EXHIBIT N

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JENAM TECH LLC’S INFRINGEMENT ANALYSIS

U.S. Patent No. 9,923,996 – Google LLC 

Claim 1 

Jenam Tech LLC (“Jenam”) provides evidence of infringement of Claim 1 of U.S. Patent No. 9,923,996 (here

Google LLC (“Google”). In support thereof, Jenam provides the following claim charts. 

“Accused Instrumentalities” as used herein refers to at least one or more websites or web addresses in

www.google.com, stored and/or hosted on one or more servers owned or under the control of Google. These claim infringement, and provide notice of such infringement, by comparing each element of the asserted claims to correspondin

features of the Accused Instrumentalities. These claim charts are not intended to constitute an expert report on infrin

include information provided by way of example, and not by way of limitation. 

The analysis set forth below is based only upon information from publicly available resources regarding the Infri

Google has not yet provided any non-public information. An analysis of Google’s (or other third parties’) technical doc

source code may assist in fully identify all infringing features and functionality. Accordingly, Jenam reserves the right tinfringement analysis once such information is made available to Jenam. Furthermore, Jenam reserves the right to revisas appropriate, upon issuance of a court order construing any terms recited in the asserted claims. 

 Unless otherwise noted, Jenam contends that Google directly infringes the ’996 patent in violation of 35 U.S.C. § 

to sell, making, using, and/or importing the Infringing Instrumentalities. The following exemplary analysis demonstrateotherwise noted, Jenam further contends that the evidence below supports a finding of indirect infringement under 35 Uconjunction with other evidence of liability under one or more of those subsections. Google makes, uses, sells, importsUnited States, or has made, used, sold, imported, or offered for sale in the past, without authority, or induces others to mfor sale in the United States, or has induced others to make, use, sell, import, or offer for sale in the past, without authoriservices that infringe Claim 1 of the ’996 patent, including without limitation, the Accused Instrumentalities. 

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

provision of the Infringing Instrumentalities. However, to the extent that Google attempts to allege that any asserted clamet, Jenam believes and contends that such elements are met under the doctrine of equivalents. More specifically, in its the Infringing Instrumentalities, Jenam did not identify any substantial differences between the elements of the patent cla

features of the Infringing Instrumentalities, as set forth herein. In each instance, the identified feature of the Infringing I

least substantially the same function in substantially the same way to achieve substantially the same result as the corresp

To the extent the chart of an asserted claim relies on evidence about certain specifically-identified Accused In

that, on information and belief, any similarly-functioning instrumentalities also infringes the charted claim. Jenam resinfringement analysis based on other products made, used, sold, imported, or offered for sale by Google. Jenam also reinfringement analysis by citing other claims of the ’996 patent, not listed in the claim chart, that are infringed by the Accufurther reserves the right to amend this infringement analysis by adding, subtracting, or otherwise modifying content in thcolumn of each chart. 

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CLAIM CHARTS

BASED ON INFRINGEMENT ANALYSIS OF GOOGLE

U.S. Patent No. 9,923,996

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June 1, 2020

Claim 1 Accused Instrumentalities

An apparatus comprising: a non‐

transitory memory storing a

network application; and one or

more processors incommunication with the non‐

transitory memory, wherein the

one or more processors execute

the network application such that

the network application is

configured to operate in

accordance with a first protocol

including a transmission control

protocol (TCP), the apparatus,

when operating in accordance

with the first protocol to establish

a TCP connection, configured to:

Google uses an apparatus (e.g., one or more servers, etc.) including a non‐transitory memo

network application (e.g., server software, etc.), and one or more processors in communica

non‐transitory memory, wherein the one or more processors execute the network applicat

the network application is configured to operate in accordance with a first protocol includin

transmission control protocol (TCP).

See excerpt(s) below, for example (emphasis added, if any):

Note: Below is a web page of Google (https://www.google.com/).

communicate a segment including

at least one first synchronize bit;

communicate a first

acknowledgement of thesegment, and at least one second

synchronize bit; and

Google uses the apparatus (e.g., the one or more servers, etc.) that, when operating in acco

the first protocol to establish the TCP connection, is configured for a) communicating a seg

including at least one first synchronize bit; b) communicating a first acknowledgement of th

and at least one second synchronize bit; and c) communicating a second acknowledgement

See excerpt(s) below, for example (emphasis added, if any):

Note: As set forth below, a) is met by 1); b) is met by 2)/3), and c) is met by 4).

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CLAIM CHARTS

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U.S. Patent No. 9,923,996

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communicate a second

acknowledgement;

“The synchronization requires each side to send its own initial sequence number and to rec

confirmation of it in acknowledgment from the other side. Each side must also receive the 

initial sequence number and send a confirming acknowledgment.

1) A ‐‐> B SYN my sequence number is X

2) A <‐‐ B ACK your sequence number is X

3) A <‐‐ B SYN my sequence number is Y

4) A ‐‐> B ACK your sequence number is Y

Because steps 2 and 3 can be combined in a single message this is called the three way (or 

message) handshake.A three way handshake is necessary because sequence numbers are not tied to a global clo

network, and TCPs may have different mechanisms for picking the ISN's. The receiver of th

no way of knowing whether the segment was an old delayed one or not, unless it remembe

sequence number used on the connection (which is not always possible), and so it must ask 

verify this SYN. The three way handshake and the advantages of a clock‐driven scheme are 

[3].”

“Request for Comments” (RFC) document RFC 793 (September 1981) https://tools.ietf.org/

wherein the network application is

further configured to operate in

accordance with a second

protocol that is separate from theTCP, the apparatus, when

operating in accordance with the

second protocol to establish a

second protocol connection,

configured to:

receive, by a second node from a

first node, a packet;

Google uses the apparatus (e.g., the one or more servers, etc.) including the non‐transitory 

storing the network application (e.g., server software, etc.) that is further configured to ope

accordance with a second protocol (e.g., QUIC, etc.) that is separate from the TCP. The app

operating in accordance with the second protocol to establish a second protocol connectio

connection), is configured to: receive, by a second node (e.g., one of a QUIC‐compliant serv

from a first node (e.g., the other one of the QUIC‐compliant server or client), a packet (e.g., 

negotiation packet).

See excerpt(s) below, for example (emphasis added, if any):

Note: Below is a web page of Google (https://www.google.com/).

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Note: As set forth below, QUIC is separate from TCP.

“On the surface, QUIC is very similar to TCP+TLS+HTTP/2 implemented on UDP. ...However

built on top of UDP, it suffers from no such limitations.” https://www.chromium.org/quic

Note: As set forth below, a QUIC connection begins with a client sending a handshake pack

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U.S. Patent No. 9,923,996

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Note: As set forth below, prior to a QUIC connection being established, the QUIC connectio

using the aforementioned handshake.

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detect an idle time period

parameter field in the packet;

Google uses the apparatus (e.g., the one or more servers, etc.) that, when operating in acco

the second protocol (e.g., QUIC, etc.) to establish the second protocol connection (e.g., QU

connection), is configured to: detect an idle time period parameter field (e.g., idle timeout 

field, etc.) in the packet (e.g., QUIC negotiation packet, etc.).

See excerpt(s) below, for example (emphasis added, if any):

Note: As set forth below, a QUIC negotiation packet includes transport parameters that inc

timeout parameter that is detected by a recipient of such packet.

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identify metadata in the idle time

period parameter field for an idletime period, detectable by the

first node, where, after the idletime period is detected, the

second protocol connection isdeemed inactive; and

Google uses the apparatus (e.g., the one or more servers, etc.) that, when operating in acco

the second protocol (e.g., QUIC) to establish the second protocol connection (e.g., QUIC co

configured to: identify metadata (e.g., a value, etc.) in the idle time period parameter field 

timeout parameter field, etc.) for an idle time period, detectable by the first node, where, a

time period is detected, the second protocol connection is deemed inactive.

See excerpt(s) below, for example (emphasis added, if any):

Note: As set forth below, the metadata includes a value in seconds that is encoded as an un

integer.

Note: As set forth below, after the idle time period is detected, the QUIC connection is clos

inactivity.

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CLAIM CHARTS

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U.S. Patent No. 9,923,996

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create or modify, by the second

node and based on the metadata,

a timeout attribute associated

with the second protocolconnection.

Google uses the apparatus (e.g., the one or more servers, etc.) that, when operating in acco

the second protocol (e.g., QUIC) to establish the second protocol connection (e.g., QUIC co

configured to: create or modify, by the second node and based on the metadata (e.g., the v

idle timeout parameter field, etc.), a timeout attribute associated with the second protoco

See excerpt(s) below, for example (emphasis added, if any):

Note: As set forth below, since the idle_timeout value sets the duration of idleness, after w

connection is shutdown, a timeout attribute of the connect is necessarily created or modifi

the value received in the idle_timeout field of the connection negotiation packet.

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Caveat: The notes and/or cited excerpts utilized herein are set forth for illustrative purposes only and are not meant to be limiti

the notes and/or cited excerpts, may or may not be supplemented or substituted with different excerpt(s) of the relevant referen

the extent any error(s) and/or omission(s) exist herein, all rights are reserved to correct the same in connection with any subsequ

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