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File Name: zte_light_18146.zip
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In addition, the patents-in-suit have been licensed to over companies, including notable technology companies such as Apple and Intel. Finally, the Sh-Boom Processor, a chip created by Messrs.

Turning now to Plaintiffs Infringement Contentions, as an initial matter, the Accused Instrumentalities in the case are LG products, not individual microprocessors. Taking Claims 6 and 13 of the Patent as an example, these claims recite a microprocessor system that comprises a central processing unit CPU and an off-chip clock.

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Thus, as far as structural elements, Claims 6 and 13 require four primary ones: With respect to the microprocessor system limitation found in the preamble of Claims 6 and 13, Plaintiffs list in Exhibit A of the Infringement Contentions, by name and model number, the phones and other devices that correspond to the microprocessor systems portion of the claim. See Plaintiffs Claim Charts, at p. Thus, the Claim Chart specifically correlates the Accused Products listed in Exhibit A to the microprocessor ZTE Light Tab V9C (Telcel) Tablet USB recited in the claims of the Patent. Next, to the extent possible, Plaintiffs identified the microprocessor contained in the Accused Products. For some of the Accused Products, however, the specific type of microprocessor included in the Accused Product could not be determined through an exhaustive search of publicly available information. For those Accused Products for which the microprocessor could not be determined, the Accused Product was evaluated to determine if it had characteristics that would indicate that it did in fact include a microprocessor.


The inclusion of a USB port or the ability to communicate using Wi-Fi, for example, was evaluated in determining whether to include a particular Accused Product in Exhibit A of the Infringement Contentions. Notably, LG has not claimed that any of the Accused Products identified in Exhibit A of the Infringement Contentions lack a microprocessor that operates with the same infringing qualities as the other Accused Microprocessors. Turning now to the oscillator limitation, Plaintiffs contend this limitation is met through the inclusion of an oscillator in the Accused Microprocessor s use of a phase ZTE Light Tab V9C (Telcel) Tablet USB loop PLL clocking system.

Specifically, the Infringement Contentions state: The presence of a PLL indicates the presence of a voltage or current controlled oscillator, which itself will include the claimed oscillator.

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The claimed oscillator is disposed upon the integrated circuit substrate, connected to the central processing unit, and is clocking the central processing unit. The oscillator is constructed of a second plurality of electronic devices. G-1 filed with Mot. As the quote from the Claim Chart demonstrates, Plaintiffs specifically identified where the oscillator is located in the PLL clocking circuitry on the Accused Microprocessor and how it is implemented in the form of a voltage or current controlled oscillator.

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The Claim Charts then go on to specifically examine some of the Accused Microprocessors for which information was available to Plaintiffs. Plaintiffs Infringement Contentions make clear that these Accused Microprocessors are representative of the other microprocessors contained in the Accused Products. Plaintiffs claim that the Accused Microprocessors discussed in the claim chart are representative of all of the Accused Microprocessors is based on a number of factors. First, Plaintiffs cite to tens of thousands of pages of microprocessor user manuals in the Infringement Contentions. These manuals were examined in the preparation of the Infringement Contentions and produced along with the Infringement Contentions and support Plaintiffs ZTE Light Tab V9C (Telcel) Tablet USB that the Accused Microprocessors discussed in the Claim Charts are representative of other Accused Microprocessors not specifically charted.

Further, this same source unambiguously states that [a]ll phase-locked loops employ an oscillator element with variable frequency capability.


Third, Plaintiffs technical expert, Dr. The is a critical piece of the MMP Portfolio because nearly all high speed microprocessors must use the clocking scheme covered by the patent.

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Although many lower speed microprocessors use external crystals to clock. Their CPU s, this is simply not possible for the high speed, high end microprocessors that are necessary for modern smartphones and other high performance wireless products. In order to achieve clock speeds in the multi-gigahertz range, it is essential to have a ring oscillator-based clocking system on the same silicon die as the CPU.

HTC Trial Transcript, at p. Oklobdzija voiced similar views about similar infringing qualities relevant to the Patent. This package contains the files for installing the ZTE Light Tab V9C (Telcel) Tablet USB Driver for Mexico only. If it has been installed, updating.

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