EXHIBIT D

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US8311805 TCL A1 (“The accused product”)

1. A method, performed in a 

character entry system, for 

interrelating character strings 

so that an incomplete input 

character string can be 

completed by selection of a 

presented character string, the 

method comprising:

The accused product practices a method, performed in a character entry system (e.g., predictive text 

system of the accused product), for interrelating character strings so that an incomplete input 

character string can be completed by selection of a presented character string (e.g., selection of 

suggested selectable words).

https://shop.tracfone.com/shop/en/tracfonestore/tf-alcatel-tcl-a1-a501dl

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https://files.bbystatic.com/zNtiTLuJOBf9%2F7gMzsOKAw%3D%3D/B6A1A272-A51A-4B11-

B1F2-87BB0077BD49.pdf

computing relationship scores 

for individual character strings 

in the system from documents 

stored in memory of the 

character entry system, the 

relationship scores consisting 

of a function consisting of cooccurrence scores between 

pairs of distinct character 

strings stored in a single matrix 

created from the character 

strings in the stored documents;

The accused product practices computing relationship scores for individual character strings in the 

system from documents (e.g., Notes, message mail, etc.) stored in memory (e.g., memory of the 

accused product) of the character entry system (e.g., predictive text system of the accused product), 

the relationship scores consisting of a function consisting of co-occurrence scores between pairs of 

distinct character strings stored in a single matrix created from the character strings in the stored 

documents.

As shown below, various character strings are associated with each other based on their mutual cooccurrence with adjacency. For instance, when a couple of paragraphs, hereinafter referred to as 

“The Combined Essay” with phrase “James Maxwell”, “James Maxima”, and "James Michener" 

are typed, and therefore input to the predictive text system of the accused product, the predictive 

text system of the accused product, based on the frequency of mutual co-occurrence of the string 

“James” with “Maxwell”, “Maxima”, and “Michener”, in the given order, start providing selectable 

character strings when “James m” is typed. The two selectable character strings, among others, are: 

Maxwell, and Maxima. For the reliability of the demonstration, The combined Essay is typed five 

times. The frequency of occurrence of “James Maxwell”, “James “Maxima”, and “James Michener” 

is 105, 50, and 20 respectively calculated over The Combined Essay repeated for five times. 

As shown below, since pairs of strings, for example, “James” and “Maxwell” has adjacently 

appeared for the greatest number of times, 105 to be precise, in comparison to the other pairs of 

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strings with “James” as one of the strings, Maxwell appears as a selectable option followed by 

“Maxima”, since the number of adjunct appearances of “James” with “Maxima” is 50.

Shown below is a Matrix depicting association of character string “James” with character strings 

“Maxwell”, “Maxima”, and “Michener”. 

Character String Matrix Vis a Vis the paragraphs

Character 

String-1

Character 

String-2

Number of co-occurrence of the Character String-1 and Character 

String-2, with both being adjacent to each other in that order 

 (Per 5 entry of “The Combined Essay”)

James Maxima 50 (10 James Maxima) 

James Maxwell 105 (21 James Maxwell)

James Michener 4 (20 James Michener)

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The Combined Essay, Part-1

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The Combined Essay, Part-2

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The Combined Essay, Part-3

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The Combined Essay, Part-4

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The Combined Essay, Part-5

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The Combined Essay, Part-6

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The Combined Essay, Part-7

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The Combined Essay, Part-8

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The Combined Essay, Part-9

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in response to inputting of a 

string of individual characters 

that exceeds a specified 

threshold, identifying at least 

one selectable character string 

from among contextual 

associations that can complete 

the input character string in 

context based upon an overall 

ranking score computed as a 

function of a relationship score 

and at least one other score; and

The accused product practices in response to inputting of a string of individual characters that 

exceeds a specified threshold (e.g., inputting a starting character of a word), identifying at least one 

selectable character string (e.g., predicting selectable words for user selection) from among 

contextual associations that can complete the input character string in context based upon an overall 

ranking score computed as a function of a relationship score and at least one other score.

As shown below, since pairs of strings, for example, “James” and “Maxwell” has adjacently 

appeared for the most number of times, 105 to be precise, in comparison to the other pairs of strings 

with “James” as one of the strings, Maxwell appears as a selectable option followed by “Maxima”, 

since the number of adjacent appearances of “James” with “Maxima” is 50 and which is greater than 

the adjacent appearance of “James” with “Michener” which stands at 20. 

Shown below is a Matrix depicting association of character string “James” with character strings 

“Maxwell”, “Maxima”, and “Michener”. 

Character String Matrix Vis a Vis the paragraphs

Character 

String-1

Character 

String-2

Number of co-occurrence of the Character String-1 and Character 

String-2, with both being adjacent to each other in that order 

 (Per 5 entry of “The Combined Essay”)

James Maxima 50 (10 James Maxima) 

James Maxwell 105 (21 James Maxwell)

James Michener 4 (20 James Michener)

When number of adjacently appearance of pairs of strings become same, the predictive text system 

suggests a word from the two based on some other relationship between them such as alphabetical 

order of the words or recently used word.

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The Combined Essay, Part-1

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The Combined Essay, Part-2

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The Combined Essay, Part-3

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The Combined Essay, Part-4

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The Combined Essay, Part-5

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The Combined Essay, Part-6

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The Combined Essay, Part-7

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The Combined Essay, Part-8

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The Combined Essay, Part-9

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providing the identified at least 

one selectable character string 

to a user for selection.

The accused product practices providing the identified at least one selectable character string (e.g., 

suggesting words for user selection) to a user for selection (e.g., user can select a desired word).

As shown below, since pairs of strings, for example, “James” and “Maxwell” has adjacently 

appeared for the most number of times, 105 to be precise, in comparison to the other pairs of strings 

with “James” as one of the strings, Maxwell appears as a selectable option followed by “Maxima”, 

since the number of adjacent appearances of “James” with “Maxima” is 50 and which is greater than 

the adjacent appearance of “James” with “Michener” which stands at 20. 

Shown below is a Matrix depicting association of character string “James” with character strings 

“Maxwell”, “Maxima”, and “Michener”. 

Character String Matrix Vis a Vis the paragraphs

Character 

String-1

Character 

String-2

Number of co-occurrence of the Character String-1 and Character 

String-2, with both being adjacent to each other in that order 

 (Per 5 entry of “The Combined Essay”)

James Maxima 50 (10 James Maxima) 

James Maxwell 105 (21 James Maxwell)

James Michener 4 (20 James Michner)

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The Combined Essay, Part-1

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The Combined Essay, Part-2

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The Combined Essay, Part-3

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The Combined Essay, Part-4

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The Combined Essay, Part-5

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The Combined Essay, Part-6

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The Combined Essay, Part-7

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The Combined Essay, Part-8

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The Combined Essay, Part-9

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2. The method of claim 1, 

wherein each relationship score 

represents the contextual 

association between an 

individual character string and 

another character string based 

upon co-occurrence of 

character strings relative to 

each other.

The accused product practices such that each relationship score represents the contextual association 

between an individual character string and another character string based upon co-occurrence of 

character strings relative to each other.

As shown below, since pairs of strings, for example, “James” and “Maxwell” has adjacently 

appeared for the most number of times, 105 to be precise, in comparison to the other pairs of strings 

with “James” as one of the strings, Maxwell appears as a selectable option followed by “Maxima”, 

since the number of adjacent appearances of “James” with “Maxima” is 50 and which is greater than 

the adjacent appearance of “James” with “Michener” which stands at 20. 

Shown below is a Matrix depicting association of character string “James” with character strings 

“Maxwell”, “Maxima”, and “Michener”. 

Character String Matrix Vis a Vis the paragraphs

Character 

String-1

Character 

String-2

Number of co-occurrence of the Character String-1 and Character 

String-2, with both being adjacent to each other in that order 

 (Per 5 entry of “The Combined Essay”)

James Maxima 50 (10 James Maxima) 

James Maxwell 105 (21 James Maxwell)

James Michener 4 (20 James Michner)

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The Combined Essay, Part-1

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The Combined Essay, Part-2

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The Combined Essay, Part-3

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The Combined Essay, Part-4

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The Combined Essay, Part-5

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The Combined Essay, Part-6

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The Combined Essay, Part-7

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The Combined Essay, Part-8

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The Combined Essay, Part-9

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