EXHIBIT 10 

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 1 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

1

Analysis of Infringement of U.S. Patent No. 7,216,301 by Microchip Technology Incorporated

Plaintiffs Caddo Systems, Inc. and 511 Technologies, Inc. (“Caddo”), provide this final and exemplary infringement analysis 

with respect infringement of U.S. Patent No. 7,216,301, entitled “ACTIVE PATH MENU NAVIGATION SYSTEM” (the “’301 

patent”) by Microchip Technology Incorporated (“Microchip”). The following chart illustrates an exemplary analysis regarding 

infringement by Microchip’s products and services (“’301 Accused Instrumentalities”):

(i) web pages and content, including user interfaces such as a hierarchical information structure, to be interactively presented 

in browsers, including, without limitation, the web pages and content accessible via https://www.microchip.com/ (as shown 

below) including www.microchipdirect.com and maintained on servers located in and/or accessible from the United States 

under the control of Defendant that allow navigating a multi-level hierarchical information structure, where each level in 

the information structure contains plural items, each item being at least one of a function, a pointer to a location, and a 

pointer to another level; 

(ii) software, including, without limitation, software that allows web pages and content to be interactively presented in and/or 

served to browsers to facilitate navigating within a multi-level hierarchical information structure, where each level in the 

information structure contains plural items, each item being at least one of a function, a pointer to a location, and a pointer 

to another level; and

(iii) computer equipment, including, without limitation, computer equipment that stores, serves, hosts, supports, and/or runs any 

of the foregoing or that allows navigating within a multi-level hierarchical information structure, where each level in the 

information structure contains plural items, each item being at least one of a function, a pointer to a location, and a pointer 

to another level, and any products, devices, systems, and/or components of systems with the same or substantially the same 

technical features and/or functionalities.

 

The analysis set forth below is based largely upon information from publicly available resources regarding the Accused 

Instrumentalities and Microchip’s limited discovery production, as discovery in this matter has not yet been completed. 

Unless otherwise noted, Caddo contends that Microchip directly infringes the ’301 patent in violation of 35 U.S.C. § 271(a) by 

making, using, and/or selling, and/or offering to sell in the United States, and/or importing into the United States, without authority or 

license, the Accused Instrumentalities. 

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 2 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

2

The following exemplary analysis demonstrates that infringement. Unless otherwise noted, Caddo further contends that the 

evidence below supports a finding of indirect infringement under 35 U.S.C. § 271(b) and 35 U.S.C. § 271(c) in conjunction with other 

evidence of liability.

Unless otherwise noted, Caddo believes and contends that each element of each claim asserted herein is literally met through 

Microchip’s provision or importation of the Accused Instrumentalities. However, to the extent that Microchip attempts to allege that 

any asserted claim element is not literally met, Caddo believes and contends that such elements are met under the doctrine of 

equivalents. More specifically, in its investigation and analysis of the Accused Instrumentalities, Caddo did not identify any 

substantial differences between the elements of the patent claims and the corresponding features of the Accused Instrumentalities, as 

set forth herein. In each instance, the identified feature of the Accused Instrumentalities performs at least substantially the same 

function in substantially the same way to achieve substantially the same result as the corresponding claim element.

Caddo reserves the right to supplement and/or amend the positions taken in this infringement analysis, including with respect

to literal infringement and infringement under the doctrine of equivalents, if and when warranted by further information obtained by 

Caddo, including but not limited to information adduced through information exchanges between the parties, fact discovery, expert 

discovery, and/or further analysis. 

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 3 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

3

U.S. Patent 

No. 

7,216,301

Claims

Infringement by the Microchip ’301 Accused Instrumentalities

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 4 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

4

1. A method 

for navigating 

within a 

multi-level 

hierarchical 

information 

structure 

where each 

level in the 

information 

structure 

contains 

plural items, 

each said item 

being at least 

one of a 

function, a 

pointer to a 

location, and 

a pointer to 

another level, 

said method 

comprising 

the steps of:

The ’301 Accused Instrumentalities (“Accused Instrumentalities”) include:

(iv) web pages and content, including user interfaces such as a hierarchical information structure, to be interactively presented 

in browsers, including, without limitation, the web pages and content accessible via https://www.microchip.com/ including 

www.microchipdirect.com and maintained on servers located in and/or accessible from the United States under the control 

of Defendant that allow navigating a multi-level hierarchical information structure, where each level in the information 

structure contains plural items, each item being at least one of a function, a pointer to a location, and a pointer to another 

level; 

(v) software, including, without limitation, software that allows web pages and content to be interactively presented in and/or 

served to browsers to facilitate navigating within a multi-level hierarchical information structure, where each level in the 

information structure contains plural items, each item being at least one of a function, a pointer to a location, and a pointer 

to another level; and

(vi) computer equipment, including, without limitation, computer equipment that stores, serves, hosts, supports, and/or runs any 

of the foregoing or that allows navigating within a multi-level hierarchical information structure, where each level in the 

information structure contains plural items, each item being at least one of a function, a pointer to a location, and a pointer 

to another level, and any products, devices, systems, and/or components of systems with the same or substantially the same 

technical features and/or functionalities.

Direct Infringement

Microchip has directly infringed claims 1-5 and 9 of the ’301 patent under 35 U.S.C. § 271(a) each time that it makes, uses, tests, 

and/or hosts in the United States the Accused Instrumentalities, or products, devices, systems, and/or components of systems, that 

practice the claimed methods described hereinbelow. Microchip also directly infringes each of the Asserted Claims under 35 U.S.C. § 

271(a) each time that it imports the Accused Instrumentalities into the United States.

Indirect Infringement

Microchip has induced and continues to induce infringement by others of claims 1-5 and 9 of the ’301 patent under 35 U.S.C. § 271(b) 

by (a) providing the Accused Instrumentalities to third parties and intending them to use the Accused Instrumentalities; (b) advertising 

these Accused Instrumentalities through Microchip’s own and through third party websites; (c) encouraging customers and other third 

parties to communicate directly with Microchip about the Accused Instrumentalities for purposes of technical assistance and repair as 

well as sales and marketing; (d) providing instructions as to how to use the Accused Instrumentalities in an infringing manner.

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 5 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

5

Microchip has contributed to and continues to contribute to infringement by others of claims 1-5 and 9 of the ’301 patent under 35 

U.S.C. § 271(c) by providing the Accused Instrumentalities, including web pages and content, user interfaces (e.g., hierarchical 

collapsing menu structure, hierarchical information structure, information structure, and/or hierarchical menu structure), software, 

and/or computer equipment as identified above, in the United States without authority, Microchip contributes to the direct 

infringement of third-parties including end users of the Accused Instrumentalities.

To the extent that the preamble of Claim 1 is a limitation, the ’301 Accused Instrumentalities provide, or support the provision of, a 

method as described below.

The ’301 Accused Instrumentalities provide a method for navigating within a multi-level hierarchical information structure where 

each level in the information structure contains plural items, each said item being at least one of a function, a pointer to a location, and 

a pointer to another level (e.g., the ’301 Accused Instrumentalities provide a method for navigating within a multi-level hierarchical 

collapsing menu structure where each level in the information structure contains plural items, each said item being at least one of a 

function, a pointer to a location, and a pointer to another level (e.g., “Products” includes “Amplifiers and Linear,” which includes 

“Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain 

Amplifiers,” and “DC Power Current Monitors”)) as shown below:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 6 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

6

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000935:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 7 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

7

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 8 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

8

See https://www.microchip.com/ (last accessed June 11, 2021).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 9 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

9

providing a 

graphical user 

menu system 

displaying the 

items of a 

given level of 

the 

hierarchical 

information 

structure and 

enabling 

selection 

thereof; and

The ’301 Accused Instrumentalities provide a graphical user menu system displaying the items of a given level of the hierarchical 

information structure and enabling selection thereof.

For example, the ’301 Accused Instrumentalities provide a graphical user menu system displaying the items of a given level of the 

hierarchical information structure and enabling selection thereof (e.g., “Products” displays and enables selection of items of a given 

level, such as “Amplifiers and Linear” and items within that same level).

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See MCHP-CADDO_0000935.

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 10 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

10

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 11 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

11

See MCHP-CADDO_0001040-41.

As another example, the ’301 Accused Instrumentalities provide a graphical user menu system displaying the items of a given level of 

the hierarchical information structure and enabling selection thereof (e.g., “Products” displays and enables selection of items of a 

given level, such as “Microcontrollers and Microprocessors” and items within that same level “Analog,” “Amplifiers and Linear ICs,” 

“Clock and Timing” “Data Converters,” etc.) as shown below:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 12 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

12

See https://www.microchip.com/ (last accessed June 8, 2021).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 13 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

13

dynamically 

constructing 

an Active 

Path as a 

sequence of 

active links as 

items are 

selected using 

the graphical 

user menu 

system, with 

one said 

active link 

corresponding 

to each of the 

items 

selected, said 

active links 

providing 

direct access 

to one of a 

function, 

corresponding 

level and 

menu item 

without the 

need to 

navigate 

using said 

The ’301 Accused Instrumentalities dynamically construct an Active Path, which has been construed by this Court (Dkt. 34) as a 

sequence of links dynamically created as a menu item is navigated, as a sequence of active links as items are selected using the 

graphical user menu system, with one said active link corresponding to each of the items selected, said active links providing direct 

access to one of a function, corresponding level and menu item without the need to navigate using said graphical user menu system.

For example, the ’301 Accused Instrumentalities dynamically construct a sequence of links dynamically created as a menu item is 

navigated, as the sequence of active links as items are selected (e.g., the ’301 Accused Instrumentalities dynamically construct a 

sequence of links dynamically created (e.g., “Amplifiers and Linear—Comparators”) as the sequence of active links as items are 

selected (e.g., as “Amplifiers and Linear” and “Comparators” are selected)), with one said active link corresponding to each of the 

items selected. Said active links provide direct access to one of a function, corresponding level and menu item without the need to 

navigate using said graphical user menu system (e.g., the ’301 Accused Instrumentalities’ sequence of links dynamically created as a 

menu item is navigated “Amplifiers and Linear—Comparators” corresponds to each of the items sequentially selected, including 

“Amplifiers and Linear” and “Comparators”).

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000935:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 14 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

14

graphical user 

menu system;

As another example, the ’301 Accused Instrumentalities dynamically construct a sequence of links dynamically created as a menu 

item is navigated, as the sequence of active links as items are selected (e.g., links in this path “Products / Microcontrollers and 

Microprocessors / 8-bit MCUs / AVR® MCUs / AVR® DA,” as a sequence of hierarchical active links as items are selected (e.g., as 

each hierarchical active link in the path “Products / Microcontrollers and Microprocessors / 8-bit MCUs / AVR® MCUs / AVR® DA” 

is selected, and the active links correspond to each of the items selected using the graphical user menu system) without the need to 

navigate using said graphical user menu system as shown below: 

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 15 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

15

See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus/avr-mcus/avr-da (last accessed June

7, 2021); see also:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 16 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

16

Id. at https://www.microchip.com/.

See also:

Id. at https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors.

See also:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 17 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

17

Id. at https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus.

See also: 

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 18 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

18

Id. at https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus/avr-mcus (last accessed Jun. 8, 

2021).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 19 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

19

each said 

active link 

enabling the 

user to 

directly 

browse all 

items on any 

given level of 

the 

hierarchical 

information 

structure 

including all 

hierarchically 

subordinate 

items without 

affecting the 

Active Path.

Each active link of the ’301 Accused Instrumentalities enables the user to directly browse all items on any given level of the 

hierarchical information structure including all hierarchically subordinate items without affecting the Active Path, which has been 

construed by this Court (Dkt. 34) as a sequence of links dynamically created as a menu item is navigated.

For example, each active link in the ’301 Accused Instrumentalities enables the user to directly browse all items on any given level of 

the hierarchical information structure including all hierarchically subordinate items without affecting the sequence of links 

dynamically created as a menu item is navigated (e.g., the ’301 Accused Instrumentalities enable the user to directly browse all items 

under “Amplifiers and Linear” such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” without affecting the a sequence of links 

dynamically created as a menu item is navigated “Amplifiers and Linear—Comparators”) as shown below:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 20 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

20

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020).

See also MCHP-CADDO_0000935:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 21 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

21

As another example, each active link in the ’301 Accused Instrumentalities enables the user to directly browse all items on any given 

level of the hierarchical information structure including all hierarchically subordinate items without affecting the sequence of links 

dynamically created as a menu item is navigated (e.g., the ’301 Accused Instrumentalities enable the user to directly browse all items 

on any given level of the hierarchical information structure including all hierarchically subordinate items in the path “Products / 

Microcontrollers and Microprocessors / 8-bit MCUs / AVR® MCUs” without affecting the a sequence of links dynamically created as 

a menu item is navigated “Products—Microcontrollers and Microprocessors”) as shown below:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 22 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

22

See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus/avr-mcus/avr-da (last visited Jun. 7, 

2021).

For example, the user can directly browse all items on any given level of the hierarchical information structure including all 

hierarchically subordinate items in the path “Products / Microcontrollers and Microprocessors” such as “Product Categories,” 

“Development Tools,” “Software Solutions,” “Application Design Centers,” and “Product Selections” without affecting the path 

“Products / Microcontrollers and Microprocessors” (e.g., the user can browse items under “Product Categories,” “Development 

Tools,” “Software Solutions,” “Application Design Centers,” or “Product Selections” without affecting the path “Products / 

Microcontrollers and Microprocessors.”).

As another example, each active link in the ’301 Accused Instrumentalities enable the user to directly browse all items on any given 

level of the hierarchical information structure (e.g., all items under “Products / Microcontrollers and Microprocessors”) including all 

hierarchically subordinate items (e.g., browsing “Development tools” allows browsing of subordinate items such as products 

associated with “Part Number: DM164136” or “Part Number: DM330028”) without affecting the sequence of links dynamically 

created as a menu item is navigated as shown below:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 23 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

23

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 24 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

24

See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors#Development%20Tools (last accessed Jun. 8, 

2021).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 25 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

25

2. The 

method for 

navigating 

according to 

claim 1, 

further 

comprising: 

providing 

pre-defined 

short-cuts 

enabling 

direct access 

to a given 

item; and

The ’301 Accused Instrumentalities provide pre-defined short-cuts enabling direct access to a given item.

For example, the ’301 Accused Instrumentalities provide pre-defined short-cuts enabling direct access to a given item (e.g., the ’301 

Accused Instrumentalities provide pre-defined shortcuts, such as “Amplifiers and Linear” or “Comparators” in the collapsing menu, 

enabling direct access to a given menu item). 

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000935:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 26 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

26

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 27 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

27

See MCHP-CADDO_0001040-41.

For example, the ’301 Accused Instrumentalities provide pre-defined short-cuts enabling direct access to a given menu item (e.g., the 

’301 Accused Instrumentalities provide pre-defined shortcuts, such as “AVR® MCUs” and “AVR® DA,” or “New Products,” that 

enable direct access to those items), as shown below:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 28 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

28

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 29 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

29

Id. at https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus (last accessed Jun. 8, 2021).

See also https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus/avr-mcus/avr-da:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 30 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

30

See also https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus/avr-mcus (e.g., providing predefined shortcuts that enable direct access to the item “AVR® DA”):

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 31 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

31

See also:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 32 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

32

Id. at https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus/avr-mcus/avr-da.

As another example, the ’301 Accused Instrumentalities provide pre-defined short-cuts enabling direct access to a given menu item 

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 33 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

33

(e.g., the ’301 Accused Instrumentalities provide pre-defined shortcuts, such as “CAN 2.0 MCUs” that enable direct access to those 

items), as shown below:

See https://www.microchip.com/ (last accessed June 8, 2021).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 34 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

34

dynamically 

constructing 

the Active 

Path when a 

pre-defined 

short-cut is 

executed, 

with one said 

active link 

corresponding 

to each of the 

items 

necessary to 

access said 

given item 

using said 

graphical user 

menu system.

The ’301 Accused Instrumentalities dynamically construct the Active Path, which has been construed by this Court (Dkt. 34) as a 

sequence of links dynamically created as the menu system is navigated, when a pre-defined short-cut is executed, with one said active 

link corresponding to each of the menu items necessary to access said given menu item using said graphical user menu system.

For example, the ’301 Accused Instrumentalities dynamically construct the sequence of links dynamically created as the menu system 

is navigated when a pre-defined short-cut is executed, with one said active link corresponding to each of the menu items necessary to 

access said given menu item using said graphical user menu system (e.g., the sequence of links dynamically created as a menu item is 

navigated is automatically constructed when “Amplifiers and Linear” or “Comparators” is executed, with each active link “Amplifiers 

and Linear” or “Comparators” corresponding to each of the menu items necessary to access the given menu item using the graphical 

user menu system). 

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000935:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 35 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

35

As another example, the ’301 Accused Instrumentalities dynamically construct the sequence of links dynamically created as the menu 

system is navigated when a pre-defined short-cut is executed (e.g., when the short-cut corresponding to the link “CAN 2.0 MCUs” is 

executed), with one said active link (e.g., the link “CAN 2.0 MCUs” in the path “Products / Interface and Connectivity / CAN / CAN 

2.0 MCUs”) corresponding to each of the menu items necessary to access said given menu item using said graphical user menu system 

(e.g., the link “CAN 2.0 MCUs” corresponding to the menu item “CAN 2.0 MCUs”), as shown below:

See, e.g., https://www.microchip.com/en-us/products/interface-and-connectivity/can/can-2-0-mcus; see also id.:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 36 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

36

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 37 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

37

3. The method 

for navigating 

according to 

claim 1, 

wherein 

rolling over a 

selected 

active link 

triggers the 

display of 

sibling items 

on the 

hierarchically 

subordinate 

levels 

associated 

with said 

selected 

active link.

The ’301 Accused Instrumentalities roll over a selected active link to trigger the display of sibling items on the hierarchically 

subordinate levels associated with said selected active link.

For example, for the ’301 Accused Instrumentalities, rolling over a selected active link triggers the display of sibling items on the 

hierarchically subordinate levels associated with said selected active link (e.g., the ’301 Accused Instrumentalities allow rolling over 

the link “Amplifiers and Linear” to trigger the display of sibling items on the hierarchically subordinate levels associated with the 

selected active link “Amplifiers and Linear” such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense 

Amplifiers,” “Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000935:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 38 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

38

As another example, in the ’301 Accused Instrumentalities, rolling over a selected active link triggers the display of sibling items on 

the hierarchically subordinate levels associated with said selected active link (e.g., rolling over and selecting “Microcontrollers and 

Microprocessors” in “Products / Microcontrollers and Microprocessors / 8-bit MCUs”) to trigger the display of sibling menu items on 

the hierarchically subordinate levels (e.g., “Product Categories,” “Developments,” “Software Solutions,” “Application Design 

Centers,” and “Product Selections”), as shown below:

See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors (last accessed Jun. 8, 2021).

To the extent Microchip contends that the ’301 Accused Instrumentalities do not literally meet the limitation of “rolling over a selected 

active link triggers the display of sibling items on the hierarchically subordinate levels associated with said selected active link,” the 

limitation is met under the doctrine of equivalents by the ’301 Accused Instrumentalities because they perform substantially the same 

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 39 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

39

function (displaying the sibling menu items on the hierarchically subordinate levels such as “Product Categories,” “Developments,” 

“Software Solutions,” “Application Design Centers,” and “Product Selections”) in substantially the same way (e.g., displaying the 

sibling menu items that are on the hierarchically subordinate levels associated with the link “Microcontrollers and Microprocessors”) to 

produce substantially the same result (e.g., sibling menu items on the level associated with the link “Microcontrollers and 

Microprocessors” are displayed and available for selection).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 40 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

40

4. The method 

for navigating 

according to 

claim 1, 

wherein 

selecting a 

given active 

link triggers 

the execution 

of a function 

associated 

with said 

given active 

link.

The ’301 Accused Instrumentalities select a given active link to trigger the execution of a function associated with said given active 

link.

For example, the ’301 Accused Instrumentalities allow selecting a given active link to trigger the execution of a function associated 

with said given active link (e.g., selecting a given active link such as “Amplifiers and Linear” triggers the execution of a function, 

such as displaying sibling menus (e.g., “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors”) or directing user to certain content) as shown 

below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000935.

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 41 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

41

As another example, selecting a given active link triggers the execution of a function associated with said given active link (e.g., 

selecting a given active link such as “CAN” in the path “Products / Interface and Connectivity / CAN / CAN 2.0 MCUs” triggers the 

execution of a function, such as displaying sibling menus (e.g., “MCU, DSC and MPU Products,” “Interface and Connectivity 

Products,” “Development Tools,” and “Documentation” associated with “CAN”) or directing user to certain content such as content 

under the link “CAN”), as shown below:

See, e.g., https://www.microchip.com/en-us/products/interface-and-connectivity/can (last accessed June 8, 2021); see also 

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 42 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

42

See https://www.microchip.com/en-us/products/interface-and-connectivity/can/can-2-0-mcus (last accessed Jun. 8, 2021).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 43 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

43

5. The method 

for navigating 

according to 

claim 1, 

wherein 

selecting a 

given active 

link triggers 

display of 

information 

associated 

with said 

given active 

link.

The ’301 Accused Instrumentalities select a given active link to trigger the display of information associated with said given active 

link.

For example, the ’301 Accused Instrumentalities allow selecting a given active link to trigger the display of information associated 

with said given active link (e.g., the ’301 Accused Instrumentalities allow selecting the link “Amplifiers and Linear” to trigger display 

of information (e.g., displaying “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” “Comparators,” 

“Programmable Gain Amplifiers,” and “DC Power Current Monitors”) associated with the link “Amplifiers and Linear”) as shown 

below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000935:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 44 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

44

As another example, selecting a given active link triggering the execution of a function associated with said given active link (e.g., 

selecting a given active link such as “CAN” in the path “Products / Interface and Connectivity / CAN / CAN 2.0 MCUs” triggers the 

execution of a function, such as displaying sibling menus (e.g., “MCU, DSC and MPU Products,” “Interface and Connectivity 

Products,” “Development Tools,” and “Documentation” associated with “CAN”) or directing user to certain content such as content 

under the link “CAN”), as shown below:

See, e.g., https://www.microchip.com/en-us/products/interface-and-connectivity/can (last accessed June 8, 2021).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 45 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

45

9. A method 

for navigating 

within a 

multi-level 

hierarchical 

information 

structure 

where each 

level in the 

structure 

contains 

plural items, 

each said item 

being at least 

one of a 

function, a 

pointer to a 

location, and 

a pointer to 

another level, 

said method 

comprising 

the steps of:

To the extent that the preamble of claim 9 is a limitation, the ’301 Accused Instrumentalities provide, or support the provision of, a 

method for navigating within a multi-level hierarchical information structure where each level in the structure contains plural items, 

each said item being at least one of a function, a pointer to a location, and a pointer to another level.

For example, the ’301 Accused Instrumentalities provide a method for navigating within a multi-level hierarchical information 

structure where each level in the structure contains plural items, each said item being at least one of a function, a pointer to a location, 

and a pointer to another level (e.g., the ’301 Accused Instrumentalities provide a method for navigating within a multi-level 

hierarchical collapsing menu structure where each level in the information structure contains plural items, each said item being at least 

one of a function, a pointer to a location, and a pointer to another level (e.g., “Products” includes “Amplifiers and Linear,” which 

includes “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” “Comparators,” “Programmable Gain 

Amplifiers,” and “DC Power Current Monitors”)) as shown below: 

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 46 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

46

See also MCHP-CADDO_0000935:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 47 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

47

See MCHP-CADDO-0000931.

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 48 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

48

As another example, , the ’301 Accused Instrumentalities provide a method for navigating within a multi-level hierarchical 

information structure where each level in the structure contains plural items, each said item being at least one of a function, a pointer 

to a location, and a pointer to another level (e.g., the ’301 Accused Instrumentalities provide a method for navigating within a multilevel hierarchical collapsing menu structure where each level in the information structure contains plural items, each said item being at 

least one of a function, a pointer to a location, and a pointer to another level (e.g., “Products” includes “Amplifiers and Linear,” which 

includes “Operational Amplifiers ICs,” “Instrumentation Amplifiers ICs,” “Current Sense Amplifiers ICs,” “Comparators ICs,” 

“Programmable Gain Amplifiers ICs,” and “Current/Voltage/Power Monitor ICs”)) as shown below: 

See https://www.microchip.com/en-us/products/amplifiers-and-linear-ics/comparator-ics (last accessed June 8, 2021).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 49 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

49

displaying a 

graphic 

element 

representing a 

root of the 

hierarchical 

information 

structure;

The ’301 Accused Instrumentalities display a graphic element representing a root of the hierarchical information structure.

For example, the ’301 Accused Instrumentalities provide displaying a graphic element representing a root of the hierarchical 

information structure (e.g., the ’301 Accused Instrumentalities display a number of graphic elements each representing a root of the 

hierarchical information structure) as shown below: 

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020) (annotated). 

See MCHP-CADDO_0000935 (annotated).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 50 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

50

As another example, the ’301 Accused Instrumentalities provide displaying a graphic element (e.g., graphic element “Microcontrollers 

and Microprocessors >”) representing a root of the hierarchical information structure as shown below:

See https://www.microchip.com/ (last accessed Jun. 8, 2021)

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 51 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

51

browsing the 

hierarchical 

information 

structure by 

rolling over 

said graphic 

element using 

a pointing 

device, 

wherein 

browsing 

results in the 

display of 

sibling items 

or 

hierarchically 

subordinate 

items;

The ’301 Accused Instrumentalities browse the hierarchical information structure by rolling over said graphic element using a 

pointing device, wherein browsing results in the display of sibling items or hierarchically subordinate items. 

For example, the ’301 Accused Instrumentalities allow browsing the hierarchical information structure by rolling over said graphic 

element using a pointing device (e.g., by rolling over, via a mouse, “Applications and Linear” or the “down arrow” or the “side 

arrow”), wherein browsing results in the display of sibling items or hierarchically subordinate items (e.g., browsing results in the 

display of items such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” “Comparators,” 

“PGAs,” and “DC Power Current Monitors”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000934:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 52 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

52

As another example, the ’301 Accused Instrumentalities allow browsing the hierarchical information structure by rolling over said 

graphic element using a pointing device (e.g., by rolling over, via a mouse, “Interface and Connectivity”), wherein browsing results in 

the display of sibling items or hierarchically subordinate items (e.g., browsing results in the display of sibling or subordinate items 

such as “CAN” and “CAN 2.0 MCUs””) as shown below:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 53 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

53

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 54 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

54

https://www.microchip.com/ (last accessed Jun. 8, 2021); see also:

https://www.microchip.com/en-us/products/interface-and-connectivity/can/can-2-0-mcus (last accessed Jun. 8, 2021).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 55 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

55

selecting one 

of the 

displayed 

items;

The ’301 Accused Instrumentalities selects one of the displayed items.

For example, the ’301 Accused Instrumentalities allow selecting one of the displayed items (e.g., selecting “Amplifiers and Linear”).

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000935:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 56 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

56

See also https://www.microchip.com/en-us/products/amplifiers-and-linear-ics/comparator-ics (last accessed June 8, 2021).

See also https://www.microchip.com/ (last accessed Jun. 8, 2021) (selecting “CAN 2.0 MCUs”);

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 57 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

57

dynamically 

constructing 

an Active 

Path as a 

sequence of 

active links as 

items are 

selected, with 

one said 

active link 

corresponding 

to each of the 

items 

selected, said 

active links 

providing 

direct access 

to one of a 

function, 

corresponding 

level and item 

without the 

need to 

navigate from 

the root of the 

hierarchical 

information 

structure;

The ’301 Accused Instrumentalities dynamically construct an Active Path, which has been construed by this Court (Dkt. 34) as a 

sequence of links dynamically created as a menu item is navigated, as a sequence of active links as items are selected, with one said 

active link corresponding to each of the items selected, said active links providing direct access to one of a function, corresponding 

level and item without the need to navigate from the root of the hierarchical information structure.

For example, the ’301 Accused Instrumentalities dynamically construct a sequence of links dynamically created as a menu item is 

navigated (e.g., the ’301 Accused Instrumentalities dynamically constructed sequence of links dynamically created as a menu item is 

navigated (e.g., “Amplifiers and Linear—Comparators”) as a sequence of active links as items are selected (e.g., as “Amplifiers and 

Linear” and “Comparators” are selected)), with one said active link corresponding to each of the items selected, said active links 

providing direct access to one of a function, corresponding level and item without the need to navigate from the root of the 

hierarchical information structure (e.g., the ’301 Accused Instrumentalities’ sequence of links dynamically created as a menu item is 

navigated “Amplifiers and Linear—Comparators” corresponds to each of the items sequentially selected, including “Amplifiers and 

Linear” and “Comparators”), as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020). 

See also MCHP-CADDO_0000935:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 58 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

58

See also https://www.microchip.com/en-us/products/amplifiers-and-linear-ics/comparator-ics (last accessed June 8, 2021) below:

See also MCHP-CADDO_0001040-41:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 59 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

59

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 60 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

60

As another example, the ’301 Accused Instrumentalities dynamically construct a sequence of links dynamically created as a menu 

item is navigated (e.g., links in the path “Products / Microcontrollers and Microprocessors / 8-bit MCUs / AVR® MCUs / AVR® 

DA” are dynamically created as their corresponding menu item is navigated) as a sequence of active links as items are selected (e.g., 

as menu items corresponding to the path “Products / Microcontrollers and Microprocessors / 8-bit MCUs / AVR® MCUs / AVR® 

DA” are selected)), with one said active link corresponding to each of the items selected (e.g., each link in “Products / 

Microcontrollers and Microprocessors / 8-bit MCUs / AVR® MCUs / AVR® DA” corresponds to an item selected), said active links 

providing direct access to one of a function, corresponding level and item without the need to navigate from the root of the 

hierarchical information structure (e.g., the links in “Products / Microcontrollers and Microprocessors / 8-bit MCUs / AVR® MCUs / 

AVR® DA” provide direct access to “Overview,” “Get Started,” “Functional Safety,” “Evaluation Boards,” “System Features,” and 

“Parametric Chart”, or direct access to content, level, or items) as shown below: 

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 61 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

61

See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus/avr-mcus/avr-da (last accessed Jun. 

8, 2021).

See also:

Id. at https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors.

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 62 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

62

See also:

Id. at https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus.

See also: 

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 63 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

63

Id. at https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus/avr-mcus.

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 64 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

64

each said 

active link 

enabling the 

user to 

directly 

browse all 

items on any 

given level of 

the 

hierarchical 

information 

structure 

including all 

hierarchically 

subordinate 

items without 

affecting the 

Active Path.

Each said active link in the ’301 Accused Instrumentalities enables user to directly browse all items on any given level of the 

hierarchical information structure including all hierarchically subordinate items without affecting the Active Path, which has been 

construed by this Court (Dkt. 34) as a sequence of links dynamically created as a menu item is navigated.

For example, each active link in the ’301 Accused Instrumentalities enables the user to directly browse all items on any given level of 

the hierarchical information structure including all hierarchically subordinate items without affecting the sequence of links

dynamically created as a menu item is navigated (e.g., the ’301 Accused Instrumentalities enable the user to directly browse all items 

under “Amplifiers and Linear” such as “Operational Amplifiers,” “Instrumentation Amplifiers,” “Current Sense Amplifiers,” 

“Comparators,” “Programmable Gain Amplifiers,” and “DC Power Current Monitors” without affecting the sequence of links 

dynamically created as a menu item “Amplifiers and Linear—Comparators”) as shown below:

See, e.g., https://www.microchip.com/design-centers/amplifiers-linear/comparators (last visited Feb. 10, 2020).

See also MCHP-CADDO_0000935:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 65 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

65

As another example, each active link in the ’301 Accused Instrumentalities enables the user to directly browse all items on any given 

level of the hierarchical information structure including all hierarchically subordinate items without affecting the sequence of links 

dynamically created as a menu item is navigated (e.g., the ’301 Accused Instrumentalities enable the user to directly browse all items 

under “Automotive Solutions” such as “Automotive Products,” including all hierarchically subordinate items such as 

“Microcontrollers,” “Analog Products,” “Connectivity,” “Automotive Touch,” “Car Access,” “memory Products,” “High Temperature

Products,” “Timing Solutions,” and “Automotive Security” without affecting the sequence of links (e.g., without affecting the links in 

“Home / Automotive Solutions / Automotive Applications”) dynamically created as a menu item is navigated) as shown below:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 66 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

66

See, e.g., https://www.microchip.com/design-centers/automotive-solutions (last visited Feb. 10, 2020). 

See also:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 67 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

67

See MCHP-CADDO-0000931.

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 68 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

68

As another example, each active link in the ’301 Accused Instrumentalities enabling the user to directly browse all items on any given 

level of the hierarchical information structure including all hierarchically subordinate items without affecting the sequence of links 

dynamically created as a menu item is navigated (e.g., the ’301 Accused Instrumentalities enable the user to directly browse all items 

on any given level of the hierarchical information structure including all hierarchically subordinate items in the path “Products / 

Microcontrollers and Microprocessors / 8-bit MCUs / AVR® MCUs” without affecting the a sequence of links dynamically created as 

a menu item is navigated “Products / Microcontrollers and Microprocessors”) as shown below:

See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors/8-bit-mcus/avr-mcus/avr-da (last visited Jun. 7, 

2021).

For example, the user can directly browse all items on any given level of the hierarchical information structure including all 

hierarchically subordinate items in the path “Products / Microcontrollers and Microprocessors” such as “Product Categories,” 

“Development Tools,” “Software Solutions,” “Application Design Centers,” and “Product Selections” without affecting the path 

“Products / Microcontrollers and Microprocessors” (e.g., the user can browse items under “Product Categories,” “Development 

Tools,” “Software Solutions,” “Application Design Centers,” or “Product Selections” without affecting the path “Products / 

Microcontrollers and Microprocessors.”).

As another example, each active link in the ’301 Accused Instrumentalities enables the user to directly browse all items on any given 

level of the hierarchical information structure (e.g., all items under “Products / Microcontrollers and Microprocessors”) including all 

hierarchically subordinate items (e.g., browsing “Development tools” allows browsing of subordinate items such as products 

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 69 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

69

associated with “Part Number: DM164136” or “Part Number: DM330028”) without affecting the sequence of links dynamically 

created as a menu item is navigated as shown below:

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 70 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

70

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 71 of 72
Plaintiffs’ Final Infringement Contentions 

Civil Action No.: 6:20-cv-245

Claim Chart re: U.S. Patent No. 7,216,301

71

See https://www.microchip.com/en-us/products/microcontrollers-and-microprocessors#Development%20Tools (last accessed Jun. 8, 

2021).

Case 6:20-cv-00245-ADA Document 48-8 Filed 11/09/21 Page 72 of 72