Intellectual Essen Capital Management Confidential...2017/05/11 · Acer acknowledged receipt of...
Transcript of Intellectual Essen Capital Management Confidential...2017/05/11 · Acer acknowledged receipt of...
EXHIBIT 1013
1 BING XU’S ASSERTED CLAIMS AND INFRINGEMENT CONTENTIONS
CASE NO. 16-02491-EJD
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Tammy J. Dunn (CSB No. 230283) OSHA LIANG LLP 909 Fannin Street, Ste. 3500 Houston, TX 77010 Tel.: 713.228.8600 Fax: 713.228.8778 [email protected]
Attorney for Plaintiff Bing Xu Precision Co. Ltd.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA – SAN JOSE DIVISION
BING XU PRECISION CO. LTD.,
Plaintiff,
v.
ACER INCORPORATED, and ACER
AMERICA CORPORATION
Defendants.
Case No. 5:16-CV-02491-EJD
PLAINTIFF BING XU PRECISION CO. LTD’S DISCLOSURE OF ASSERTED CLAIMS AND PRELIMINARY INFRINGEMENT CONTENTIONS
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Pursuant to Patent L.R. 3-1, Plaintiff Bing Xu Precision Co. Ltd. (“Bing Xu”) hereby
serves on all parties its “Disclosure of Asserted Claims and Infringement Contentions.”
I. DISCLOSURES PURSUANT TO PATENT LOCAL RULE 3-1
A. Patent L.R. 3-1(a): Infringed Claims
Bing Xu contends that Defendants Acer Incorporated and Acer America Corporation
(“Acer”) each individually and/or jointly infringe claims 1-4 of United States Patent Nos.
8,758,044 (“the ’044 patent”) and 8,512,071 (“the ’071 patent”), and claims 1-2 of U.S. Patent
No. 8,740,631 (“the ’631 patent”) (collectively “the patents in suit”).
B. Patent L.R. 3-1(b): Accused Instrumentalities
Bing Xu hereby discloses separately for each asserted claim, each accused apparatus,
product, device, process, method, act, or other instrumentality (“Accused Instrumentality”) of
Acer of which Bing Xu is currently aware. Bing Xu preliminarily identifies that the Accused
Instrumentalities include the Luxshare SATA cable connector assembly used in Acer’s Aspire
product line, including but not limited to part numbers 450.02B04.0001 VA30 HDD FFC and
450.02BN04.0001 VA 30 HDD FFC, and any similar SATA connectors with the same features.
Bing Xu reserves the right to supplement this disclosure with any other infringing SATA
connectors that it learns of through discovery.
The Luxshare SATA cable connector infringes claims 1-4 of the ’044 patent and ’071
patent, and claims 1-2 of the ’631 patent.
Bing Xu anticipates that events in the litigation, including discovery to be provided by
Acer and/or by third parties and the Court’s claim construction, may impact the patent claims it
will allege Acer infringes. Bing Xu reserves the right to add to or otherwise modify its
identification of claims it contends are infringed by each Accused Instrumentality and add
Accused Instrumentalities that infringe such claims. Bing Xu additionally reserves the right to
add to or otherwise modify its identification of the manner in which claims are infringed.
C. Patent L.R. 3-1(c): Charts
Attached as Exhibits A-C (and incorporated by reference as though fully stated here) are
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charts identifying specifically where each limitation of each asserted claim is found with respect
to each Accused Instrumentality. These claim charts can be supplemented and/or amended based
on discovery, additional evidence, further investigation, and/or the Court’s claim construction.
Bing Xu anticipates that events in the litigation, including discovery to be provided by Acer
and/or by third parties and the Court’s claim construction, may impact the patent claims it will
allege Acer infringes. Bing Xu reserves the right to add to or otherwise modify its identification
of claims it contends are infringed. Bing Xu additionally reserves the right to add to or
otherwise modify its identification of the manner in which claims are infringed.
Bing Xu’s identification of Accused Instrumentalities above and/or in the accompanying
charts is preliminary. Bing Xu’s identification of where elements of asserted claims may be
found in the Accused Instrumentalities also is preliminary. These identifications are based upon
Bing Xu’s present knowledge and analysis. Bing Xu continues its investigation and reserves its
right to supplement, amend, and/or revise its contentions as events in the litigation occur and
Bing Xu conducts further investigation and/or analysis.
D. Patent L.R. 3-1(d): Indirect Infringement
Bing Xu hereby identifies, for each claim which is alleged to have been indirectly
infringed, an identification of any direct infringement and a description of the acts of the alleged
indirect infringer that contribute to or are inducing that direct infringement. Insofar as alleged
direct infringement is based on joint acts of multiple parties, the role of each such party in the
direct infringement, as currently known to Bing Xu, is described.
As demonstrated by the attached claim charts, Exhibits A-C, Acer’s SATA connector
assemblies meet the limitations of the claims disclosed in the chart. Thus, any sales and/or offers
for sale or importation of Acer’s computers with the Accused Instrumentalities in the United
States are direct infringement activities, as would be the use and manufacture of such computers
in the United States.
Acer had pre-suit knowledge of the patents in suit through a letter dated August 12, 2015,
sent to Mr. George Huang. Acer acknowledged receipt of the August 12, 2015 letter in an email
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from Kate Ci Shang of Acer that was sent on August 25, 2015 and cc’ed Mr. Morgan Lin. Mr.
Lin is believed to serve as head of Acer’s legal department in Taiwan.
On September 11, 2015, after receiving no response from Mr. Lin, Bing Xu sent a follow
up letter to Mr. Lin asking for a response by September 25, 2015, and included a copy of the
August 15, 2015, letter. Neither Mr. Lin nor any other Acer employee responded.
At least as of the time when Acer received the warning letters, Acer knew it was
incorporating a SATA Connector that had been accused of infringing Bing Xu’s patents into at
least some of its laptops. Acer had full knowledge of Bing Xu’s patents at that point and did not
deny infringement of any of them.
Acer actively induced infringement of the patents in suit by actively and knowingly
aiding and abetting its Original Design Manufacturers and/or component manufacturers through
activities such as creating and/or distributing data sheets, requirements documents, assembly
instructions and/or similar materials with instructions on creating, manufacturing, designing,
assembling and/or implementing the Accused Instrumentalities, with the specific intent to induce
others to directly make, use, offer for sale, sell, and/or import into the United States computers
with the Accused Instrumentalities without license or authority from Plaintiff. On information
and belief, Acer knows that the induced acts constitute infringement of the patents in suit.
E. Patent L.R. 3-1(e): Literal or Doctrine of Equivalents
As demonstrated by the attached claim chart, each limitation of each claim of the patents
in suit asserted against Acer is literally present in Acer’s Luxshare SATA connector assembly. If
Acer contends that any limitation of any of the asserted claims is not literally present in Acer’s
Luxshare SATA connector assembly and components, Bing Xu asserts that any such limitation
of the asserted claims is also present under the doctrine of equivalents because any difference
between Acer’s Luxshare SATA connector assembly and components, and what is literally
claimed in the asserted claims is insubstantial. Because Acer has not produced documents or
information to date concerning the accused instrumentalities in connection with initial disclosure
obligations or otherwise, Acer will be able to provide more specific contentions under the
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doctrine of equivalents if, after, and when Acer identifies which elements it contends are not
literally present in Acer’s Luxshare SATA connector assembly and components.
F. Patent L.R. 3-1(f): Priority Date
The claims of the ’071 Patent are entitled to a priority date of March 28, 2011.
The claims of the ’631 Patent are entitled to a priority date of October 28, 2011.
The claims of the ’044 Patent are entitled to a priority date of March 16, 2012.
G. Patent L.R. 3-1(g): Practicing Products
Bing Xu’s licensees’ products that are covered by the patents in suit are identified in
Exhibit D. Bing Xu is not in possession, custody, or control of documents or information
sufficient to identify which of the asserted claims cover each of Bing Xu’s licensees’ products.
These identifications are based upon Bing Xu’s present knowledge and analysis. Bing
Xu continues its investigation and reserves its right to supplement, amend, and/or revise its
contentions as events in the litigation occur, including the Court’s claim construction, and Bing
Xu conducts further investigation and/or analysis.
H. Patent L.R. 3-1(h): Damages Timeframe
Bing Xu is entitled to collect damages for any infringement of the patents in suit from the
issuance date of each patent through trial and final judgment with appropriate interest. Bing Xu
is also entitled to an ongoing royalty for future use of the patented technology until the patents in
suit expire.
Bing Xu, on information and belief, is aware that Acer incorporated the Accused
Instrumentalities into its computer products sold in the United States in the second half of 2013.
These identifications are based upon Bing Xu’s present knowledge and analysis. Bing
Xu continues its investigation and reserves its right to supplement, amend, and/or revise its
contentions as events in the litigation occur and Bing Xu conducts further investigation and/or
analysis.
I. Patent L.R. 3-1(i): Willful Infringement
Acer had pre-suit knowledge of the patents in suit through a letter dated August 12, 2015,
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sent to Mr. George Huang. Acer acknowledged receipt of the August 12, 2015, letter in an email
from Kate Ci Shang of Acer that was sent on August 25, 2015 and cc’ed Mr. Morgan Lin. Mr.
Lin is believed to serve as head of Acer’s legal department in Taiwan.
On September 11, 2015, after receiving no response from Mr. Lin, Bing Xu sent a follow
up letter to Mr. Lin asking for a response by September 25, 2015, and included a copy of the
August 15, 2015, letter. Neither Mr. Lin nor any other Acer employee responded.
At least as of the time when Acer received the warning letters, Acer knew that it was
incorporating a SATA Connector that had been accused of infringing Bing Xu’s patents into at
least some of its laptops. Acer had full knowledge of Bing Xu’s patents at that point and did not
deny infringement of any of them.
Acer could have instructed the OEM to use a different connector, to purchase the
connector from a supplier who had a license granted by Bing Xu, or to actively seek a license
from Bing Xu. Acer did none of these things. Instead, Acer ignored Bing Xu’s warnings and,
without denying infringement, continued to direct the OEM to incorporate the infringing
connector into Acer’s computers.
II. DISLCOSURES PURSUANT TO PATENT LOCAL RULE 3-2
Bing Xu identifies the following documents that are currently within its possession. Bing
Xu will supplement its production as additional documents become available.
A. Patent L.R. 3-2(a)
Bing Xu is not aware of any disclosure, offers for sale, or public use of the patented
inventions prior to the date of applications for the patents in suit.
B. Patent L.R. 3-2(b)
All documents related to conception, reduction to practice, design, and development of
each claimed invention within Bing Xu’s possession, custody, and control are being produced at
BingXu00000384 – BingXu00004849.
C. Patent L.R. 3-2(c)
Copies of the file histories for the patents-in-suit are being produced at BingXu00000014
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– BingXu00000381.
D. Patent L.R. 3-2(d)
All documents evidencing ownership of the patents-in-suit within Bing Xu’s possession,
custody, and control are being produced at BingXu00000001 – BingXu00000003.
E. Patent L.R. 3-2(e)
All documents sufficient to show the operation and structure of instrumentalities
identified pursuant to Patent L.R. 3-1(g) within Bing Xu’s possession, custody, and control are
being produced at BingXu00005386 – BingXu0005633.
F. Patent L.R. 3-2(f)
All agreements, including licenses, transferring an interest in any patent-in-suit are being
produced at BingXu00005318 – BingXu00005340.
G. Patent L.R. 3-2(g)
Licenses within Bing Xu’s possession, custody, and control that Bing Xu contends are
comparable to a hypothetical negotiation are being produced at BingXu00005318 –
BingXu00005340. Bing Xu reserves the right to supplement this disclosure with additional
comparable licenses it may identify through discovery, including any additional licenses Bing
Xu may procure and/or other comparable licenses between non-parties identified by a damages
expert.
H. Patent L.R. 3-2(h)
Bing Xu is not aware of any agreements other than the licenses that are being produced
pursuant to Patent L.R. 3-2(f) and (g) that may be used to support Bing Xu’s damages case at this
time. Bing Xu reserves the right to amend and/or supplement this section when further
information becomes available and/or for other good cause.
I. Patent L.R. 3-2(i)
Bing Xu does not have documents in its possession, custody, or control sufficient to show
marking of instrumentalities identified pursuant to Patent L.R. 3-1(g) at this time because all
such instrumentalities are made by third party licensees that are not under Bing Xu’s control.
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Bing Xu reserves the right to amend and/or supplement this section when further information
becomes available and/or for other good cause.
J. Patent L.R. 3-2(j)
Bing Xu is not aware of any documents comprising or reflecting a F/RAND commitment
or agreement with respect to the asserted patents.
III. CONCLUSION
These contentions are preliminary, are based on known publicly available information,
and are subject to change based on the Court’s claim construction and/or information learned
through discovery. Bing Xu reserves the right to amend and/or supplement these infringement
contentions if and when further information regarding Defendants’ products and components
becomes available and/or for other good cause.
Dated: May 11, 2017 OSHA LIANG LLP
/s/Tammy J. Dunn
Tammy J. Dunn 909 Fannin Street., Ste. 3500 Houston, TX 77010 [email protected] Attorney for Plaintiff Bing Xu Precision Co. Ltd.
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CERTIFICATE OF SERVICE
I certify that on May 11, 2017, the foregoing document was served on all counsel of
record via electronic transmittal delivery (e-mail), as the parties have previously agreed.
/s/ Tammy J. Dunn
Tammy J. Dunn
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 9
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EXHIBIT A CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,512,071
1
Claim Limitations of
the ’071 Patent Acer’s SATA FFC CABLE
1. An electrical connector assembly comprising:
Acer’s electrical connector assembly is shown above.
an insulating housing having a plurality of grooves, a plurality of data terminal holes, and a plurality of power terminal holes;
The insulating housing is depicted at 10 above. The plurality of grooves is shown at 12 and 13 above. The plurality of data terminal holes is shown at 133 below and the plurality of power terminal holes is shown at 123 below.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 10
EXHIBIT A CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,512,071
2
Claim Limitations of the ’071 Patent
Acer’s SATA FFC CABLE
a PCB (printed circuit board) having a plurality of first soldering holes, a plurality of second soldering holes, a plurality of first contacts electrically connected to the first soldering holes, and a plurality of second contacts electrically connected to the second soldering holes;
The PCB shown above has a plurality of soldering holes and a plurality of contacts electrically connected to the soldering holes. The designation of a soldering hole or contact as first and second is arbitrary and not significant for purposes of showing infringement of this claim.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 11
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EXHIBIT A CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,512,071
3
Claim Limitations of the ’071 Patent
Acer’s SATA FFC CABLE
a plurality of power terminals fastened in the grooves of the insulating housing respectively, the power terminals each having a mating portion inserted into each of the power terminal holes, and the power terminals each having a soldering portion soldered in each of the first soldering holes;
The power terminals, of which there is a plurality, are shown above at 20 and fasten into the grooves shown at 12 of the insulating housing 10. Each power terminal has a mating portion (shown above at 23) that is inserted into each of the power terminal holes shown at 123. Each power terminal also has a soldering portion shown at 25 which is soldered in each of the first soldering holes as shown at P42. The designation of a soldering hole as first or second is arbitrary and not significant for purposes of showing infringement of this claim.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 12
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EXHIBIT A CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,512,071
4
Claim Limitations of the ’071 Patent
Acer’s SATA FFC CABLE
a plurality of data terminals fastened in the grooves of the insulating housing respectively, the data terminals each having a mating portion inserted into each of the data terminal holes, and the data terminals each having a soldering portion soldered in each of the second soldering holes; and
The plurality of data terminals shown above at 30 are fastened in the grooves shown above at 13 of the insulating housing shown above at 10. The mating portion of the data terminals is shown above at 33. The mating portion of the data terminals is inserted into each hole of the data terminal holes shown at 133. The data terminals have a soldering portion shown at 35 above which are soldered in each of the second soldering holes shown at 43. The designation of a soldering hole as first or second is arbitrary and not significant for purposes of showing infringement of this claim.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 13
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EXHIBIT A CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,512,071
5
Claim Limitations of the ’071 Patent
Acer’s SATA FFC CABLE
an FFC (flexible flat cable) having an insulating layer for enclosing a plurality of first conductors and a plurality of second conductors;
The flexible flat cable has an insulating layer that encloses a plurality of conductors. The designation of conductors as first or second is arbitrary and not significant for purposes of showing infringement of this claim.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 14
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EXHIBIT A CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,512,071
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Claim Limitations of the ’071 Patent
Acer’s SATA FFC CABLE
wherein the PCB is secured to the insulating housing, exposed ends of the first conductors are electrically connected to the first contacts, and exposed ends of the second conductors are electrically connected to the second contacts.
The PCB is depicted above at 40 and is shown secured to the insulating housing shown at 10. The exposed ends of several conductors are electrically connected to several contacts. The designation of conductors as first or second is arbitrary and not significant for purposes of showing infringement of this claim.
2. The electrical connector assembly of claim 1, wherein a pitch between two adjacent first contacts is less than a pitch between any two adjacent first soldering holes of the PCB, and a pitch between any two adjacent second contacts is less than a pitch between any two adjacent second soldering holes of the PCB.
The soldering holes have a consistent width between each soldering hole on the PCB. The contacts also have a consistent width between each contact. The width between two adjacent contacts is less than the width between two adjacent soldering holes of the PCB.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 15
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EXHIBIT A CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,512,071
7
Claim Limitations of the ’071 Patent
Acer’s SATA FFC CABLE
3. The electrical connector assembly of claim 1, wherein the insulating housing further comprises an internal wall, and wherein a first bending portion of the FFC is fastened by the internal wall and the PCB.
The internal wall of the rear cover of the insulating housing secures the bending portion of the FFC to the PCB where it is latched to the front section of the insulating housing.
4. The electrical connector assembly of claim 1, wherein the insulating housing further having at least one pin and at least one latch, the PCB further having at least one pin hole for fixing the pin of the insulating housing, and wherein the latch of the insulating housing is pressed to clamp the PCB.
The insulating housing has a pin and latch shown below. The PCB has a pin hole for the pin of the insulating housing that secures the PCB. The latch of the front of the insulating housing secures the rear cover of the insulating housing which clamps the PCB.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 16
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EXHIBIT B CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,758,044
1
Claim Limitations of
the ’044 Patent Acer’s SATA FFC CABLE
1. An electrical connector assembly comprising:
Acer’s electrical connector assembly is shown above.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 17
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EXHIBIT B CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,758,044
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Claim Limitations of the ’044 Patent
Acer’s SATA FFC CABLE
an insulating housing having a plurality of grooves, a plurality of data terminal holes, and a plurality of power terminal holes;
The insulating housing is depicted at 10. The plurality of grooves is shown at 12 and 13. The plurality of data terminal holes is shown at 133 and the plurality of power terminal holes is shown at 123.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 18
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EXHIBIT B CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,758,044
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Claim Limitations of the ’044 Patent
Acer’s SATA FFC CABLE
a PCB (printed circuit board) having a plurality of first soldering holes, a plurality of second soldering holes, a plurality of first contacts electrically connected to the first soldering holes, and a plurality of second contacts electrically connected to the second soldering holes;
The PCB shown above has a plurality of soldering holes and a plurality of contacts electrically connected to the soldering holes. The designation of a soldering hole or contact as first and second is arbitrary and not significant for purposes of showing infringement of this claim.
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EXHIBIT B CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,758,044
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Claim Limitations of the ’044 Patent
Acer’s SATA FFC CABLE
a plurality of power terminals fastened in the grooves of the insulating housing respectively, the power terminals each having a mating portion inserted into each of the power terminal holes, and the power terminals each having a soldering portion soldered in each of the first soldering holes;
The power terminals, of which there is a plurality, are shown above at 20 and fasten into the grooves shown at 12 of the insulating housing 10. Each power terminal has a mating portion (shown above at 23) that is inserted into each of the power terminal holes shown at 123. Each power terminal also has a soldering portion shown at 25 which is soldered in each of the first soldering holes as shown at P42. The designation of a soldering hole as first or second is arbitrary and not significant for purposes of showing infringement of this claim.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 20
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EXHIBIT B CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,758,044
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Claim Limitations of the ’044 Patent
Acer’s SATA FFC CABLE
a plurality of data terminals fastened in the grooves of the insulating housing respectively, the data terminals each having a mating portion inserted into each of the data terminal holes, and the data terminals each having a soldering portion soldered in each of the second soldering holes; and
The plurality of data terminals shown above at 30 are fastened in the grooves shown above at 13 of the insulating housing shown above at 10. The mating portion of the data terminals is shown above at 33. The mating portion of the data terminals is inserted into each hole of the data terminal holes shown at 133. The data terminals have a soldering portion shown at 35 above which are soldered in each of the second soldering holes shown at 43. The designation of a soldering hole as first or second is arbitrary and not significant for purposes of showing infringement of this claim.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 21
FFC L ......—
Insulating layer
...x-,.. . i 4. ... • • • ..
" .
conductors contacts and
4th 0 44L ,i, k_ As _ 4. 4,4 ItC Sit
- .
•
contacts and conductors
Pl. Po Pip 1 # .0 . 1
ob • . , • .
• 1 i. %4,4.4 #1te lit
. . _ .
EXHIBIT B CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,758,044
6
Claim Limitations of the ’044 Patent
Acer’s SATA FFC CABLE
an FFC (flexible flat cable) having an insulating layer for enclosing a plurality of first conductors and a plurality of second conductors;
The flexible flat cable has an insulating layer that encloses a plurality of conductors. The designation of conductors as first or second is arbitrary and not significant for purposes of showing infringement of this claim.
wherein exposed ends of the second conductors are electrically connected to the second contacts.
The exposed ends of several conductors are electrically connected to several contacts. The designation of conductors as first or second is arbitrary and not significant for purposes of showing infringement of this claim.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 22
EXHIBIT B CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,758,044
7
Claim Limitations of the ’044 Patent
Acer’s SATA FFC CABLE
2. The electrical connector assembly of claim 1, wherein a pitch between two adjacent first contacts is less than a pitch between any two adjacent first soldering holes of the PCB, and a pitch between any two adjacent second contacts is less than a pitch between any two adjacent second soldering holes of the PCB.
The soldering holes have a consistent width between each soldering hole on the PCB. The contacts also have a consistent width between each contact. The width between two adjacent contacts is less than the width between two adjacent soldering holes of the PCB.
3. The electrical connector assembly of claim 1, wherein the insulating housing further comprises an internal wall, and wherein a first bending portion of the FFC is fastened by the internal wall and the PCB.
The internal wall of the rear cover of the insulating housing secures the bending portion of the FFC to the PCB where it is latched to the front section of the insulating housing.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 23
EXHIBIT B CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,758,044
8
Claim Limitations of the ’044 Patent
Acer’s SATA FFC CABLE
4. The electrical connector assembly of claim 1, wherein the insulating housing further has at least one latch, and the latch of the insulating housing is pressed to clamp the PCB.
The insulating housing has a pin and latch shown below. The PCB has a pin hole for the pin of the insulating housing that secures the PCB. The latch of the front of the insulating housing secures the rear cover of the insulating housing which clamps the PCB.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 24
//- ' • I, • .
•I
EXHIBIT C CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,740,631
1
Claim Limitations of
the ’631 Patent Acer’s SATA FFC CABLE
1. An electrical connector assembly comprising:
Acer’s electrical connector assembly is shown above. an insulating housing (10) comprising a plurality of terminal holes (127);
The insulating housing is depicted at 10. The plurality of data terminal holes is shown at 133 and the plurality of power terminal holes is shown at 123.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 25
VA
4, 4
44. 4.
r%
r
soldering holes
•
414.... 4
contacts
A •
EXHIBIT C CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,740,631
2
Claim Limitations of the ’631 Patent
Acer’s SATA FFC CABLE
a printed circuit board (PCB) (80) comprising a plurality of first, second, third, and fourth soldering holes (81, 82, 83, and 84) and a plurality of first, second, third, and fourth contacts (85, 86, 87, and 88) wherein the PCB (80) is vertically secured to a rear end (108) of the insulating housing (10), a front surface (801) of the PCB (80) faces interior of the insulating housing (10), and a rear surface (802) of the PCB (80) is distal the rear end (108) of the insulating housing (10);
The PCB has a plurality of soldering holes and a plurality of contacts. The designation of a soldering hole or contact as first, second, third, and fourth is arbitrary and not significant for purposes of showing infringement of this claim. The following photographs show the orientation of the surfaces of the PCB with respect to the insulating housing (10) with the PCB vertically secured to the rear end of the insulating housing, a front surface of the PCB facing the interior of the insulating housing, and a rear surface of the PCB distal the rear end of the insulating housing.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 26
EXHIBIT C CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,740,631
3
Claim Limitations of the ’631 Patent
Acer’s SATA FFC CABLE
10
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 27
30
10
EXHIBIT C CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,740,631
4
Claim Limitations of the ’631 Patent
Acer’s SATA FFC CABLE
a plurality of terminals (70) fastened in the terminal holes (127) respectively, each terminal (70) comprising a mating portion (73) at one end fastened in one of the terminal holes (127), and a soldering portion (75) at the other end soldered in one of the first, second, third, and fourth soldering holes (81, 82, 83, 84);
The plurality of power terminals is shown above at 20. The power terminals fasten into the terminals shown at 12 of the insulating housing 10. Each power terminal has a mating portion (shown above at 23) that is inserted into each of the power terminal holes shown at 12 and 123. Each power terminal also has a soldering portion as shown at 25 which is soldered in soldering holes as shown at 42. The designation of a soldering hole as first, second, third, and fourth is arbitrary and not significant for purposes of showing infringement of this claim.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 28
. ii . ...
......— L FFC
—NI:
Insulating layer
• • . ..
r
44 F1
lb 4.--44 s.-4L-4•
- ..
_
IIP I:,
will
contacts and conductors
Pi
i
-
i ' j
. . . I t
- _
- _
4.4a. 4.4-4, 4'4.4
,
• 1111=1.10
isimmillli
f
EXHIBIT C CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,740,631
5
Claim Limitations of the ’631 Patent
Acer’s SATA FFC CABLE
a flex flat cable (FFC) (90) comprising a plurality of conductors (95) and an insulating layer (901) for enclosing substantial portions of the conductors (95);
The flexible flat cable has an insulating layer that encloses a plurality of conductors.
wherein the first, second, third, and fourth contacts (85, 86, 87, and 88) are disposed on the rear surface (802) of the PCB (80), and exposed portion (951) of each conductor (95) at one end (91) of the FFC (90) is electrically connected to one of the first, second, third, and fourth contacts (85, 86, 87, and 88) of the PCB (80); and
The contacts are disposed on the rear surface of the PCB and an exposed portion of each conductor at one end of the FFC is electrically connected to one of the contacts of the PCB. The designation of a contact as first, second, third, and fourth is arbitrary and not significant for purposes of showing infringement of this claim.
an adhesive (96) coated on the conductors (95) at one end (91) of the FFC (90) to secure the FFC (90) to the PCB (80), wherein the adhesive (96) is AB adhesive, UV adhesive, hot melt type adhesive, quick dry adhesive, or any of other adhesives for fastening and protecting the FFC (90).
The adhesive coated on the conductors at the end of the FFC to secure the FFC to the PCB is shown circled above.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 29
EXHIBIT C CLAIM CHART SHOWING INFRINGEMENT OF U.S. PATENT NO. 8,740,631
6
Claim Limitations of the ’631 Patent
Acer’s SATA FFC CABLE
2. The electrical connector assembly of claim 1, wherein soldering holes (a1, a2, a3, a4, a5, a6, and a7) of the first soldering holes (81) on the rear surface (802) of the PCB (80) are electrically connected to contacts (b1, b2, b3, b4, b5, b6, and b7) of the first contacts (85) respectively, furthering comprising a ground member (803) disposed on the front surface (801) of the PCB (80), and at least three soldering holes (a1, a4, and a7) of the first soldering holes (81) are electrically connected to the ground member (803) respectively.
Seven soldering holes on the rear surface of the PCB are electrically connected to seven contacts. A ground member on the front surface of the PCB is connected to at least three soldering holes.
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 30
EX
HIB
IT D
PA
TE
NT
L.R
. 3-1
(G) C
HA
RT
1
Lice
nsee
Pa
rt N
o./M
odel
No.
Pr
oduc
t Nam
e 上達
Sh
anda
35
1220
-100
SA
TA +
FFC
ASS
EMBL
Y DR
AWIN
G 35
1253
-100
SA
TA +
FFC
ASS
EMBL
Y DR
AWIN
G 34
20B8
-100
O
DD S
ATA
+ FF
C CA
BLE
3420
55-1
00
ODD
SAT
A +
FFC
CABL
E 34
2085
-100
O
DD S
ATA
+ FF
C CA
BLE
3420
50-1
00
ODD
SAT
A +
FFC
CABL
E 今皓
Jin
Hao
Pa
rt N
o./M
odel
No.
Pr
oduc
t Nam
e N
BX00
027L
00 &
P51
0P16
0975
FS
_15_
HDD_
FFC_
12pi
n P5
10P1
6076
1 HD
D CA
BLE
LIST
DD
0G97
HD00
0 &
P51
0P16
0896
CA
BLE
ASSY
G97
HDD
JHI
DD0G
76HD
000
& P
510P
1609
36
HDD
FFC
DD0G
75HD
010
& P
510P
1609
37
CABL
E AS
SY G
75 H
DD JH
I DD
0G74
HD00
0 &
P51
0P16
0893
CA
BLE
ASSY
G74
HDD
(10P
/15P
,1A)
30V
JHI
DD0G
72HD
010
& P
510P
1609
01
CABL
E AS
SY G
72 H
DD(1
0P/1
5P,1
A)30
V JH
I P5
10P1
6091
8 HD
D FF
C P5
10P1
6074
5 HD
D FF
C DD
0G3B
CD01
0 &
P51
0P16
0957
CA
BLE
ASSY
G3B
ODD
(13P
/18P
,1A)
30V
JHI
DD0G
3BHD
010
& P
510P
1609
53
CABL
E AS
SY G
3B H
DD(2
2P/1
0P,1
A)30
V JH
I DD
0G3A
HD00
0 &
P51
0P16
0898
CA
BLE
ASSY
G3A
HDD
JHI
品威
Pi
ng W
ei
Part
No.
/Mod
el N
o.
Prod
uct N
ame
SD-2
0010
03
SATA
HDD
WIT
H FF
C CA
BLE
MS1
781
FFC1
12P
IN L
=35.
7MM
SD
-200
1003
SA
TA H
DD W
ITH
FFC
CABL
E M
S178
1 FF
C2 1
2PIN
L=5
5.46
MM
SD
-200
1004
SA
TA O
DD W
ITH
FFC
CABL
E L=
300M
M
SD-2
0010
03
SATA
HDD
WIT
H FF
C CA
BLE
SB15
L=7
9.5M
M
SD-2
0010
04
SATA
ODD
WIT
H FF
C CA
BLE
L=59
MM
SD
-200
1003
SA
TA H
DD W
ITH
FFC
CABL
E L=
41.6
MM
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 31
EX
HIB
IT D
PA
TE
NT
L.R
. 3-1
(G) C
HA
RT
2
Part
No.
/Mod
el N
o.
Prod
uct N
ame
SD-2
0010
04
SATA
ODD
WIT
H FF
C CA
BLE
SNO
W L
=63.
81M
M
SD-2
0010
04
SATA
ODD
WIT
H FF
C CA
BLE
L=63
.81M
M
F061
017H
SA
TA H
DD W
ITH
FFC
CABL
E CF
L=6
2.5M
M
Unk
now
n CA
BLE
ASSY
Tos
hiba
SAT
A HD
D SD
-200
1003
SA
TA H
DD W
ITH
FFC
CABL
E L=
150.
5MM
F2
4100
2H
SATA
ODD
WIT
H FF
C CA
BLE
L=15
0MM
F2
4100
1H
SATA
HDD
WIT
H FF
C CA
BLE
F241
007H
SA
TA H
DD W
ITH
FFC
CABL
E N
UBE
01B
L=46
MM
F2
4101
0H
SATA
HDD
WIT
H FF
C CA
BLE
S14B
WO
X L=
58.5
MM
F2
4100
6H
SATA
ODD
WIT
H 18
PIN
FFC
CAB
LE S
FFBT
03 L
=145
MM
F2
2000
2H
CABL
E.FF
C..S
AT..E
F10M
I2..H
F. L
EAD-
FREE
.JPC
F210
004H
EF
10 S
ATA
HDD
WIT
H FF
C CA
BLE
12PI
N
F220
001H
CA
BLE
.FFC
..SAT
A..T
L10R
E1. L
EAD-
FREE
JPC
F202
064H
Sh
lva_
hdd_
ffc_
F202
003R
CA
BLE
ASSY
ST7
SAT
A HD
D(10
P/15
,REV
2A)5
V F2
0200
1R
CABL
E AS
SY S
T6 S
ATA
HDD(
10P/
15,R
EV1A
)5V
F202
075H
CA
BLE
ASSY
G72
HDD
(10P
/15P
,3A)
30V
KWE
F202
076H
CA
BLE
ASSY
G75
HDD
(10P
/15P
,1A)
30V
KWE
F202
077H
CA
BLE
ASSY
G74
HDD
(10P
/15P
,3A)
30V
KWE
F202
054H
SP
P177
HDD
CAB
LE
F202
061H
CA
BLE
ASSY
G38
D HD
D(10
P/15
P,1A
)30V
KW
E F2
0203
0H
SATA
HDD
10
PIN
FFC
CAB
LE A
M9
L=76
.14M
M
F202
017H
SA
TA H
DD W
ITH
10 P
IN F
FC C
ABLE
NB2
NL3
L=3
4MM
SD
-200
1003
SA
TA H
DD W
ITH
FFC
CABL
E N
L8 A
STA
GE L
=95.
5MM
F2
0201
4H
CABL
E AS
SY Z
YW S
ATA
HDD(
10P/
15P,
REV1
A)5V
F2
0200
4H
SATA
HDD
WIT
H 10
PIN
FFC
CAB
LE L
=28M
M
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 32
EX
HIB
IT D
PA
TE
NT
L.R
. 3-1
(G) C
HA
RT
3
F2
0201
3H
CABL
E AS
SY Z
QX
HDD(
13/1
3P,3
A)5V
U
nkno
wn
SATA
HDD
WIT
H 10
PIN
F2
0200
9H
SATA
HDD
WIT
H 10
PIN
FFC
CAB
LE N
B7 L
=54M
M
F202
015H
SA
TA H
DD W
ITH
10 P
IN F
FC C
ABLE
NB7
CZ1
L=1
52.6
8MM
F2
0202
7H
SATA
ODD
WIT
H FF
C CA
BLE
X62
L=35
.5m
m
F202
078H
CA
BLE
ASSY
HDD
(10P
/15P
,3A)
30V
KWE
F202
068H
N
11-1
3 HD
D SA
TA c
able
TIM
SD
-200
1004
SA
TA O
DD W
ITH
FFC
CABL
E L=
115M
M
F061
005R
SA
TA H
DD W
ITH
FFC
CABL
E DW
17 H
DD2
F061
006R
SA
TA H
DD W
ITH
FFC
CABL
E DW
17 H
DD1
F061
007R
SA
TA H
DD W
ITH
FFC
CABL
E DW
15
建舜
Jia
nshu
n Pa
rt N
o./M
odel
No.
Pr
oduc
t Nam
e 15
10-0
830-
xxxx
CA
BLE
ASSY
G97
HDD
JSE
1510
-xxx
x-xx
xx
CABL
E AS
SY G
74 H
DD JS
E 15
10-x
xxx-
xxxx
CA
BLE
ASSY
G76
HDD
JSE
1510
-083
0-00
72
CABL
E AS
SY G
72 H
DD(1
0P/1
5P,1
A)30
V JS
E 15
10-0
830-
0073
CA
BLE
ASSY
G75
HDD
(10P
/15P
,1A)
30V
JSE
1510
-083
0-xx
xx
CABL
E AS
SY G
97 O
DD JS
E 15
10-x
xxx-
xxxx
CA
BLE
ASSY
WBC
15
HDD
JSE
1510
-083
0-00
83
CABL
E AS
SY G
3B O
DD JS
E IQ
H150
160
DESS
ERT
14TH
IN H
DD F
FC L
60.
96
IQH1
5016
2 DE
SSER
T 15
PO
WER
HDD
FFC
L 8
6.29
IQ
H150
161
DESS
ERT
15 T
HIN
HDD
FFC
L 6
3.8
IQH1
5016
3 DE
SSER
T 17
PO
WER
HDD
FFC
L 4
0 U
nkno
wn
CABL
E AS
SY G
38D
HDD
IQH1
60xx
x CA
BLE
ASSY
NL5
/NL5
A HD
D JS
E 15
10-0
830-
0054
X8
3 SA
TA O
DD F
FC C
ABLE
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 33
EX
HIB
IT D
PA
TE
NT
L.R
. 3-1
(G) C
HA
RT
4
佳必琪
(大部
份由秀宇代工
&付權利金
) JP
C
Part
No.
/Mod
el N
o.
Prod
uct N
ame
TNPT
0134
-1
SATA
HDD
WIT
H FF
C CA
BLE
L=68
.5M
M
Unk
now
n SA
TA H
DD W
ITH
10PI
N F
FC C
ABLE
PC
B012
J000
10-2
SA
TA H
DD W
ITH
FFC
CABL
E L=
80M
M
PCB0
12J0
0008
-9
SATA
HDD
WIT
H FF
C CA
BLE
L=63
.3M
M
Unk
now
n CA
BLE
ASSY
ODD
JPC
PCB0
12J0
0009
-1
ASW
50 H
DD F
FC C
ON
N
SD-2
0010
03
SATA
HDD
WIT
H FF
C CA
BLE
TO L
VDS
20P
SD-2
0010
03
SATA
HDD
WIT
H FF
C CA
BLE
TO L
VDS
20P
Unk
now
n SA
TA H
DD W
ITH
FFC
CABL
E U
nkno
wn
SATA
HDD
WIT
H FF
C CA
BLE
L=55
MM
U
nkno
wn
SATA
HDD
WIT
H 10
PIN
FFC
CAB
LE
PCB0
12K0
0004
-2
SATA
ODD
WIT
H FF
C CA
BLE
L=55
MM
PC
B012
K000
04-4
SA
TA O
DD W
ITH
FFC
CABL
E L=
125M
M
PCB0
12K0
0004
-3
SATA
ODD
WIT
H FF
C CA
BLE
L=90
MM
PC
B012
J000
07-5
SA
TA H
DD W
ITH
FFC
CABL
E L=
45M
M
PCB0
12J0
0007
-6
SATA
HDD
WIT
H FF
C CA
BLE
L=27
MM
PC
B012
J000
07-8
SA
TA H
DD W
ITH
FFC
CABL
E L=
42.4
MM
PC
B012
J000
07-7
SA
TA H
DD W
ITH
FFC
CABL
E L=
65.9
MM
PC
B012
J000
07-9
SA
TA H
DD W
ITH
FFC
CABL
E L=
69.2
MM
TN
PT01
49-1
SA
TA H
DD W
ITH
FFC
CABL
E L=
40M
M
Unk
now
n SA
TA H
DD W
ITH
FFC
CABL
E L=
118M
M
PCB0
12K0
0003
-5
CABL
E AS
SY O
DD(1
0P,2
A)30
V JP
C PC
B012
K000
03-5
CA
BLE
ASSY
ODD
(10P
,2A)
30V
JPC
Unk
now
n SA
TA H
DD W
ITH
FFC
CABL
E U
nkno
wn
SATA
ODD
WIT
H FF
C CA
BLE
Unk
now
n SA
TA H
DD W
ITH
FFC
CABL
E N
I3BT
03 L
=81.
7MM
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 34
EX
HIB
IT D
PA
TE
NT
L.R
. 3-1
(G) C
HA
RT
5
Prod
uct N
ame
Part
No.
/Mod
el N
o.
Unk
now
n SA
TA H
DD W
ITH
FFC
CABL
E SF
FBT0
1 L=
34M
M
PCBC
D181
503-
1 SA
TA O
DD W
ITH
18PI
N F
FC C
ABLE
A43
10 L
=150
MM
U
nkno
wn
SATA
ODD
WIT
H 18
PIN
FFC
CAB
LE E
T203
0I L
=250
MM
PC
B012
J000
07-6
SA
TA H
DD W
ITH
FFC
CABL
E L=
180M
M
TNO
T016
5-1
CABL
E AS
SY G
35 H
DD(1
0P/1
5P,3
A)30
V JP
C TN
PT01
66-1
CA
BLE
ASSY
G31
HDD
(10P
/15P
,3A)
30V
JPC
TNPT
0164
-1
CABL
E AS
SY G
34 H
DD(1
0P/1
5P,3
A)30
V JP
C TN
PT01
67-1
CA
BLE
ASSY
G37
HDD
(10P
/15P
,3A)
30V
JPC
TNPT
0162
-7
CABL
E AS
SY G
38D
HDD(
10P/
15P,
1A) J
PC
PCB0
12J0
0007
-2
CABL
E AS
SY X
15 H
DD(1
0P/1
5P,2
A)30
V JP
C L=
66M
M
PCB0
12J0
0007
-4
CABL
E AS
SY X
18 H
DD(1
0P/1
5P,2
A)30
V JP
C L=
72M
M
PCB0
12J0
0007
-3
CABL
E AS
SY X
12 H
DD(1
0P/1
5P,2
A)30
V JP
C L=
61M
M
PCB0
12K0
0003
-4
CABL
E AS
SY X
15 O
DD(1
8P/1
3P,2
A)30
V JP
C L=
51M
M
PCB0
12K0
0003
-5
CABL
E AS
SY X
18 O
DD(1
8P/1
3P,2
A)30
V JP
C L=
83M
M
PCBC
5D18
0651
-1
SATA
ODD
WIT
H FF
C CA
BLE
PCB0
12K0
0003
-4
CABL
E AS
SY L
V7 O
DD(1
8P/1
3P,2
A)30
V JP
C U
nkno
wn
CABL
E AS
SY H
DD JP
C L=
80M
M
PCBC
5D10
0341
-1
SATA
HDD
WIT
H 10
PIN
FFC
CAB
LE N
B2 N
L3 L
=34M
M
Unk
now
n SA
TA H
DD W
ITH
10P
FFC
CABL
E ZY
W Z
YV L
=88M
M
PCBC
5D18
1005
-1
SATA
ODD
WIT
H 18
PIN
FFC
CAB
LE Y
17 L
=95.
6MM
PC
BC5D
1003
05-1
SA
TA H
DD W
ITH
FFC
CABL
E Y1
1 L=
30M
M
PCBC
5D10
0605
-1
SATA
HDD
WIT
H 10
PIN
FFC
CAB
LE Y
17 L
=45M
M
PCBC
5D10
0513
-1
SATA
HDD
WIT
H 10
P FF
C CA
BLE
Y34
L=61
MM
PC
BC5D
1005
54-1
SA
TA H
DD W
ITH
10PI
N F
FC C
ABLE
Y37
L=5
5MM
PC
BC5D
1846
32-1
SA
TA O
DD W
ITH
18PI
N F
FC C
ABLE
Y14
L=4
6.3M
M
PCBC
5D10
0351
-1
SATA
HDD
WIT
H 10
PIN
FFC
CAB
LE Y
62 L
=35M
M
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 35
EX
HIB
IT D
PA
TE
NT
L.R
. 3-1
(G) C
HA
RT
6
Pa
rt N
o./M
odel
No.
Pr
oduc
t Nam
e PC
B012
J000
09-5
CA
BLE
ASSY
X1P
HDD
30V
JPC
Unk
now
n SA
TA H
DD W
ITH
10 P
IN F
FC C
ABLE
Y0H
L=1
5MM
PC
BC5D
1003
51-1
SA
TA H
DD W
ITH
10PI
N F
FC C
ABLE
L=3
5MM
U
nkno
wn
SATA
HDD
WIT
H 10
PIN
FFC
CAB
LE R
M8
L=99
MM
LUXSHARE PRECISION INDUSTRY CO., LTD.EX. 1013 - Page 36