variants he brand-identifier, iterating through the remote control code
has to keep a certain button pressed. The URC starts iterating sets corresponding to the brand and testing said remote con
through all code-sets for the selected device and sends one or trol code-sets, and in case that the identifier-entry is a code
more IR-functions in the code-set (often Power-toggle or set-identifier: testing the remote control code-set
Power-off) to the equipment. As soon as the CE device reacts 60 corresponding to the code-set-identifier.
(by either turning off, on, or any other response to the IR-code This allows making the configuration of a URC simpler for
sent), the user presses a button (or releases a button he was a user. At the same time it makes producing the so created
holding). Now he can try if the other keys work as well, or simpler URC cheaper for the manufacturer because there is
have a mechanism to restart auto-scan trying to find another no additional need for electronic storage and the instructions
code-set that works better. 65 for use (e.g. manual) can be kept a lot Smaller.
The main drawback of this auto-scan it that it can take a The main improvement is to combine the Brand-id (as
long time for the URC to find a working code-set. Also used in the Brand-search method) with the Code-set-id (as
Case 8:21-cv-00658 Document 1-1 Filed 04/08/21 Page 9 of 13 Page ID #:19
US 8,378,875 B2
3 4
used in the manual code-set-id selection method). To the a wild card (e.g. "0000) may be selected that will scan
user all these ids appear to be Brand-ids; some of these ids through all code sets. Preferably, the code sets of minor
are actual Brand-ids (referring to a pre-programmed list of brands with the highest likelihood are first scanned through.
code-set-ids for a certain brand/device-type combination); According to a further embodiment the use of a numerical
others are actual code-set-ids. For brands/device-type com keyboard for entering a brand-identifier comprising letters is
binations that have only a low number of code-sets, or the first enabled. This brand identifier preferably is the name of the
code-set has a very high Success-rate, the user will punch in brand. In this way, the user can write the brand-identifier by
the code-set-id directly. This means there is no additional means of the numerical keyboard of the remote control in the
memory usage for making a pointer from a brand-id to code same way as writing SMS-messages using the numerical
set-ids. In technical terms the notion of code-set-ids and 10 keyboard of his mobile phone. Since most users have expe
brand-ids still exists, but this is made invisible to the user. rience in writing SMS-messages, this results in a very com
There might be a numbering convention to distinguish prehensible way of entering the brand identifier.
between brand-ids and code-set-ids (e.g. all brand-ids start According to a further aspect of the invention another
with 8 or 9). method for setting up a Remote Control is provided. It com
The method according to the present invention has numer 15 prises the steps of entering a configuration mode, Scanning
ous advantages: though remote control code-sets, testing if individuals keys of
Within the same memory constraints, the Brand-search can a code set send correct codes and receiving user-feedback on
be extended to ALL brands, not a small subset of popular the correct and/or incorrect working of the tested keys, replac
brands. ing non-working codes by codes from at least a further remote
It is easier for a user, since there is no fallback scenario control code-set, combining codes from the remote control
from Brand-search to Auto-scan or manual Code-set-id selec code-sets and storing them for use by the remote control. So,
tion needed, anymore. a number of remote control code-sets are combined into a
There is no need for an extensive manual as needed for the single remote control code-set. The single remote control
Code-set-id selection method (method 1). It makes configu code-set is installed in the remote control. This is very prac
ration of URC functionality easier for users. 25 tical if there are multiple code-sets that trigger a reaction on
In the method according to the invention by only changing the equipment to be controlled but also comprise a few codes
the instructions for use, almost all brands can be supported. In that do not work.
case that a new brand appears, the instructions for use should According to an embodiment codes from the same remote
reflect this new brand by means of the code-set-id of the basic control code-set are assigned to keys belonging to a certain
IR-code-set that it uses. To the user this code-set-id appears to 30 key-group. In practice it is very likely that if one key of a
be the brand-id of the new brand. This assumes that this basic certain keygroup works, all keys will work if their functions
IR-code-set is already in the IR-Database (which is often the are taken from the same IR-codeset. This will speed up the
case). set-up of the remote.
According to an embodiment of the invention, the iteration According to a further embodiment based on the testing
through remote control code-sets corresponding to the brand 35 step the user-feedback is used to limit or extend the set of
continues until a user approval of a remote control code-set is remote control code-sets that are scanned through. For
entered or until all the remote control code-sets correspond example, if the user feeds-back that a certain button is or isn't
ing to the brand have been tested. In this way, the Success rate working, this information can be used to remove codesets
of finding a working remote control code-set for the brand is from the set of codesets that haven’t been iterated through,
made as high as possible. If the user approves of a certain 40 yet. This will speed up the set-up of the remote.
remote control code-set, it is installed into the remote control. Preferably, the method according to the invention is imple
Preferably, the step of testing a remote control code-set mented by means of a computer program.
comprises the steps of sending a remote control signal of the According to a further aspect of the invention a remote
remote control code-set (preferably power toggle or power control is provided comprising memory means storing brand
on/off), checking for a user reaction, and in case of a user 45 identifiers pointing to a list of code set-identifiers for the
reaction, enabling the user to test keys of the Remote Control brand and storing single code set-identifiers which are not
for the remote control code-set. So, first a limited test of the pointed to by a brand-identifier.
code-set is performed sending one or a few codes. If this/these According to a still further aspect of the invention a remote
code(s) work correctly, the user reacts, for example by press control is provided comprising:
ing a key of the remote control. He is then given the oppor 50 means for entering a configuration mode,
tunity to test also the other codes. This way of testing is very means for accepting an identifier-entry,
efficient, because the user only has to perform an extensive means for Scanning though remote control code-sets
test for the code-sets for which the first code(s) worked, wherein the means for Scanning are adapted for:
correctly. For the other code-sets no full test has to be per in case that the identifier entry is a brand-identifier,
formed. 55 iterating through the remote control code-sets corre
According to a further preferred embodiment of the inven sponding to the brand and testing said remote control
tion, a device type entry is accepted. In this way, the scanning code-sets,
can be limited to code-sets for a certain device type, thereby in case that the identifier-entry is a code-set-identifier:
Substantially reducing the time of the scanning process. testing the remote control code-set corresponding to
Because there is a small possibility that the brand-search 60 the code-set-identifier.
initiated by this method doesn’t result in a working URC, the According to a still further a further aspect of the invention
programming of the URC will automatically go to a further a remote control is provided comprising
scanning step where the remotes iterates through all back means for entering a configuration mode:
up code-sets for the selected device-type, if no working means for scanning though remote control code-sets,
code-set was found during the first scanning step. 65 means for testing if individuals keys of a code set send
In order to shorten the user manual by taking out the minor correct codes and receiving user-feedback on the correct
brands, or to allow new brand names with existing codes sets, and/or incorrect working of the tested keys,
Case 8:21-cv-00658 Document 1-1 Filed 04/08/21 Page 10 of 13 Page ID #:20
US 8,378,875 B2
5 6
means for replacing non-working codes by codes from at Steps to Configure a URC Using a Preferred Method of the
least a further remote control code-set, Invention.
means for combining codes from the remote control code The User Interaction can resemble a typical Brand-search
sets and storing them for use by the remote control. approach. The steps are shown in FIG.5 and may actually be
in a different order in different embodiments. The different
BRIEF DESCRIPTION OF THE DRAWINGS steps are described below.
The user starts the configuration mode of the URC (step 1).
The invention will be better understood and its numerous There may be different mechanisms to do this, such as press
objects and advantages will become more apparent to those ing a setup-key for a longer time, or by means of a magic
skilled in the art by reference to the following drawing, in 10
key-press where different buttons are pressed simultaneously.
conjunction with the accompanying specification, in which: If the remote is universal for more than one Device-type,
FIG. 1 shows entries for a code-set from a user manual
according to the prior art. the user selects the Device-type he wants to setup the URC for
FIG.2 shows apart of a manual that the useruses to lookup (step 2). This could be TV. VCR, DVD. Sat, Amp, . . . as
the brand-ids according to the prior art. 15 supported by the URC. This step is optional.
FIG.3 shows a table that links brand-ids per device-type to Alternatively, the device type is not selected and the scan
a list of code-sets that a brand-search will iterate through ning process described herein after includes code sets for all
according to the prior art. device types for which the URC is suitable. Note that this
FIG. 4 shows an example of a table with actual pointer to a selection may be combined in step 1 if the magic key-press
list of code-sets. contains the button for the device-type to be configured.
FIG. 5 shows steps to configure a URC using a preferred The user looks up the Brand-id or the single code-set-id in
method. the instructions for use of the remote and enters it on the URC
FIG. 6 shows steps to configure a URC using a further (step 3). As explained herein above, to the user all these ids
preferred method. appear to be Brand-ids. Optionally a LED may be used to
FIG. 7 shows a block diagram of a remote control suitable 25 confirm the Successful or unsuccessful acceptance of the
for implementing the present invention. entered digits. Optionally there is an id to press if the Brand is
Throughout the figures like reference numerals refer to like unknown or not in the list (e.g. 0000, a so called “wildcard').
elements. The user starts the scanning process (step 4). They may be
implemented by pressing a button on the URC or by pressing
DETAILED DESCRIPTION OF THE PRESENT 30 & holding a button.
INVENTION The URC determines the code-sets to iterate through (step
5). If the entered ID was a pointer to a set of code-sets, the
The table of FIG. 4 shows an example of a table with actual software iterates through all these codesets (step 6). If the ID
pointers to a list of code-sets. Ids starting with a 9, the brand was a specific Code-set-id only, the list will only contain that
ids, (Philips, Pioneer, Samsung, Sony) are actually a pointer 35 single Code-set and proceed (step 6). During the iteration, the
to a list of code-set-ids for a certain brand/device-type com URC sends a specific (or multiple specific) IR-functions per
bination. All other ids (Philco, Sanyo) are actually single code-set (step 7). In step 8 it is checked if there is a user
code-set-ids. The digit convention is just to illustrate the reaction. If there is no user reaction, the algorithm waits a
invention. For the user there is no difference between the certain time. Then it is checked if the iteration through the
brand-ids and the single code-set-ids, the URC's software 40 code-sets is finished (step 11). If this is not the case the
handles the two different kinds of ids. iteration is continued (step 6). The next code-set is retrieved
For Philips the software-algorithm will look up the code and a specific (or multiple specific) IR-functions is/are sent.
sets to use by using the brand-scan process in the Software. When there is a user reaction (by pressing a key or by releas
For Philco it will only use Code-set-id 5689. Another Philco ing the pressed key) or when the last IR-code is sent, the
code-set-id (4566) will not be used since it is very unlikely to 45 iteration stops.
be the correct code-set anyway. If the user reacted, he is (optionally) offered to try the
Another advantage of this approach is that because the buttons of the URC for the selected code-set (step 9). Steps 7.
actual code-set-ids can be entered in the setup, it is possible 8 and 9 together form the step of testing said remote control
for the user to type in the correct code-set in one go. This code-sets.
allows the support of brands that were not in the brand-list at 50 In step 10 the user indicates if he accepts the current remote
the time the remote was produced, but use a code-set that is control code-set or not. If the user accepts, then the algorithm
already available in the Database. In that case the instructions stops and the user approved code-set is installed (step 14). If
for use should beamended accordingly or the helpdesk could the user doesn’t accept, the scanning process is continued by
instruct the user which ID to enter. In case that a new brand going to step 11.
appears, the instructions for use should reflect this new brand 55 In step 12 the algorithm checks if the iteration, that was
by means of the code-set-id of the basic IR-code-set that it finished in step 11, was an iteration of code sets belonging to
uses. To the user this code-set-id appears to be the brand-id of a brand (“first level iteration). If so, the algorithm proceeds
the new brand. This assumes that this basic IR-code-set is to step 13. This means that no code-set was found by iterating
already in the IR-Database (which is often the case). through the available code-sets. In step 13 a “second-level
The instructions for use may be in the form of a paper 60 set of code sets is selected and the iteration is re-started. This
manual or in electronic form for example on a user Support second-level set could for instance consist of a list contain
web site. ing 1) all Brands for the device-type and/or 2) a list of back-up
This approach works best if the remote control is universal code-sets known to be likely candidates. Then the algorithm
for only one device-type (i.e. TV), which is the majority. In continues with this new list to iterate through at step 6.
other cases a different brand-list should be present in the 65 If in step 12 the algorithm determines that the iteration, that
instructions for use for each device-type. Alternatively, a was finished in step 11, was a second-level iteration, the
single list could be used for all device types. algorithm stops without installing a code-set (step 15).
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US 8,378,875 B2
7 8
Alternative Embodiments What IR-codes are actually sent-out depend on the
In a different embodiment, the invention may be used to progress in the algorithm. It may be a preconfigured IR-code
set-up the URC-functionally of a set-top box, PVR, .... This or an IR-code for which the user indicated that it didn't work
may happen when the set-top-box controls other devices like (see step 78).
a Satellite or cable receiver. 6. The algorithm checks for a user reaction (indicating a
Instead of IR-codes, the idea can also be applied to RF sent IR-code triggers some function on the target device).
codes. This reaction is often the press (or release) of a key (step 76).
SMS-Keyboard Entry of the Brand When the user doesn’t react, the algorithm continues at
In the description above, the Brand-id is represented as an 10
step 74. When the user does react, the algorithm continues at
X-digit code (X 4 in the examples). This always requires step 77.
lookup in the manual. To make it even easier the SMS-key 7. Assume that code-set i is selected. Keys that previously
board can be used instead. On a GSM phone the 2 key also werent associated with an IR-code or were indicated to be
has the letters ABC assigned, 3 has DEF. The SMS associated with non-working IR-codes, will be associated
keyboard is a way to compose words using the numerical 15 with IR-codes from code-set i (Step 77).
keypad as found on phones. Because on remotes the same 8. The user can now try pressing the keys on the URC to test
keyboard is used (so these letters are also printed on the digit if they work as expected (step 78). He has means to indicate
keys), it is possible to perform similar composing. whether the keys function correctly or not.
Assuming the single-tap SMS keyboard, one can spell P In different embodiments the way to indicate that differs. In
HILIPS as: 7445477 (so each digit once), Sony becomes a preferred embodiment the algorithm assumes all keys work
7669, etc. Alternatively, the use of multi-tap is possible: OK unless the user keeps the key pressed. In other embodi
PHILIPS becomes 74.4444. 555 4447 7777. (3 taps of the ments the user can, after pressing a key, press a thumbs-up or
7 key generate the 3-rd letter R (the 7 key also refers to thumbs-down key to indicate if the previous key sent the
PQRS). LED-lights may be used to communicate a user that correct command. Or alternatively, each key has a green and
the entry of a brand was successful or not. Whether to use 25 red backlight. Red means that the key doesn’t work, green
single-tap, multi-tap or any other variation is not relevant for means that it does. Many alternatives can be conceived of
the present invention. If the user is happy with the result, he can choose to end the
Any number of digits is allowed, but its possible to cap the algorithm and store the current code-sets. (step 80).
maximum number of digits. In case of overlap (two different 9. The algorithm determines if the user indicated if a key
brands result in the same digit-sequence), a resolution can be 30 doesn’t work (step 79). If the user indeed indicates a key
to concatenate the list of Code-sets for both brands and iterate doesn’t work continue at step 74 (now taking into account the
through these all in the scan process. user's feedback for working and non-working keys), other
The SMS-keyboard entry of the brand may be used with the wise return to step 78.
method as described with reference to FIG. 5 but also with the 10. When the user is satisfied with all keys after step 77, the
prior art method Brand-search (method 3). 35 algorithm stops (step 80). It installs IR-codes from one or
Combine IR Codes from Different Code-Sets During the more IR-codesets.
Scan Process. Optionally, the user can indicate that he's still not happy
Often, the Scanning process will find multiple code-sets with the current results and wants to start from scratch. In that
that trigger a reaction on the CE equipment. This is because case the user can jump to step 73 after indicating this.
there can be overlap between multiple code-sets. I.e. for code 40 In an alternative embodiment of this algorithm, key-groups
set X the Power, digits and Teletext works ok, but volume are taken into account. This means that all keys that logically
does not, while for code-set Y the Power, digits and volume belong together will always be using IR-codes from the same
work but Teletext does not. In this case it’s very practical IR-codeset. For example, the Volume keygroup consists of
when a user can indicate for a given matching code-set which volume up, volume down and mute. The teletext key
codes do work and/or which codes do not. The URC can track 45 group consists of all keys controlling teletext modes, the
this and combine the working codes of multiple code-sets into digits keygroup consists of all digits. In practice it is very
a new custom configuration code set, which contains func likely that if one key of a certain keygroup works, all keys will
tions from multiple code-sets. work if their functions are taken from the same IR-codeset.
The Scanning process is depicted in the flowchart shown in This will speed up the set-up of the remote.
FIG 6: 50 According to an alternative embodiment, the algorithm
1. Start the set-up process, e.g. by pressing the right may abandon the concept of the keygroups in the following
(magic) key (-combination). At this time none of the keys will situation: if the first key of a keygroup works but the second
have associated IR-codes (step 71). (or Subsequent) key of the key group does not work. In that
2. Optionally select the device-type and optionally select case, the algorithm treats all keys in the keygroup, individu
the brand (step 72). This can be done in either order and may 55 ally which means that the keys from the keygroup may use
in practice be combined with step 71. codes from different IR-code sets.
3. The algorithm determines what Code-sets may work for It is also possible to use the given feedback in steps 77 and
the user's device. Suppose there are N different Code-sets 78 to limit or extend current set of remote control codesets
selected. These set of code-sets will be iterated through, start while the algorithm is running. For example, when in step 78
ing with the first (step 73). 60 the user feeds-back that a certain button is or isn't working,
When the users indicates so (by pressing (and holding) a this information can be used to remove codesets from the set
key) continue to next step. of codesets that haven’t been iterated through yet. So if the
4. The algorithm iterates through the next Code-set (step user would indicate that the volume up IR-code isn't work
74): Codeset X where x ranges from 1 to N. ing the remote-control can omit trying another codeset with
5. For each Code-set in the iteration, the algorithm sends 65 that same IR-code for the volume up function. Also when the
one or more IR-code(s) and wait some time to give the user user would indicate that the program down function would
the chance to react (step 75). be correct this information can be used.
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US 8,378,875 B2
10
The combination of IR codes from different code-sets may in case of a user reaction, enabling, via the processor,
be used with the method as described with reference to FIG. memory, and transmitter, to test keys of the Remote
5 but also with the prior art methods “Autoscan' (method 2) Control for the remote control code-set.
and Brand-search (method 3). 5. The method according to claim 1, further comprising the
FIG. 7 shows a block diagram of a remote control 20 step of accepting, via the keyboard and processor, a device
suitable for implementing the present invention. Only the type entry.
relevant components are shown. The remote control 20 com 6. The method according to claim 1, wherein if no user
prises a processor 30, a keyboard 40, an IR or RF transmitter approval of a remote control code set has been entered, via the
50 for transmitting control codes and a memory 60. The keyboard, during the step of scanning, a further scanning step
invention is preferably implemented by a suitable computer 10 is performed, scanning through further remote control code
program stored in memory 60, which is run by processor 30. SetS.
The brand-identifiers and code-set identifiers are also stored 7. The method according to claim 1, further comprising
in the memory 60. enabling, via the processor and memory, the use of a numeri
As will be recognized by those skilled in the art, the inno cal keyboard for entering a brand-identifier comprising let
Vative concepts described in the present application can be 15 ters.
modified and varied over a wide range of applications. 8. The method according to claim 1, wherein a numbering
Accordingly, the scope of patented Subject matter should not convention is used to distinguish between brand-identifiers
be limited to any of the specific exemplary teachings dis and code-set-identifiers.
cussed, but is instead defined by the following claims. Any 9. The method according to claim 1, wherein the identifier
reference signs in the claims shall not be construed as limiting entry is a “wild card’ code, and upon detecting, via the pro
the scope. cessor and keyboard, that the “wild card’ code is entered,
scanning further comprises iterating through all code sets for
The invention claimed is: at least a device type.
1. A method for setting up a Remote Control that includes 10. A non-transitory computer-readable medium embod
a keyboard, a processor, a memory, and a transmitter, the 25 ied with a computer program that comprises computer pro
method comprising the steps of gram code executable by a processor to perform the steps of
entering, via the keyboard and processor, a configuration setting up a Remote Control of claim 1.
mode; 11. A method for setting up a Remote Control that includes
accepting, via the keyboard and processor, an identifier a keyboard, a processor, a memory, and a transmitter, the
entry; and 30 method comprising the steps of
Scanning, via the processor and memory, though remote entering, via the keyboard and processor, a configuration
control code-sets in a database stored in the memory of mode:
the Remote Control, wherein the step of Scanning com scanning, via the processor and memory, though remote
prises: control code-sets in a database stored in the memory of
in case that the identifier-entry is a brand-identifier that 35 the Remote Control;
identifies a brand, (i) iterating, via the processor and testing, via the keyboard, if individuals keys of a code set
memory, through the remote control code-sets corre send, via the transmitter, correct codes and receiving, via
sponding to the brand and (ii) testing said remote the keyboard, user-feedback on the correct and/or incor
control code-sets by sending, via the transmitter, to a rect working of the tested keys;
Consumer Electronic device for a given iteration, one 40 replacing, via the processor and memory, non-working
or more specific control code functions of a corre codes with codes from at least a further remote control
sponding remote control code-set, and code-set; and
in case that the identifier-entry is a code-set-identifier combining, via the processor and memory, correct working
that identifies a single remote control code-set which codes from the Scanned remote control code-sets into a
in not pointed to by a brand-identifier, testing the 45 new custom configuration code set and installing, via the
single remote control code-set corresponding to the processor and memory, the combined correct working
code-set-identifier by sending, via the transmitter, to codes of the new custom configuration code set for use
the Consumer Electronic device one or more specific by the remote control.
control code functions of the corresponding single 12. The method according to claim 11, where codes from
remote control code-set. 50 the same remote control code-set are assigned to keys belong
2. The method according to claim 1, wherein the iteration ing to a certain key-group.
through remote control code-sets corresponding to the brand 13. The method according to claim 11, where based on the
continues (i) until a user approval of a remote control code-set testing step, the user-feedback is used to limit or extend a
is entered, via the keyboard, or (ii) until all the remote control number of remote control code-sets that are scanned through.
code-sets corresponding to the brand have been tested. 55 14. Remote Control comprising:
3. The method according to claim 1, further comprising the means for entering a configuration mode;
step of checking, via the processor, memory, and keyboard, means for accepting an identifier-entry; and
for user approval of a remote control code-set and installing, means for scanning though remote control code-sets in a
via the processor and memory, the user approved remote database stored in a memory of the Remote Control
control code-set for use by the Remote Control. 60 wherein the means for Scanning are adapted for:
4. The method according to claim 1, wherein the step of in case that the identifier-entry is a brand-identifier that
testing a remote control code-set comprises the following identifies a brand, (i) iterating through the remote con
steps: trol code-sets corresponding to the brand and (ii) testing
sending, via the transmitter, a remote control signal of the said remote control code-sets by sending to a Consumer
remote control code-set; 65 Electronic device for a given iteration, one of more spe
checking, via the processor, memory, and keyboard, for a cific control code functions of a corresponding remote
user reaction; and control code-set; and
Case 8:21-cv-00658 Document 1-1 Filed 04/08/21 Page 13 of 13 Page ID #:23
US 8,378,875 B2
11 12
in case that the identifier-entry is a code-set-identifier that means for testing if individuals keys of a code set send
identifies a single remote control code-set which is not correct codes and receiving user-feedback on the correct
pointed to by a brand-identifier, testing the single remote and/or incorrect working of the tested keys;
control code-set corresponding to the code-set-identifier means for replacing non-working codes with codes from at
by sending to the Consumer Electronic device one or least a further remote control code-set; and
more specific control code functions of the correspond means for combining correct working codes from the
ing single remote control code-set. Scanned remote control code-sets into a new custom
15. Remote Control comprising: configuration code set and for installing the combined
means for entering a configuration mode; correct working codes of the new custom configuration
10 code set for use by the remote control.
means for scanning though remote control code-sets in a
database stored in the memory of the Remote Control; k k k k k
Case 8:21-cv-00658 Document 1-2 Filed 04/08/21 Page 1 of 10 Page ID #:24
EXHIBIT B
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USOO73885.11B2
OUTPUT MEANs
Case 8:21-cv-00658 Document 1-2 Filed 04/08/21 Page 3 of 10 Page ID #:26
•
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a as a es a sad a as a as
z?V3N0IC1A0BHON.)
Case 8:21-cv-00658 Document 1-2 Filed 04/08/21 Page 4 of 10 Page ID #:27
MICRO
CONTROLLER
31
MICRO
MICRO- CONTROLLER
PROCESSOR
ROM
36 INPUT/OUTPUT
44
DISPLAY
45:
KEYPAD
am n- - is a n -- - - - - - -- ---- - - -- -- - -
FIG.3
Case 8:21-cv-00658 Document 1-2 Filed 04/08/21 Page 5 of 10 Page ID #:28
40 4.
4.
MICRO
PROCESSOR
42
•
=
•
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-
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-
INPUTIOUTPUT
36
FIG.4
Case 8:21-cv-00658 Document 1-2 Filed 04/08/21 Page 6 of 10 Page ID #:29
US 7,388,511 B2
1. 2
SYSTEM FOR REMOTE CONTROL OF the received user-specified command if said identifiers
IDENTICAL DEVICES do not match; an output means for Supplying the
user-specified command to the controllable device.
The invention relates to a system for remote control of at In this way, the system of the invention comprises the
least two controllable devices, the system comprising a coding device and the decoding device and allows control of
remote control device with communicating means for com identical devices. It is assumed that the controllable devices
municating to the controllable devices a user-specified com could be conventional controllable devices and are not
mand produced by the remote control device. necessarily identical.
The invention also relates to a method of remote control
of at least two controllable devices, the method comprising 10 There are many possibilities for implementation of the
the step of communicating a user-specified command to the system of the present invention. The coding and decoding
controllable devices. devices could be designed as devices which are not depen
An embodiment of such a system is known from U.S. Pat. dent on the implementation of the remote control device and
No. 5,748,263. controllable devices. Thus, the coding device includes
Well known remote control systems include consumer 15 receiving means for obtaining the command from the remote
electronics products, such as a television set (TV), video control device and could be manufactured as a separate
cassette recorder (VCR), which are remote-controllable device. Similarly, the decoding device includes transmitting
devices and can receive user commands produced by means means and may be separate from the controllable device. It
of a remote control device. Sometimes, such remote control is also supposed that the receiving and transmitting means of
systems involve two or more controllable devices, which the coding and decoding devices are Suitable to communi
may be identical. When the controllable devices are situated cate with the receiving and transmitting means of the remote
control device and controllable devices.
fairly close to each other, a signal of the remote control
device may reach not only the targed-controllable device, Another possibility for implementation of the system of
but also another controllable device. Both devices will the present invention may be to design the coding device and
receive the signal and respond to it. This situation may occur 25 the decoding devices in combination with the remote control
in the showrooms of shops, exhibition pavilions, studios device and the controllable devices, respectively. For
with professional electronics equipment, home theaters and example, the communicating means of the remote control
other places with controllable devices, like TVs, VCRs, device may be combined with the transmitting means of the
digital versatile disk (DVD) recorders, etc. coding device, and the communicating means of the con
It is known to communicate to a group of apparatuses by 30 trollable device may be combined with the receiving means
assigning unique addresses to the apparatuses and indicating of the decoding device.
these addresses at the apparatuses themselves. Conse The object of the invention is also realized in that the
quently, these apparatuses are unique and not identical. It is method of the invention comprises the further steps of:
also already known from U.S. Pat. No. 5,774,673 to com adding to the user-specified command a device identifier
municate between apparatuses with the help of using appli 35 for identification of at least one of the controllable
cations stored in these apparatuses. Thus, current remote devices;
control systems with a one-directional communication do transmitting the device identifier and the user-specified
not allow control of the identical remote-controllable
devices without using special Software, introducing any command;
differences or hardware changes into the identical appara 40 receiving the device identifier and the user-specified com
tuses or storing the unique pre-assigned addresses in said mand;
identical devices. extracting the device identifier; comparing said extracted
For many consumer electronics products, an infrared light device identifier with a further device identifier for
is commonly used as a carrier for wireless communication. identification of the controllable device; refraining
Thus, it is also necessary to develop a remote control system 45 from further operation with the received user-specified
that can be adapted to operate with the infrared devices. command if said identifiers do not match;
It is an object of the invention to provide a system for Supplying the user-specified command to the controllable
remote control of at east two controllable devices of the kind device.
defined in the opening paragraph, which will be able to The method of the invention describes steps of operation
identify identical controllable devices and control them 50 of the system for remote control of at least two controllable
independently of each other. devices.
The object of the invention is realized in that: These and other aspects of the invention will be further
the remote control device is equipped with a coding elucidated with reference to the accompanying drawings,
device comprising an input means for obtaining the wherein:
user-specified command from the remote control 55
device; a coding means designed to add to the user FIG. 1 shows an embodiment of the system and method
specified command a device identifier for identification of the present invention, block diagrams of the coding and
of at least one of the controllable devices; a transmit decoding devices and a general principle of operation of said
ting means adapted to transmit the device identifier and system;
the user-specified command; 60 FIG. 2 shows an embodiment of the system of the present
the controllable device is equipped with a decoding invention, in which a schematic diagram of the processor
device comprising a receiving means adapted to receive that could be embedded in the coding or decoding device is
the device identifier and the user-specified command; a shown:
decoding means designed to extract the device identi FIG.3 shows an embodiment of the system of the present
fier; to compare said extracted device identifier with a 65 invention, in which a schematic diagram of the remote
further device identifier for identification of the con control device and coding device with combined transmit
trollable device; to refrain from further operation with ting means is shown;
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US 7,388,511 B2
3 4
FIG. 4 shows an embodiment of the system of the present devices. In this case, the coding device may include receiv
invention, in which a schematic diagram of the controllable ing means for obtaining the user-specified command from
device and decoding device with combined receiving means the remote control device, and the decoding device may
is shown. include transmitting means for Supplying the user-specified
Referring now to the drawings, FIG. 1 shows an embodi command to the controllable device. However, there is a
ment of the system and method of the present invention. The requirement that said receiving means of the coding device
Figure shows the block diagram of the coding device 1 and can communicate with the transmitting means of the remote
the block diagram of the decoding devices 2 and 3 associated control device and said transmitting means of the decoding
with the controllable devices 4 and 5, respectively. The device can communicate with the receiving means of the
method of the invention and the general operation principle 10 controllable device.
of the system are also disclosed with reference to the FIG. In this way, the coding or decoding devices can be
1. realized as is shown in FIG. 2. The embodiment comprises
The remote control device 6 may have a number of keys, receiving means 30, transmitting means 31, a microcontrol
which generally include numerical keys, function keys and ler 32 and a clock 33. The microcontroller 32 has an
means 7 for selecting a device identifier associated with the 15 embedded random access memory 34 and an embedded
controlled device, like the controllable device 4 or 5. An read-only memory 35, which is used for program storage.
extra Switch on the remote control device or coding device The microcontroller 32 could implement the coding means
could implement said means for selection of the device of the coding device or the decoding means of the decoding
identifiers. The decoding devices 2.3 may include means 8.9 device. Depending on the first or second implementation, the
for setting further device identifiers associated with the coding means of the coding device or the decoding means of
controlled devices 4, 5. the decoding device can be realized. When the coding means
In FIG. 1, a selection between the device identifiers A, B is realized, an input/output function 36, the receiving means
and C is used as an example with the aim to explain the 30 and the transmitting means 31 are adapted to receive the
present invention. The device identifiers could be selected user-specified command from the remote control device and
independently in the coding and decoding devices. Thus, it 25 to transmit the user-specified command and selected device
is shown in FIG. 1 that the further device identifier A is identifier. When the decoding means is realized, the input/
selected in the coding device 1 and the further device output function 36, the receiving means 30 and the trans
identifier B is set in the decoding device 3. mitting means 31 are adapted to receive the user-specified
The remote control device 6 produces the user-specified command and the device identifier from the coding device
command 10. The coding device 1 comprises input means 30 and to transmit the user-specified command to the control
11, coding means 12 and transmitting means 13. Thus, the lable device. Additionally, the microcontroller 32 can be
coding device 1 may obtain the user-specified command 10 equipped with the display, the keypad and other communi
using the input means 11. Then, the coding means add to the cation means. The blocks in FIG. 2 are well known in the
user-specified command the selected device identifier, which prior art and are not further discussed herein.
can be assigned to the specific controllable device or a group 35 FIG.3 shows an embodiment of the system of the present
of the controllable devices. The transmitting means 13 of the invention, in which a schematic diagram of the remote
coding device 1 further transmit a signal 20 incorporating control device and coding device with a combined trans
the user-specified command and the device identifier to be mitting means is shown. FIG. 4 shows a schematic diagram
received by the decoding devices. of the controllable device and decoding device with a
The decoding devices 2, 3 comprise receiving means 14, 40 combined receiving means.
15, decoding means 16, 17 and output means 18, 19. The FIG. 3 shows the coding device comprising the coding
user-specified command and the device identifier 20 are means 12, the transmitting means 13 and a clock 43. The
being received by the receiving means 14, 15 of the decod microcontroller 32 has the embedded random access
ing devices 2, 3. Then the decoding means 16, 17 extract the memory 34 and the embedded read-only memory 35, which
received device identifier and compare it with the further 45 is used for program storage. The remote control device 6 can
device identifier, which identifies the associated controllable be realized with a microprocessor 40, a random access
device. The decoding means refrain from further operation memory 41, a read-only memory 42, the clock 43, a display
with the received user-specified command if said identifiers 44, a keypad 45 and the transmitting means 13. The remote
do not match. If the received device identifier and the further control device and the coding device could advantageously
device identifier, which identifies the associated controllable 50 share the transmitting means 13 and the clock 43. Both the
device, do match, the output means of the decoding device microprocessor 40 and microcontroller 32 can read the clock
further supply the received user-specified command to the 43. The transmitting means 13 is used for transmitting the
associated controllable device. user-specified command and the device identifier.
As is shown in FIG. 1, the further device identifier A is set The embodiment depicted in FIG. 4 comprises the con
in the decoding device 2 and the further device identifier B 55 trollable device and the decoding device with the combined
is set in the decoding device 3. The coding device 1 receiving means 14. Said decoding device comprises the
transmits the user-specified command with the device iden decoding means 16, the receiving means 14 and the clock
tifier A. In this connection, only the controllable device 4 43. The microcontroller 32 has the embedded random access
will receive the user-specified command 10 produced by the memory 34 and the embedded read-only memory 35, which
remote control device 6, because the further device identifier 60 is E for program storage. The controllable device 4 may
A is set in decoding device 2 but not in the decoding device comprise the microprocessor 40, the random access memory
3. 41, the read-only memory 42, the clock 43 and the receiving
FIG. 2 shows an embodiment of the system of the present means 14. The controllable device and the decoding device
invention with a schematic diagram of the processor that could advantageously share the receiving means 14 and the
could be embedded in the coding or decoding device. 65 clock 43. Both the microprocessor 40 and microcontroller
The coding and decoding devices can be implemented 32 can read the clock 43. The receiving means 14 is used for
separately from the remote control device and controllable receiving the user-specified command and the device iden
Case 8:21-cv-00658 Document 1-2 Filed 04/08/21 Page 8 of 10 Page ID #:31
US 7,388,511 B2
5 6
tifier. Further details of the internal design of the embodi in the decoding device. The device identifier could be
ments shown in FIGS. 3, 4 will be apparent to people skilled indicated in the coding device with the help of the means for
in the art. selecting the device identifiers, and in the decoding device
An alternative to having the microcontroller 32, which with the help of the means for setting the further device
can implement the coding or decoding means, is to build the identifiers associated with the controlled device. Various
coding and decoding functions directly into the program Switches, buttons, keys, other hardware realizations or pro
stored in the read-only memory 42. This would eliminate the gram products could implement these means for selecting
need for the microcontroller 32. Of course, other hardware and setting device identifiers.
to perform the coding or decoding functions may also be The invention makes it possible to control many control
used. 10 lable devices by using the one remote control device with the
The described system of the present invention allows means for selecting of the device identifiers. When each
cost-effective implementations with the additional advan device identifier is associated with the only one controllable
tages of using the infrared communication. The remote device, a user can select the associated device identifier at
control device may be the conventional remote control the remote control device and control this controllable
device producing infrared signals that are received by the 15 device independently of the rest of them.
controllable device. The controllable devices may include The remote control system of the present invention also
televisions, VCRs or other electronic appliances or devices allows the use of more than one remote control device
capable of receiving the infrared signals. Accordingly, the equipped with the coding device. It is also possible to use the
coding device may be designed to receive the infrared remote control devices equipped with the coding devices
signals produced by the remote control device. The infrared and the conventional remote control devices at the same
signals produced by the transmitting means of the decoding time in the system.
device can be adapted to transmit the same key characteristic The various program products may implement the func
(such as frequency and duration) as the infrared signals tions of the system and method of the present invention and
produced by the remote control device. Thus, said decoding may be combined in several ways with the hardware or
device can communicate with the controlled device in the 25 located in different devices. Variations and modifications of
same way as the conventional remote control device would the described embodiment are possible within the scope of
communicate with the controllable device. the inventive concept.
Other implementations, which provide similar functions, The invention claimed is:
could be substituted for the aforementioned implementa 1. A system for remote control of at least two like
tions without departing from the scope of the present inven 30
controllable devices, the system comprising:
tion.
The method of the invention describes steps of operation a) a remote control device comprising:
of the system for remote control of at least two controllable a remote control input means for inputting a user
devices: adding to the user-specified command a device specified command for controlling the controllable
identifier for identification of at least one of the controllable 35 devices; and
devices and transmitting the device identifier and the user a remote control transmitting means adapted to transmit
specified command. the user-specified command;
Obviously, different frame structures may be used to b) a coding device comprising:
compose a message including the device identifier and the a coding input means for receiving the user-specified
user-specified command. For example, a header incorporat 40 command from the remote control device;
ing the device identifier may be added to the message with a coding means designed to add to the user-specified
the user-specified command. Any digital, symbol or other command a device identifier for identification of at
format may be used for implementation of the device least one of the controllable devices;
identifiers. a coding transmitting means adapted to transmit the
The method further comprises steps being executed at the 45 device identifier and the user-specified command in
decoding device: receiving the device identifier and the combination;
user-specified command; then extracting the device identi c) the like controllable devices each comprising:
fier, comparing said extracted device identifier with a further a receiving means adapted to receive the device iden
device identifier for identification of the controllable device. tifier and the user-specified command in combina
The method provides the steps of refraining from further 50 tion;
operation with the received user-specified command if said a decoding means designed (1) to extract the device
identifiers do not match, and Supplying the user-specified identifier, (2) to compare said extracted device iden
command to the controllable device if the identifiers do tifier with a further device identifier for identification
match. of the controllable device, and (3) to refrain from
The steps of receiving and sending the user-specified 55 further operation with the received user-specified
command or the device identifier and user-specified com command if said identifiers do not match;
mand could be modified accordingly for the system of the an output means for Supplying the user-specified com
present invention. Thus, the step of Supplying the user mand if said identifiers do match;
specified command to the controllable device may comprise wherein the remote control device and the coding
a step of transmitting the user-specified command to the 60 device are separate devices which are selectively
controllable device. Also, the step of obtaining the user interconnectable and disconnectable, the remote
specified command from the remote control device may control device functioning to transmit the user-speci
comprise a step of receiving the user-specified command fied command to controllable devices when the cod
from the remote control device. ing device is disconnected and the coding device
Before the afore-mentioned steps, the device identifiers 65 functioning to transmit the user-specified command
have to be assigned to the associated controllable devices or when the remote control device and the coding
to the groups of the controllable devices and then indicated device are connected.
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US 7,388,511 B2
7 8
2. The system according to claim 1, wherein the device c) a decoding device comprising:
identifier added by the coding means is user-selected and the a decoding receiving means adapted to receive the
further device identifier to which the decoding means com combined device identifier and the user-specified
pares the extracted device identifier is user-selected. command from the coding device;
3. A system for remote control of a plurality of like a decoding means designed to (1) extract the device
controllable devices which are controllable with common identifier and (2) compare said extracted device
commands, the system comprising: identifier with a further device identifier for identi
a) a remote control device including: fication of an associated controllable device;
an input means for inputting a user-specified one of the an output means for Supplying the user-specified com
commands which control the plurality of like con 10 mand to the associated controllable device if the
trollable devices; identifiers match;
a coding means configured to add to the user-specified d) the controllable devices each comprising:
command a device identifier for identification of at a receiving means adapted to receive the user-specified
least a selected one of the controllable devices; command from an associated decoding device output
15 means,
a transmitting means configured to transmit the device a means for controlling the controllable device to carry
identifier and the user-specified command in combi out the user-specified command received by the coding
nation; device; and
b) a decoding device comprising: e) wherein at least one of:
a first receiving means configured to receive the device the remote control device and the coding device are
identifier and the user-specified command in combi separate devices which are selectively interconnect
nation; able and disconnectable, the remote control device
a decoding means configured to (1) extract the device functioning to transmit the user-specified command
identifier and (2) compare said extracted device to controllable devices when the coding device is
identifier with a user-specified device identifier for 25 disconnected and the coding device functioning to
identification corresponding to the controllable transmit the user-specified command when the
selected device; remote control device and the coding device are
an output means configured for Supplying the user connected; and
specified command to the corresponding controllable the decoding device and the controllable devices are
device if the identifiers match; 30 separate devices, the decoding device being selec
c) the controllable devices each comprising: tively connectable to one of the controllable devices,
a second receiving means configured to receive the when the decoding device is connected with the
user-specified command from the corresponding controllable device, the decoding device receives the
decoding device output means; transmitted device identifier and the user-specified
35 command in combination from the coding device
a means for controlling the controllable device to and when the decoding device is separate from the
implement each user-specified command received controllable device, the controllable device receives
from the decoding device; the user-specified command and the device identifier
wherein the decoding device and the controllable devices in combination from the coding device.
are separate devices, the decoding device being selec 40 5. A method for remote control of at least two like
tively connectable to one of the controllable devices, controllable devices, the method comprising:
when the decoding device is connected with the con a) with a remote control device,
trollable device, the decoding device receives the trans inputting a user-specified command for controlling the
mitted device identifier and the user-specified com controllable devices; and
mand in combination from the coding device and when 45 transmitting the user-specified command;
the decoding device is separate from the controllable b) with a coding device,
device, the controllable device receives the user-speci receiving the user-specified command from the remote
fied command and the device identifier in combination control device;
from the coding device. adding to the user-specified command a device identi
4. A system for remote control of a plurality of like 50 fier for identification of at least one of the control
controllable devices, the system comprising: lable devices;
a) a remote control device comprising: transmitting the device identifier and the user-specified
a remote control input means for inputting a user command in combination;
specified command for controlling the controllable c) with one of the like controllable devices,
devices; and 55 receiving the device identifier and the user-specified
a remote control transmitting means adapted to transmit command in combination;
the user-specified command; extracting the device identifier;
b) a coding device comprising: comparing said extracted device identifier with a fur
ther device identifier for identification of the con
a coding input means for receiving the user-specified 60 trollable device;
command from the remote control device; refraining from further operation with the received
a coding means designed to combine the user-specified user-specified command if said identifiers do not
command and a device identifier for identification of match; and
at least one of the controllable devices; Supplying the user-specified command if said identifi
a coding transmitting means adapted to transmit the 65 ers do match;
device identifier and the user-specified command in wherein the remote control device and the coding device
combination; are separate devices which are selectively interconnect
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able and disconnectable, and wherein the step of trans Supplying the user-specified command to the corre
mitting the user specified command further includes: sponding controllable device if the identifiers match;
transmitting the user-specified command from the c) with the identified controllable device,
remote control device to controllable devices when
the coding device is disconnected and receiving the user-specified command from the corre
transmitting the user-specified command and the sponding decoding device output means;
device identifier from the coding device to the con controlling the identified controllable device to imple
trollable devices when the remote control device and ment each user-specified command received from
the coding device are connected. the decoding device;
6. A method for remote control of a plurality of like 10
wherein the decoding device and the controllable devices
controllable devices which are controllable with common
commands, the method comprising: are separate devices, the decoding device being selec
a) with a remote control device, tively connectable to the identified one of the control
inputting a user-specified one of the common com lable devices, and further including:
mands which control the plurality of like controllable 15 when the decoding device is connected with the iden
devices; tified controllable device, receiving the transmitted
adding to the user-specified command a device identi device identifier and the user-specified command in
fier for identification of at least a selected one of the
controllable devices; combination from the coding device with the decod
transmitting the device identifier and the user-specified ing device, and
command in combination; when the decoding device is separate from the control
b) with a decoding device, lable device, receiving the user-specified command
receiving the device identifier and the user-specified and the device identifier in combination from the
command in combination; coding device with the identified controlling device.
extracting the device identifier, 25
comparing said extracted device identifier with a user
specified device identifier for identification of an
identified one of the controllable devices;
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EXHIBIT C
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As used in this claim chart, “UEI Accused Products” include without limitation the products and models identified in the Complaint as
infringing U.S. Patent No. 8,378,875, as well as any other product that operates in a manner reasonably similar to the specific theory of
infringement identified in the claim chart below.
Roku, Inc. (“Roku”) contends that UEI (as defined in the Complaint) directly infringes the method claims listed below when UEI or
those acting on UEI’s behalf, such as employees, officers, directors, principals, agents, consultants, and/or representatives use, test or
demonstrate the UEI Accused Products in the United States.
Roku contends that UEI directly infringes the asserted product claims by making, using, offering to sell, or selling within the United
States or importing into the United States the UEI Accused Products.
Further, Roku contends that UEI’s customers and/or end users directly infringe the method and product claims listed below by making,
using, offering to sell, or selling within the United States or importing into the United States the UEI Accused Products, and UEI
therefore indirectly infringes by way of inducement and/or contributory infringement.
Roku contends that each of the following limitations is met literally, and, to the extent a limitation is not met literally, it is met under
the doctrine of equivalents.
This claim chart is based on the information currently available to Roku and is intended to be exemplary in nature. The information
cited herein related to the UEI URC 7935 is representative in all material aspects for other UEI Accused Products with respect to any of
the charted claims that are asserted against any of the other UEI Accused Products. Based on information presently available to Roku,
each of the UEI Accused Products is understood to operate in the same manner with respect to the contentions provided in this chart for
each asserted claim. Roku reserves all rights to update and elaborate its infringement positions, including as Roku obtains additional
information during the course of discovery.
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For example, during the setup process, holding down a key on the keyboard causes the
processor to retrieve codes stored in a remote control memory and transmit function signals
via an IR transmitter.
Tear-down photographs and Maxim datasheet below provide evidence that the URC 7935
includes a keyboard, a Maxim MAXQ610 processor, which contains memory, and IR
transmitters.
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1a entering, via the keyboard The UEI Accused Products provide the step of entering, via the keyboard and processor, a
and processor, a configuration mode.
configuration mode;
For example, when the “TV Power” and “BACK” keys on the keyboard are held down, the
remote control enters a configuration mode for controlling a TV.
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1b accepting, via the The Accused Products provide the step of accepting, via the keyboard and processor, an
keyboard and processor, identifier-entry.
an identifier-entry; and
The remote control accepts keyboard entries that are identifier-entries. For example, to set up
the remote control to control a Samsung TV, a “Replay” button entry is accepted as an
identifier-entry. In another example, to set up the remote control to control a Zenith TV, a 5
digit code entry is accepted as an identifier-entry.
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1c scanning, via the processor The UEI Accused Products provide the step of scanning, via the processor and memory,
and memory, though though remote control code-sets in a database stored in the memory of the remote control.
remote control code-sets in
a database stored in the
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1d in case that the identifier- In case that the identifier-entry is a brand-identifier that identifies a brand, the UEI Accused
entry is a brand-identifier Products provide the step of (i) iterating, via the processor and memory, through the remote
that identifies a brand, (i) control code-sets corresponding to the brand and (ii) testing said remote control code-sets by
iterating, via the processor sending, via the transmitter, to a Consumer Electronic device for a given iteration, one or more
and memory, through the specific control code functions of a corresponding remote control code-set.
remote control code-sets
corresponding to the brand For example, during the “SimpleSet” setup procedure, the identifier-entry corresponds to a
and (ii) testing said remote brand-identifier (e.g., the “Replay” button corresponds to Samsung). In that case, the remote
control code-sets by control locates an appropriate code-set by iterating through code-sets and testing a current
sending, via the code-set by transmitting a control function.
transmitter, to a Consumer
Electronic device for a For example, during the setup procedure for a TV, the remote control tries code-sets for the
given iteration, one or identified brand in succession , sending the “Power” key for each code-set every 3 seconds,
more specific control code until the TV reacts, indicating that the appropriate code-set has been located.
functions of a
corresponding remote
control code-set, and
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1e in case that the identifier- In case that the identifier-entry is a code-set-identifier that identifies a single remote control
entry is a code-set- code-set which in not pointed to by a brand-identifier, the UEI Accused Products provide the
identifier that identifies a step of testing the single remote control code-set corresponding to the code-set-identifier by
single remote control sending, via the transmitter, to the consumer electronic device one or more specific control
code-set which in not code functions of the corresponding single remote control code-set.
pointed to by a brand-
identifier, testing the For example, during the “Setup by Code” setup procedure for the remote control, the
single remote control identifier-entry is a code-set identifier that corresponds to a single code-set for a device whose
code-set corresponding to brand is not listed in the “SimpleSet” procedure (e.g. 11565 for a Zenith TV). The remote
the code-set-identifier by control tests the single code-set identified by the code-set-identifier by transmitting to the
sending, via the consumer electronics device a control code for either “Power” or “Mute,” depending on the
transmitter, to the type of device being controlled.
Consumer Electronic
device one or more
specific control code
functions of the
corresponding single
remote control code-set.
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Claim 10
10 A non-transitory The UEI Accused Products comprise a non-transitory computer-readable medium embodied
computer-readable with a computer program that comprises computer program code executable by a processor to
medium embodied with a perform the steps of setting up a remote control of claim 1.
computer program that
comprises computer The UEI Accused Products have a processor and memory containing computer code that when
program code executable executed performs the steps of setting up a remote control as set forth in claim 1.
by a processor to perform
the steps of setting up a See evidence for claim 1.
Remote Control of claim
1.
Claim 11
11pre A method for setting up a To the extent the preamble is construed as limiting, the UEI Accused Products provide a
Remote Control that method for setting up a Remote Control that includes a keyboard, a processor, a memory, and
includes a keyboard, a a transmitter.
processor, a memory, and
a transmitter, the method See evidence for claim 1 preamble.
comprising the steps of
11a entering, via the keyboard The UEI Accused Products provide the step of entering, via the keyboard and processor, a
and processor, a configuration mode.
configuration mode;
See evidence for claim element 1a.
11b scanning, via the processor The UEI Accused Products provide the step of scanning, via the processor and memory,
and memory, though though remote control code-sets in a database stored in the memory of the remote control.
remote control code-sets in
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11c testing, via the keyboard, The UEI Accused Products provide the step of testing, via the keyboard, if individual keys of a
if individuals keys of a code set send, via the transmitter, correct codes and receiving, via the keyboard, user-feedback
code set send, via the on the correct and/or incorrect working of the tested keys.
transmitter, correct codes
and receiving, via the For example, during the “SimpleSet” setup procedure for a TV, the remote control tries code-
keyboard, user-feedback sets in succession, sending the “Power” key for each code-set every 3 seconds, to test one of
on the correct and/or the codes in a current code-set. If successful, the User’s Manual invites the user to test other
incorrect working of the remote keys to “find [if] one or more keys do not work as you expect. . . .”
tested keys;
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The user may then provide feedback that the key did not work by entering the Learning Mode.
11d replacing, via the The UEI Accused Products provide the step of replacing, via the processor and memory, non-
processor and memory, working codes with codes from at least a further remote control code-set.
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14pre Remote Control To the extent the preamble is construed as limiting, the UEI Accused Products are remote
comprising: controls.
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14a means for entering a The UEI Accused Products comprise means for entering a configuration mode.
configuration mode;
For example, when the “TV Power” and “BACK” keys are pressed simultaneously, the
processor initiates a configuration mode.
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14b means for accepting an The UEI Accused Products comprise means for accepting an identifier-entry.
identifier-entry; and
The remote control has a keyboard and processor that accept entries that act as identifiers. For
example, to set up the remote control to control a Samsung TV, a “Replay” button entry is
accepted as a brand-identifier. In another example, to set up the remote control to control a
Zenith TV, a 5-digit code entry is accepted as a code-set-identifier.
14c means for scanning though The UEI Accused Products comprise means for scanning though remote control code-sets in a
remote control code-sets in database stored in a memory of the remote control.
a database stored in a
memory of the Remote For example, the remote control contains a processor and software that perform scanning
Control wherein the means through remote control code-sets in a database stored in a memory of the remote control.
for scanning are adapted
for: See evidence for claim element 1c.
14d in case that the identifier- In case that the identifier-entry is a brand-identifier that identifies a brand, the UEI Accused
entry is a brand-identifier Products comprise means for scanning that are adapted for (i) iterating through the remote
that identifies a brand, (i) control code-sets corresponding to the brand and (ii) testing said remote control code-sets by
iterating through the sending to a consumer electronic device for a given iteration, one of more specific control
remote control code-sets code functions of a corresponding remote control code-set.
corresponding to the brand
and (ii) testing said remote See evidence for claim element 1d.
control code-sets by
sending to a Consumer
Electronic device for a
given iteration, one of
more specific control code
functions of a
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14e in case that the identifier- In case that the identifier-entry is a code-set-identifier that identifies a single remote control
entry is a code-set- code-set which is not pointed to by a brand-identifier, the Accused Products comprise means
identifier that identifies a for scanning that are adapted for testing the single remote control code-set corresponding to
single remote control the code-set-identifier by sending to the consumer electronic device one or more specific
code-set which is not control code functions of the corresponding single remote control code-set.
pointed to by a brand-
identifier, testing the See evidence for claim element 1e.
single remote control
code-set corresponding to
the code-set-identifier by
sending to the Consumer
Electronic device one or
more specific control code
functions of the
corresponding single
remote control code-set.
References:
[3] “16-Bit Microcontroller with Infrared Module”, Maxim Integrated Products, 2011,
https://datasheets.maximintegrated.com/en/ds/MAXQ610.pdf
(“MAXQ610 Datasheet”).
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EXHIBIT D
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As used in this claim chart, “UEI-Charter Accused Products” include without limitation the products and models identified in the
Complaint as infringing U.S. Pat. No. 8,378,875, as well as any other product that operates in a manner reasonably similar to the specific
theory of infringement identified in the claim chart below.
Roku, Inc. (“Roku”) contends that that UEI (as defined in the Complaint) directly infringes the method claim listed below when UEI or
those acting on UEI’s behalf, such as employees, officers, directors, principals, agents, consultants, and/or representatives perform the
claimed method such as during testing or demonstration of the UEI Accused Products in the United States..
Roku contends that UEI directly infringes the asserted product claims by making, using, offering to sell, or selling within the United
States or importing into the United States the UEI-Charter Accused Products.
Further, Roku contends that Charter’s customers and/or end users directly infringe the method and product claims listed below by
making, using, offering to sell, or selling within the United States or importing into the United States the UEI-Charter Accused Products,
and UEI therefore indirectly infringes by way of inducement and/or contributory infringement.
Roku contends that each of the following limitations is met literally, and, to the extent a limitation is not met literally, it is met under
the doctrine of equivalents.
This claim chart is based on the information currently available to Roku and is intended to be exemplary in nature. The information
cited herein related to the SR-002-R remote (URC 1160 Charter Spectrum) is representative in all material aspects for each of the UEI-
Charter Accused Products. Based on information presently available to Roku, each of the UEI-Charter Accused Products is understood
to operate in the same manner with respect to the contentions provided in this chart. Roku reserves all rights to update and elaborate its
infringement positions, including as Roku obtains additional information during the course of discovery.
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1pre A method for setting up a To the extent the preamble is construed as limiting, the UEI-Charter Accused Products provide
Remote Control that a method for setting up a remote control that includes a keyboard, a processor, a memory, and
includes a keyboard, a a transmitter.
processor, a memory, and
a transmitter, the method The SR-002-R (URC 1160 Charter Spectrum) is a remote control that includes a keyboard,
comprising the steps of: processor, a memory and a transmitter.
For example, during the setup process, holding down a key on the keyboard causes the
processor to retrieve codes stored in a remote control memory and transmit function signals
via an IR transmitter.
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Tear-down photographs and Qorvo product documentation below provide evidence that the
SR-002-R includes a keyboard, a GP565 processor, which contains memory, and a transmitter.
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1b accepting, via the The UEI-Charter Accused Products provide the step of accepting, via the keyboard and
keyboard and processor, processor, an identifier-entry.
an identifier-entry; and;
The remote control accepts keyboard entries that are identifier-entries. For example, to set up
the remote control to control an Insignia TV, a “1” button entry is accepted as an identifier-
entry. In another example, to set up the remote control to control an Acer TV, a 5-digit code
entry is accepted as an identifier-entry.
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1c scanning, via the processor The UEI-Charter Accused Products provide the step of scanning, via the processor and
and memory, though memory, though remote control code-sets in a database stored in the memory of the remote
remote control code-sets in control.
a database stored in the
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memory of the Remote For example, the remote control via the processor and memory scans through remote control
Control, wherein the step code-sets in a database stored in the memory of the remote control.
of scanning comprises:
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1d in case that the identifier- In case that the identifier-entry is a brand-identifier that identifies a brand, the UEI-Charter
entry is a brand-identifier Accused Products provide the step of (i) iterating, via the processor and memory, through the
that identifies a brand, (i) remote control code-sets corresponding to the brand and (ii) testing said remote control code-
iterating, via the processor sets by sending, via the transmitter, to a consumer electronic device for a given iteration, one
and memory, through the or more specific control code functions of a corresponding remote control code-set.
remote control code-sets
corresponding to the brand For example, during the “Setup for Popular TV Brands” setup procedure, the identifier-entry
and (ii) testing said remote corresponds to a brand-identifier (e.g., the “1” button corresponds to Insignia). In that case,
control code-sets by the remote control locates an appropriate code-set by iterating through code-sets and testing a
sending, via the current code-set by transmitting a control function.
transmitter, to a Consumer
Electronic device for a For example, during the “Setup for Popular TV Brands” procedure for a TV, the remote
given iteration, one or control tries code-sets for the identified brand in succession, sending the “Power” key for each
more specific control code code-set until the TV reacts, indicating that the appropriate code-set has been located.
functions of a
corresponding remote
control code-set, and
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1e in case that the identifier- In case that the identifier-entry is a code-set-identifier that identifies a single remote control
entry is a code-set- code-set which in not pointed to by a brand-identifier, the UEI-Charter Accused Products
identifier that identifies a provide the step of testing the single remote control code-set corresponding to the code-set-
single remote control identifier by sending, via the transmitter, to the Consumer Electronic device one or more
code-set which in not specific control code functions of the corresponding single remote control code-set.
pointed to by a brand-
identifier, testing the For example, during the “Direct Code Entry” setup procedure for the remote control, the
single remote control identifier-entry is a single code-set that corresponds to a code-set for a device whose brand is
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code-set corresponding to not listed in the “Setup for Popular TV Brands” feature (e.g. 11675 for an Akai TV). The
the code-set-identifier by remote control tests the single code-set identified by the code-set-identifier by transmitting to
sending, via the the consumer electronics device a control code for either a power control function or a volume
transmitter, to the control function.
Consumer Electronic
device one or more
specific control code
functions of the
corresponding single
remote control code-set.
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Claim 10
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Claim 14
14pre Remote Control To the extent the preamble is construed as limiting, the UEI-Charter Accused Products are
comprising: remote controls.
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14a means for entering a The UEI-Charter Accused Products comprise means for entering a configuration mode.
configuration mode;
For example, when the “Menu” and “OK” keys are pressed simultaneously, the processor
initiates a configuration mode.
14b means for accepting an The UEI-Charter Accused Products comprise means for accepting an identifier-entry.
identifier-entry; and
The remote control has a keyboard and processor that accept entries that act as identifiers. For
example, to set up the remote control to control for an Insignia TV, a “1” button entry button
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14c means for scanning though The UEI-Charter Accused Products comprise means for scanning though remote control code-
remote control code-sets in sets in a database stored in a memory of the remote control.
a database stored in a
memory of the Remote For example, the remote control contains a processor and software that perform scanning
Control wherein the means through remote control code-sets in a database stored in a memory of the remote control.
for scanning are adapted
for: See evidence for claim element 1c.
14d in case that the identifier- In case that the identifier-entry is a brand-identifier that identifies a brand, the UEI-Charter
entry is a brand-identifier Accused Products comprise means for scanning that are adapted for (i) iterating through the
that identifies a brand, (i) remote control code-sets corresponding to the brand and (ii) testing said remote control code-
iterating through the sets by sending to a consumer electronic device for a given iteration, one of more specific
remote control code-sets control code functions of a corresponding remote control code-set.
corresponding to the brand
and (ii) testing said remote See evidence for Claim element 1d.
control code-sets by
sending to a Consumer
Electronic device for a
given iteration, one of
more specific control code
functions of a
corresponding remote
control code-set
14e in case that the identifier- In case that the identifier-entry is a code-set-identifier that identifies a single remote control
entry is a code-set- code-set which is not pointed to by a brand-identifier, the UEI-Charter Accused Products
identifier that identifies a comprise means for scanning that are adapted for testing the single remote control code-set
single remote control
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code-set which is not corresponding to the code-set-identifier by sending to the consumer electronic device one or
pointed to by a brand- more specific control code functions of the corresponding single remote control code-set.
identifier, testing the
single remote control See evidence for claim element 1e.
code-set corresponding to
the code-set-identifier by
sending to the Consumer
Electronic device one or
more specific control code
functions of the
corresponding single
remote control code-set.
References:
[3] “1160 Charter Spectrum Remote 2015 Teardown Internal Photos Full page photo
Universal Electronics”, FCC, 2015,
https://fccid.io/MG3-1160/Internal-Photos/Internal-Photos-2714082
(“1160 Charter Spectrum Remote 2015 Teardown Internal Photos”).
[5] “GP565 RF4CE Communications Controller for Remote Control Product Brief,”
GP_P007_PB_06535 V2.00, Qorvo, 2017
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https://www.qorvo.com/products/d/da006198
(“GP565 Product Brief”).
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EXHIBIT E
Case 8:21-cv-00658 Document 1-5 Filed 04/08/21 Page 2 of 24 Page ID #:98
As used in this claim chart, “UEI-Altice Accused Products” include without limitation the products and models identified in the
Complaint as infringing U.S. Pat. No. 8,378,875, as well as any other product that operates in a manner reasonably similar to the specific
theory of infringement identified in the claim chart below.
Roku, Inc. (“Roku”) contends that UEI (as defined in the Complaint) directly infringes the method claim listed below when UEI or those
acting on UEI’s behalf, such as employees, officers, directors, principals, agents, consultants, and/or representatives perform the claimed
method such as during testing or demonstration of the UEI-Altice Accused Products in the United States.
Roku contends that UEI directly infringes the asserted product claims by making, using, offering to sell, or selling within the United
States or importing into the United States the UEI-Altice Accused Products.
Further, Roku contends that Altice’s customers and/or end users directly infringe the method and product claims listed below by making,
using, offering to sell, or selling within the United States or importing into the United States the UEI-Altice Accused Products, and UEI
therefore indirectly infringes by way of inducement and/or contributory infringement.
Roku contends that each of the following limitations is met literally, and, to the extent a limitation is not met literally, it is met under
the doctrine of equivalents.
This claim chart is based on the information currently available to Roku and is intended to be exemplary in nature. The information
cited herein related to the Optimum Silver with “O.” Button Remote (URC 2464 Optimum) is representative in all material aspects for
each of the UEI-Altice Accused Products. Based on information currently available to Roku, each of the UEI-Altice Accused Products
is understood to operate in the same manner with respect to the contentions provided in this chart. Roku reserves all rights to update and
elaborate its infringement positions, including as Roku obtains additional information during the course of discovery.
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See Optimum URC 2464 Manual; see also Optimum FAQ for silver with “O.” button remote.
1a entering, via the The UEI-Altice Accused Products provide the step of entering, via the keyboard and processor, a
keyboard and configuration mode.
processor, a
configuration mode; For example, when the “TV” and “SEL” keys on the keyboard are held down, the processor initiates
a configuration mode for controlling a TV.
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Case 8:21-cv-00658 Document 1-5 Filed 04/08/21 Page 8 of 24 Page ID #:104
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Case 8:21-cv-00658 Document 1-5 Filed 04/08/21 Page 9 of 24 Page ID #:105
See Optimum URC 2464 Manual; see also Optimum FAQ for silver with “O.” button remote.
1b accepting, via the The UEI-Altice Accused Products provide the step of accepting, via the keyboard and processor, an
keyboard and identifier-entry.
processor, an
identifier-entry; The remote control accepts keyboard entries that act as identifiers. For example, to set up the remote
and; control to control an Insignia TV, a “1” button entry is accepted as an identifier-entry. In another
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1c scanning, via the The UEI-Altice Accused Products provide the step of scanning, via the processor and memory,
processor and though remote control code-sets in a database stored in the memory of the remote control.
memory, though
remote control For example, the remote control via the processor and memory scans through remote control code-
code-sets in a sets in a database stored in the memory of the remote control.
database stored in
the memory of the
Remote Control,
wherein the step of
scanning comprises:
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See Optimum URC 2464 Manual; see also Optimum FAQ for silver with “O.” button remote.
1d in case that the In case that the identifier-entry is a brand-identifier that identifies a brand, the UEI-Altice Accused
identifier-entry is a Products provide the step of (i) iterating, via the processor and memory, through the remote control
brand-identifier that code-sets corresponding to the brand and (ii) testing said remote control code-sets by sending, via the
identifies a brand, transmitter, to a Consumer Electronic device for a given iteration, one or more specific control code
(i) iterating, via the functions of a corresponding remote control code-set.
processor and
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Case 8:21-cv-00658 Document 1-5 Filed 04/08/21 Page 15 of 24 Page ID #:111
See Optimum URC 2464 Manual; see also Optimum FAQ for silver with “O.” button remote.
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Case 8:21-cv-00658 Document 1-5 Filed 04/08/21 Page 16 of 24 Page ID #:112
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Claim 10
10 A non-transitory The UEI-Altice Accused Products comprise a non-transitory computer-readable medium embodied
computer-readable with a computer program that comprises computer program code executable by a processor to
medium embodied perform the steps of setting up a remote control of claim 1.
with a computer
program that The UEI-Altice Accused Products have a processor and memory containing computer code that when
comprises computer executed performs the steps of setting up a remote control as set forth in claim 1.
program code
executable by a See evidence for claim 1.
processor to
perform the steps of
setting up a Remote
Control of claim 1.
Claim 14
14pre Remote Control To the extent the preamble is construed as limiting, the UEI-Altice Accused Products are remote
comprising: controls.
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See Optimum URC 2464 Manual; see also Optimum FAQ for silver with “O.” button remote.
14a means for entering a The UEI-Altice Accused Products comprise means for entering a configuration mode.
configuration mode;
When the “TV” and “SEL” keys are pressed simultaneously, the processor initiates a setup mode.
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14c means for scanning The UEI-Altice Accused Products comprise means for scanning though remote control code-sets in a
though remote database stored in a memory of the Remote Control.
control code-sets in
a database stored in For example, the remote control contains a processor and software that perform scanning through
a memory of the remote control code-sets in a database stored in a memory of the remote control.
Remote Control
wherein the means See evidence for claim element 1c.
for scanning are
adapted for:
14d in case that the In case that the identifier-entry is a brand-identifier that identifies a brand, the UEI-Altice Accused
identifier-entry is a Products provide means for scanning that are adapted for (i) iterating through the remote control
brand-identifier that code-sets corresponding to the brand and (ii) testing said remote control code-sets by sending to a
identifies a brand, consumer electronic device for a given iteration, one of more specific control code functions of a
(i) iterating through corresponding remote control code-set.
the remote control
code-sets See evidence for claim element 1d.
corresponding to the
brand and (ii)
testing said remote
control code-sets by
sending to a
Consumer
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14e in case that the In case that the identifier-entry is a code-set-identifier that identifies a single remote control code-set
identifier-entry is a which is not pointed to by a brand-identifier, the UEI-Altice Accused Products comprise means for
code-set-identifier scanning that are adapted for testing the single remote control code-set corresponding to the code-set-
that identifies a identifier by sending to the consumer electronic device one or more specific control code functions of
single remote the corresponding single remote control code-set.
control code-set
which is not pointed See evidence for claim element 1e.
to by a brand-
identifier, testing
the single remote
control code-set
corresponding to the
code-set-identifier
by sending to the
Consumer
Electronic device
one or more specific
control code
functions of the
corresponding
single remote
control code-set.
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EXHIBIT F
Case 8:21-cv-00658 Document 1-6 Filed 04/08/21 Page 2 of 25 Page ID #:122
As used in this claim chart, “UEI-Wow Accused Products” include without limitation the products and models identified in the
Complaint as infringing U.S. Pat. No. 8,378,875, as well as any other product that operates in a manner reasonably similar to the specific
theory of infringement identified in the claim chart below.
Roku, Inc. (“Roku”) contends that UEI (as defined in the Complaint) directly infringes the method claim listed below when UEI or those
acting on UEI’s behalf, such as employees, officers, directors, principals, agents, consultants, and/or representatives perform the claimed
method such as during testing or demonstration of the UEI-Wow Accused Products in the United States.
Roku contends that UEI directly infringes the asserted product claims by making, using, offering to sell, or selling within the United
States or importing into the United States the UEI-Wow Accused Products.
Further, Roku contends that WOW’s customers and/or end users directly infringe the method and product claims listed below by making,
using, offering to sell, or selling within the United States or importing into the United States the UEI-Wow Accused Products, and UEI
therefore indirectly infringes by way of inducement and/or contributory infringement.
Roku contends that each of the following limitations is met literally, and, to the extent a limitation is not met literally, it is met under
the doctrine of equivalents.
This claim chart is based on the information currently available to Roku and is intended to be exemplary in nature. The information
cited herein related to the WOW! Experience Remote (URC 2135) is representative in all material aspects for each of the UEI-Wow
Accused Products. Based on information presently available to Roku, each of the UEI-Wow Accused Products is understood to operate
in the same manner with respect to the contentions provided in this chart. Roku reserves all rights to update and elaborate its infringement
positions, including as Roku obtains additional information during the course of discovery.
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Tear-down photographs and Qorvo product documentation below provide evidence that the WOW!
Experience (URC 2135) remote includes a keyboard, a GP565 processor, which contains memory,
and a transmitter.
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1a entering, via the The UEI-Wow Accused Products provide the step of entering, via the keyboard and processor, a
keyboard and configuration mode.
processor, a
configuration For example, when the “OK” and “MUTE” keys on the keyboard are held down, the processor
mode; initiates a configuration mode for controlling a TV.
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Case 8:21-cv-00658 Document 1-6 Filed 04/08/21 Page 10 of 25 Page ID #:130
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1b accepting, via the The UEI-Wow Accused Products provide the step of accepting, via the keyboard and processor, an
keyboard and identifier-entry.
processor, an
identifier-entry; The remote control accepts keyboard entries that act as identifiers. For example, to set up the remote
and; control to control an Insignia TV, a “1” button entry is accepted as an identifier-entry. In another
example, to set up the remote control to control an Akai TV, a 4-digit code entry is accepted as an
identifier-entry.
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Case 8:21-cv-00658 Document 1-6 Filed 04/08/21 Page 12 of 25 Page ID #:132
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1c scanning, via the The UEI-Wow Accused Products provide the step of scanning, via the processor and memory, though
processor and remote control code-sets in a database stored in the memory of the remote control.
memory, though
remote control For example, the remote control via the processor and memory scans through remote control code-sets
code-sets in a in a database stored in the memory of the remote control.
database stored in
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1d in case that the In case that the identifier-entry is a brand-identifier that identifies a brand, the UEI-Wow Accused
identifier-entry is a Products provide the step of (i) iterating, via the processor and memory, through the remote control
brand-identifier code-sets corresponding to the brand and (ii) testing said remote control code-sets by sending, via the
that identifies a transmitter, to a consumer electronic device for a given iteration, one or more specific control code
brand, (i) iterating, functions of a corresponding remote control code-set.
via the processor
and memory, During the “Popular Brands” setup procedure, the identifier-entry corresponds to a brand-identifier
through the remote (e.g., the “1” button corresponds to Insignia). In that case, the remote control locates an appropriate
control code-sets code-set by iterating through code-sets and testing a current code-set by transmitting a control
corresponding to function.
the brand and (ii)
testing said remote For example, during the setup procedure for a TV, the remote tries code-sets for the identified brand
control code-sets in succession, sending the “Power” key for each code-set, until the TV reacts, indicating that the
by sending, via the appropriate code-set has been located.
transmitter, to a
Consumer
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1e in case that the In case that the identifier-entry is a code-set-identifier that identifies a single remote control code-set
identifier-entry is a which in not pointed to by a brand-identifier, the UEI-Wow Accused Products provide the step of
code-set-identifier testing the single remote control code-set corresponding to the code-set-identifier by sending, via the
that identifies a transmitter, to the consumer electronic device one or more specific control code functions of the
single remote corresponding single remote control code-set.
control code-set
which in not
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Claim 10
10 A non-transitory The UEI-Wow Accused Products comprise a non-transitory computer-readable medium embodied
computer-readable with a computer program that comprises computer program code executable by a processor to perform
medium embodied the steps of setting up a remote control of claim 1.
with a computer
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Claim 14
14pre Remote Control To the extent the preamble is construed as limiting, the UEI-Wow Accused Products are remote
comprising: controls.
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14b means for The UEI-Wow Accused Products comprise means for accepting an identifier-entry.
accepting an
identifier-entry; The remote control has a keyboard and processor that accept entries that act as identifiers. For
and example, to set up an Insignia TV, a “1” button entry is accepted as a brand-identifier. In another
example, to set up an Akai TV, a 4-digit code entry is accepted as a code-set-identifier.
14c means for scanning The UEI-Wow Accused Products comprise means for scanning though remote control code-sets in a
though remote database stored in a memory of the Remote Control.
control code-sets in
a database stored in For example, the remote control contains a processor and software that perform scanning through
a memory of the remote control code-sets in a database stored in a memory of the remote control.
Remote Control
wherein the means See evidence for claim element 1c.
for scanning are
adapted for:
14d in case that the In case that the identifier-entry is a brand-identifier that identifies a brand, the UEI-Wow Accused
identifier-entry is a Products provide means for scanning that are adapted for (i) iterating through the remote control code-
brand-identifier sets corresponding to the brand and (ii) testing said remote control code-sets by sending to a consumer
that identifies a electronic device for a given iteration, one of more specific control code functions of a corresponding
brand, (i) iterating remote control code-set.
through the remote
control code-sets See evidence for Claim element 1d.
corresponding to
the brand and (ii)
testing said remote
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14e in case that the In case that the identifier-entry is a code-set-identifier that identifies a single remote control code-set
identifier-entry is a which is not pointed to by a brand-identifier, the UEI-Wow Accused Products comprise means for
code-set-identifier scanning that are adapted for testing the single remote control code-set corresponding to the code-set-
that identifies a identifier by sending to the consumer electronic device one or more specific control code functions of
single remote the corresponding single remote control code-set.
control code-set
which is not See evidence for claim element 1e.
pointed to by a
brand-identifier,
testing the single
remote control
code-set
corresponding to
the code-set-
identifier by
sending to the
Consumer
Electronic device
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References:
[3] “2135 WOW Experience RF4CE Remote 2016 Teardown Internal Photos Full page photo
Universal Electronics”, FCC, 2016,
https://fccid.io/MG3-2135/Internal-Photos/Internal-Photos-3168480
(“Wow URC 2135 Teardown Internal Photos”).
[5] “GP565 RF4CE Communications Controller for Remote Control Product Brief,”
GP_P007_PB_06535 V2.00, Qorvo, 2017
https://www.qorvo.com/products/d/da006198
(“GP565 Product Brief”).
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EXHIBIT G
Case 8:21-cv-00658 Document 1-7 Filed 04/08/21 Page 2 of 40 Page ID #:147
As used in this claim chart, “LG Accused Products” include without limitation the products and models identified in the Complaint, all
of which integrate UEI’s QuickSet, as infringing U.S. Patent No. 7,388,511 as well as any other product that operates in a manner
reasonably similar to the specific theory of infringement identified in the claim chart below.
Roku, Inc. (“Roku”) contends that UEI (as defined in the Complaint) directly infringes the method claim listed below when UEI or those
acting on UEI’s behalf, such as employees, officers, directors, principals, agents, consultants, and/or representatives perform the claimed
method such as during testing or demonstration of the LG Accused Products in the United States.
Further, Roku contends that UEI’s customers (such as LG) and/or end users of LG Accused Products directly infringe the method claim
listed below when using the LG Accused Products in the United States. UEI therefore indirectly infringes by way of inducement at least
by providing UEI’s QuickSet technology for integration into the LG Accused Products and by providing UEI’s QuickSet Cloud service
for use with the LG Accused Products.
Further, Roku contends that each of the following limitations is met literally, and, to the extent a limitation is not met literally, it is met
under the doctrine of equivalents.
This claim chart is based on the information currently available to Roku and is intended to be exemplary in nature. The information
cited herein related to the LG NanoCell 81 Series 2020 Smart TV (Model number: 55NANO81ANA) is representative in all material
aspects for other LG Accused Products with respect to the charted claim that is asserted against any of the other LG Accused Products.
Based on information presently available to Roku, each of the LG Accused Products is understood to operate in the same manner with
respect to the contentions provided in this chart. Roku reserves all rights to update and elaborate its infringement positions, including as
Roku obtains additional information during the course of discovery.
See https://www.lg.com/us/tvs/lg-55nano81ana-4k-uhd-tv#.
See https://www.urcsupport.com/urc_product/lg-smart-tv-2020/
inputting a user- For example, a user of a Magic Remote Control inputs a user-specified command for controlling the
specified controllable devices (e.g. via buttons). For example, a user of a Magic Remote Control inputs a “play”
command for or “pause” command by pressing a key, or button, on the remote control that corresponds to that
controlling the command for controlling external devices such as DVD recorders or Blu-ray players.
controllable
devices; and The Magic Remote Control then transmits the user-specified command.
transmitting the
user-specified
command;
5b b) with a coding The LG Accused Products perform the step of, with a coding device, receiving the user-specified
device, command from the remote control device, adding to the user-specified command a device identifier for
identification of at least one of the controllable devices, transmitting the device identifier and the user-
receiving the specified command in combination.
user-specified
command from For example, the coding device may include the hardware and software components in the LG Smart TV
the remote involved in receiving commands from the remote control and generating and transmitting HDMI-CEC
control device; frames (referred to hereinafter as the “HDMI-CEC Coding Device”). The HDMI-CEC Coding Device
may include the UEI QuickSet CEC Control Engine.
adding to the
user-specified For example, after receiving the user-specified command from the remote control using RF, the HDMI-
command a CEC Coding Device creates an HDMI-CEC frame comprising a header block and a data block. The
device identifier HDMI-CEC Coding Device adds to the user-specified command (e.g., information bits in the data block
for identification of the HDMI-CEC frame) a device identifier (e.g., destination bits in the header block of the HDMI-CEC
of at least one of frame) for identification of one of the controllable devices. The HDMI-CEC frame is transmitted in its
the controllable entirety to the controllable devices, such as DVD recorders or Blu-ray players, via an HDMI connection.
devices;
When two like controllable devices are connected to two HDMI ports of the LG Smart TV, the HDMI-
transmitting the CEC Coding Device adds a device identifier to the command specified by the user, and sends the
device identifier command together with the device identifier to the devices using the CEC protocol over an HDMI
and the user- connection.
specified
command in For example, when a user presses the “play” or “pause” buttons on the Magic Remote Control to indicate
combination; a user-specified command, the HDMI-CEC Coding Device receives the user-specified command, and
creates an HDMI-CEC frame comprising a header block and a data block. The header block of the
HDMI-CEC frame comprises the logical address of a destination device, and the data block of the
HDMI-CEC frame comprises an opcode block that corresponds to the user-specified command. The
HDMI-CEC frame is transmitted in its entirety to the destination devices, via an HDMI connection.
See https://www.urcsupport.com/urc_product/lg-smart-tv-2020/.
See https://quicksetcloud.com/technology/.
See https://quicksetcloud.com/quickset-in-action/
See https://shop.panasonic.com/support-only/DMR-EZ28K.html?t=manuals
5d wherein the In the LG Accused Products, the remote control device and the coding device are separate devices which
remote control are selectively interconnectable and disconnectable.
device and the
coding device are The Magic Remote Control and the HDMI-CEC Coding Device are separate devices which are
separate devices selectively interconnectable and disconnectable.
which are
selectively For example, when the Magic Remote Control and the HDMI-CEC Coding Device are configured by
interconnectable QuickSet to control controllable devices via HDMI-CEC commands, the remote control is connected to
and
See https://quicksetcloud.com/technology/.
See https://quicksetcloud.com/quickset-in-action/
See https://www.lg.com/uk/microsites/tv/simplink-function
See https://quicksetcloud.com/technology/
See https://quicksetcloud.com/quickset-in-action/
For example, when a Panasonic DP-UB420-K Blu-Ray Player and a Panasonic DMR-EZ28K DVD
Recorder are connected to the LG Smart TV via the HDMI ports, and QuickSet configures the Magic
Remote Control and the HDMI Coding Device to control these devices using IR commands, the play and
pause buttons on the remote control cause both devices to play and pause regardless of which of those
devices is selected as the current input source.
As another example, when two identical Panasonic DP-UB420-K Blu-ray Players are connected to the
LG Smart TV via the HDMI ports, and QuickSet configures the Magic Remote Control and the HDMI
Coding Device to control these devices using IR commands, the play and pause buttons on the remote
control cause both devices to play and pause regardless of which of those devices is selected as the
current input source.
5f transmitting the The LG Accused Products perform the step of transmitting the user-specified command and the device
user-specified identifier from the coding device to the controllable devices when the remote control device and the
command and the coding device are connected.
See https://quicksetcloud.com/technology/.
See https://quicksetcloud.com/quickset-in-action/.
See https://www.lg.com/uk/microsites/tv/simplink-function.
For example, when a Panasonic DP-UB420-K Blu-Ray Player and a Panasonic DMR-EZ28K DVD
Recorder are connected to the LG Smart TV via the HDMI ports, and QuickSet configures the Magic
Remote Control and the HDMI Coding Device to control these devices using HDMI-CEC commands,
the play and pause buttons on the remote control cause only the device that is selected as the current
input source to play and pause.
As another example, when two identical Panasonic DP-UB420-K Streaming Blu-Ray Players are
connected to the LG Smart TV via the HDMI ports, and QuickSet configures the Magic Remote Control
and the HDMI Coding Device to control these devices using HDMI-CEC commands, the play and pause
buttons on the remote control cause only the device that is selected as the current input source to play and
pause.
1. LG NanoCell 81 Series 2020 55 inch Class 4K Smart UHD NanoCell TV w/ AI ThinQ® (54.6''
Diag), https://www.lg.com/us/tvs/lg-55nano81ana-4k-uhd-tv#.
8. “Panasonic Blu-ray Disc Player Model No. DP-UB420”, TQBS0234, Panasonic Corporation of
North America, 2019, https://eww.pavc.panasonic.co.jp/bd/UB420_330_320/DP-
UB420_P_EN_TQBS0234.pdf (“DP-UB420 Manual”).
EXHIBIT H
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As used in this claim chart, “Samsung Accused Products” include without limitation the products and models identified in the Complaint,
all of which integrate UEI’s QuickSet, as infringing U.S. Patent No. 7,388,511 as well as any other product that operates in a manner
reasonably similar to the specific theory of infringement identified in the claim chart below.
Roku, Inc. (“Roku”) contends that UEI (as defined in the Complaint) directly infringes the method claim listed below when UEI or those
acting on UEI’s behalf, such as employees, officers, directors, principals, agents, consultants, and/or representatives perform the claimed
method such as during testing or demonstration of the Samsung Accused Products in the United States.
Further, Roku contends that Samsung’s customers and/or end users of the Samsung Accused Products directly infringe the method claim
listed below when using the Samsung Accused Products in the United States. UEI therefore indirectly infringes by way of inducement
at least by providing the Samsung Accused Products with UEI’s QuickSet technology for integration into the Samsung Accused Products
and by providing UEI’s QuickSet Cloud service for use with the Samsung Accused Products.
Further, Roku contends that each of the following limitations is met literally, and, to the extent a limitation is not met literally, it is met
under the doctrine of equivalents.
This claim chart is based on the information currently available to Roku and is intended to be exemplary in nature. The information
cited herein related to the Samsung 4K QLED Series Q70T TV (Model Number: QN55Q70TAFXZA) is representative in all material
aspects for other Samsung Accused Products with respect to the charted claim that is asserted against any of the other Samsung Accused
Products. Based on information presently available to Roku, each of the Samsung Accused Products is understood to operate in the
same manner with respect to the contentions provided in this chart. Roku reserves all rights to update and elaborate its infringement
positions, including as Roku obtains additional information during the course of discovery.
Infringement of U.S. Patent No. 7,388,511 via Samsung Accused Products Page 1 of 32
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See https://www.samsung.com/us/televisions-home-theater/tvs/qled-4k-tvs/55-class-q70t-qled-4k-uhd-
hdr-smart-tv-2020-qn55q70tafxza/.
Infringement of U.S. Patent No. 7,388,511 via Samsung Accused Products Page 2 of 32
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See https://www.urcsupport.com/urc_product/samsung-smart-tv-2020/.
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5a a) with a remote The Samsung Accused Products perform the step of, with a remote control device, inputting a user-
control device, specified command for controlling the controllable devices and transmitting the user-specified command.
inputting a user- For example, a user of a Samsung Universal Remote Control inputs a user-specified command for
specified controlling the controllable devices (e.g. via buttons). For example, a user of a Samsung Universal
command for Remote Control inputs a “play” or “pause” command by pressing a key, or button, on the remote control
controlling the that corresponds to that command for controlling external devices such as DVD recorders or Blu-ray
controllable players.
devices; and
The Samsung Universal Remote Control then transmits the user-specified command.
transmitting the
user-specified
command;
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5b b) with a coding The Samsung Accused Products perform the step of, with a coding device, receiving the user-specified
device, command from the remote control device, adding to the user-specified command a device identifier for
identification of at least one of the controllable devices, transmitting the device identifier and the user-
receiving the specified command in combination.
user-specified
command from For example, the coding device may include the hardware and software components in the Samsung
the remote Smart TV involved in receiving commands from the remote control and generating and transmitting
control device; HDMI-CEC frames (referred to hereinafter as the “HDMI-CEC Coding Device”). The HDMI-CEC
Coding Device may include the UEI QuickSet CEC Control Engine.
adding to the
user-specified For example, after receiving the user-specified command from the remote control using RF, the HDMI-
command a CEC Coding Device creates an HDMI-CEC frame comprising a header block and a data block. The
device identifier HDMI-CEC Coding Device adds to the user-specified command (e.g., information bits in the data block
for of the HDMI-CEC frame) a device identifier (e.g., destination bits in the header block of the HDMI-CEC
identification of frame) for identification of a one of the controllable devices. The HDMI-CEC frame is transmitted in its
at least one of entirety to the controllable devices, such as DVD Recorders or Blu-ray players, via an HDMI connection.
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the controllable When two like controllable devices are connected to two HDMI ports of the Samsung Smart TV, the
devices; HDMI-CEC Coding Device adds a device identifier to command specified by the user, and sends the
command together with the device identifier to the devices using the CEC protocol over an HDMI
transmitting the connection.
device identifier
and the user- For example, when a user presses the “play” or “pause” buttons on the Samsung Universal Remote
specified Control to indicate a user-specified command, the HDMI-CEC Coding Device receives the user-specified
command in command, and creates an HDMI-CEC frame comprising a header block and a data block. The header
combination; block of the HDMI-CEC frame comprises the logical address of a destination device, and the data block
of the HDMI-CEC frame comprises an opcode block that corresponds to the user-specified command.
The HDMI-CEC frame is transmitted in its entirety to the destination devices, via an HDMI connection.
See https://www.urcsupport.com/urc_product/samsung-smart-tv-2020/.
Infringement of U.S. Patent No. 7,388,511 via Samsung Accused Products Page 10 of 32
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See https://quicksetcloud.com/technology/.
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See https://quicksetcloud.com/quickset-in-action/.
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5c c) with one of When the Samsung Accused Products are connected to like controllable devices and configured to control
the like the controllable devices as instructed, one of those controllable devices performs the step of receiving the
controllable device identifier and the user-specified command in combination, extracting the device identifier,
devices, comparing said extracted device identifier with a further device identifier for identification of the
controllable device, refraining from further operation with the received user-specified command if said
receiving the identifiers do not match, and supplying the user-specified command if said identifiers do match.
device identifier
and the user- A For example, a controllable device (e.g., a DVD recorder or a Blu-ray player that supports the HDMI-
specified CEC protocol) that is connected to the Samsung Smart TV using an HDMI connection receives the device
command in identifier and the user-specified command in combination (e.g., in an HDMI-CEC frame transmitted from
combination; the HDMI-CEC Coding Device). In this example, the DVD recorder or Blu-ray player inspects the
HDMI-CEC frame arriving on the CEC bus, and extracts and compares the destination bits in the header
extracting the block of the frame to the controllable device’s own logical address.
device
identifier; In this example, a DVD recorder or Blu-ray player refrains from further operation with the received user-
specified command if the identifiers do not match (e.g., the DVD recorder or Blu-ray player does not
comparing said respond unless the destination bits in the header block of the HDMI-CEC frame match the device’s own
extracted device logical address). If the identifiers do match, then the user-specified command is supplied (e.g., if the
identifier with a destination bits in the header block of the HDMI-CEC frame match the logical address of the DVD
further device recorder or Blu-ray player, then the user-specified command is supplied for performing the command by
identifier for that device).
identification of
the controllable Many home entertainment devices support the HDMI-CEC protocol, including DVD recorders such as the
device; Panasonic DMR-EZ28K DVD Recorder and Blu-ray players such as the Panasonic DP-UB420-K Blu-ray
player.
refraining from
further
For example, when a Panasonic DP-UB420-K Blu-Ray Player and a Panasonic DMR-EZ28K DVD
operation with
Recorder are connected to the Samsung Smart TV via the HDMI ports, and QuickSet configures the
the received
Samsung Universal Remote Control and the HDMI Coding Device to control these devices using HDMI-
user-specified
CEC commands, the play and pause buttons on the remote control cause only the device that is selected as
command if
the current input source to play and pause.
said identifiers
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do not match; As another example, when two identical Panasonic DP-UB420-K Streaming Blu-Ray Players are
and connected to the Samsung Smart TV via the HDMI ports, and QuickSet configures the Samsung
Universal Remote Control and the HDMI Coding Device to control these devices using HDMI-CEC
supplying the commands, the play and pause buttons on the remote control cause only the device that is selected as the
user-specified current input source to play and pause.
command if
said identifiers
do match;
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See https://shop.panasonic.com/support-only/DMR-EZ28K.html?t=manuals.
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5d wherein the In the Samsung Accused Products, the remote control device and the coding device are separate devices
remote control which are selectively interconnectable and disconnectable.
device and the
coding device The Samsung Universal Remote Control and the HDMI-CEC Coding Device are separate devices which
are separate are selectively interconnectable and disconnectable.
devices which
are selectively For example, the Samsung Universal Remote Control and the HDMI-CEC Coding Device are configured
interconnectable by QuickSet to control controllable devices via HDMI-CEC commands, the remote control is connected
and to the HDMI-CEC Coding Device such that commands received from the remote control via RF are
disconnectable, transmitted to the controllable devices via HDMI-CEC.
and wherein the
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step of Alternatively, when the Samsung Universal Remote Control and HDMI-CEC Coding Device are not
transmitting the configured by QuickSet to control controllable devices via HDMI-CEC commands, the remote control is
user specified disconnected from the HDMI-CEC Coding Device such that commands are transmitted directly from the
command remote control to the controllable devices via IR.
further includes:
See https://quicksetcloud.com/technology/.
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See https://quicksetcloud.com/quickset-in-action/.
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5e transmitting the The Samsung Accused Products perform the step of transmitting the user-specified command from the
user-specified remote control device to controllable devices when the coding device is disconnected.
command from
the remote For example, when the Samsung Universal Remote Control and the HDMI-CEC Coding Device are not
control device configured by QuickSet to control controllable devices via HDMI-CEC commands, the HDMI-CEC Coding
to controllable Device is disconnected and the remote control transmits the user command to controllable devices via IR
devices when communication.
the coding
device is
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disconnected
and
See https://quicksetcloud.com/technology/.
See https://quicksetcloud.com/quickset-in-action/.
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For example, when a Panasonic DP-UB420-K Blu-Ray Player and a Panasonic DMR-EZ28K DVD
Recorder are connected to the Samsung Smart TV via the HDMI ports, and QuickSet configures the
Samsung Universal Remote Control and the HDMI Coding Device to control these devices using IR
commands, the play and pause buttons on the remote control cause both devices to play and pause
regardless of which of those devices is selected as the current input source.
As another example, when two identical Panasonic DP-UB420-K Blu-ray Players are connected to the
Samsung Smart TV via the HDMI ports, and QuickSet configures the Samsung Remote Control and the
HDMI Coding Device to control these devices using IR commands, the play and pause buttons on the
remote control cause both devices to play and pause regardless of which of those devices is selected as the
current input source.
5f transmitting the The Samsung Accused Products perform the step of transmitting the user-specified command and the
user-specified device identifier from the coding device to the controllable devices when the remote control device and
command and the coding device are connected.
the device
identifier from For example, when the Samsung Universal Remote Control and the HDMI Coding Device are configured
the coding by QuickSet to control controllable devices via HDMI-CEC commands, the remote control is connected to
device to the the HDMI-CEC Coding Device, and the HDMI-CEC Coding Device transmits the user command along
controllable with the device identifier in an HDMI-CEC frame to the controllable devices via an HDMI connection.
devices when
the remote
control device
and the coding
device are
connected.
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See https://quicksetcloud.com/technology/.
See https://quicksetcloud.com/quickset-in-action/.
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For example, when a Panasonic DP-UB420-K Blu-Ray Player and a Panasonic DMR-EZ28K DVD
Recorder are connected to the Samsung Smart TV via the HDMI ports, and QuickSet configures the
Samsung Universal Remote Control and the HDMI Coding Device to control these devices using HDMI-
CEC commands, the play and pause buttons on the remote control cause only the device that is selected as
the current input source to play and pause.
As another example, when two identical Panasonic DP-UB420-K Streaming Blu-Ray Players are
connected to the Samsung Smart TV via the HDMI ports, and QuickSet configures the Samsung
Universal Remote Control and the HDMI Coding Device to control these devices using HDMI-CEC
commands, the play and pause buttons on the remote control cause only the device that is selected as the
current input source to play and pause.
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References:
7. “Panasonic Blu-ray Disc Player Model No. DP-UB420”, TQBS0234, Panasonic Corporation of
North America, 2019, https://eww.pavc.panasonic.co.jp/bd/UB420_330_320/DP-
UB420_P_EN_TQBS0234.pdf (“DP-UB420 Manual”).
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