EXHIBIT C

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US7991784 TCL A1 (“The accused product”)

1. A method, performed 

in a character entry 

system so that 

incomplete input 

character strings input 

by a user interacting 

with the character entry 

system, that are part of a 

series of input character 

strings which establish a 

context for the 

incomplete input 

character string, can be 

completed by a 

selection of a presented 

character string using an 

input device connected 

to the character entry 

system, the method 

comprising

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

of the accused product) so that incomplete input character strings input by a user interacting with the 

character entry system, that are part of a series of input character strings which establish a context for the 

incomplete input character string (e.g., previous appearance of charter strings in adjacent fashion), can be 

completed by a selection of a presented character string (e.g., selection of suggested selectable words) using 

an input device (e.g., Touchscreen of the accused product) connected to the character entry system.

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 contextual 

associations between 

multiple character 

strings based upon 

occurrence of character 

strings relative to each 

other in documents 

present in the character 

entry system, wherein 

the computing 

contextual associations 

comprises:

The accused product practices computing contextual associations between multiple character strings based 

upon occurrence of character strings relative to each other (e.g., number of adjacent co-occurrence of pairs 

of various character strings) in documents (e.g., Notes, message mail, etc.) present in the character entry 

system.

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 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”. 

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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

i) identifying pertinent 

documents present in 

The accused product practices identifying pertinent documents (e.g., stored notes or notes being composed) 

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

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the character entry 

system,

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

ii) creating a list of 

character strings 

contained within 

The accused product practices creating a list of character strings contained within documents in the 

character entry system (e.g., predictive text system of the accused product) and creating an interrelationship 

between distinct character strings (e.g., frequency of adjacent appearance of pairs of character strings) in 

Case 1:20-cv-23178-WPD Document 1-3 Entered on FLSD Docket 07/31/2020 Page 22 of 57
documents in the 

character entry system; 

and

iii) creating an 

interrelationship 

between distinct 

character strings in the 

list using their 

occurrence in the 

documents of the 

character entry system;

the list using their occurrence in the documents of the character entry system (e.g., predictive text system 

of the accused product).

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. 

For calculating mutual co-occurrences of pairs of character strings the accused product must create a list of 

character strings contained in the documents (i.e., previously stored notes or notes being composed).

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

in response to the user 

inputting a specified 

threshold of individual 

The accused product practices in response to the user inputting a specified threshold (e.g., inputting a 

starting character of a word followed by the corresponding preceding word) of individual characters using 

the input device (e.g., Touchscreen of the accused product), identifying at least one selectable character 

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characters using the 

input device, identifying 

at least one selectable 

character string from 

among the character 

strings used in creating 

the computed contextual 

associations that can 

complete the incomplete 

input character string in 

context;

string (e.g., predicting selectable words for user selection) from among the character strings used in creating 

the computed contextual associations that can complete the incomplete input character string in context.

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)

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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 

in a manner suitable for 

selection by the user 

using the input device; 

and

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

suggesting words for user selection) to a user in a manner suitable for selection by the user using the input 

device (e.g., Touchscreen of the accused product).

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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receiving, in the system, 

the user's selection and 

completing the 

incomplete input 

character string based 

upon the selection.

The accused product practices receiving, in the system, the user's selection (e.g., selecting a suggested word 

by user) and completing the incomplete input character string based upon the selection.

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