EXHIBIT J

Case 6:20-cv-00453-ADA Document 1-10 Filed 06/01/20 Page 1 of 9
JENAM TECH LLC’S INFRINGEMENT ANALYSIS

U.S. Patent No. 10,075,565 – Google LLC 

Claim 1 

Jenam Tech LLC (“Jenam”) provides evidence of infringement of Claim 1 of U.S. Patent No. 10,075,565 (her

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 docsource 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 ’565 patent in violation of 35 U.S.C. § 

to sell, making, using, and/or importing the Infringing Instrumentalities. The following exemplary analysis demonstrate

otherwise 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 ’565 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 Ileast 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 res

infringement 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 ’565 patent, not listed in the claim chart, that are infringed by the Accu

further 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. 10,075,565

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June 1, 2020

Claim 1 Accused InstrumentalitiesAn apparatus comprising: a server

computer including: a non‐

transitory memory storing a

network application; and one or

more processors in

communication with the non‐

transitory memory, wherein the

one or more processors execute

the network application tooperate in accordance with a first

protocol including a transmission

control protocol (TCP), the server

computer, when operating in

accordance with the first protocol

to establish a TCP connection with

a client computer, configured to:

Google uses an apparatus comprising a server computer including a non‐transitory memory 

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

non‐transitory memory. The one or more processors execute the network application to o

accordance with a first protocol including a transmission control protocol (TCP). The server 

when operating in accordance with the first protocol to establish a TCP connection with a c

computer, is configured to carry out the following functionality.

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 the

segment, and at least one second

synchronize bit; and

Google uses the apparatus comprising the server computer which, when operating in accor

the first protocol to establish the TCP connection with the client computer, is configured to 

communicate a segment including at least one first synchronize bit; b) communicate a first

acknowledgement of the segment, and at least one second synchronize bit; and c) commun

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. 10,075,565

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communicate a second

acknowledgement; “The synchronization requires each side to send it's own initial sequence number and to re

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/

said server computer, further

configured to communicate, to

the client computer, code that,

when used by the client

computer, causes the clientcomputer to operate in

accordance with a second

protocol that is separate from theTCP, in order to establish a second

protocol connection with another

server computer, by: receiving a

packet; detecting an idle time

Google uses the apparatus comprising the server computer to communicate code (e.g., HT

etc.) to the client computer, where the code, when used by the client computer, causes the 

computer to operate in accordance with a second protocol that is separate from the TCP, in 

establish a second protocol connection with another server computer, by: receiving a packe

an idle time period parameter field (e.g., idle timeout parameter field, etc.) in the packet; id

metadata (e.g., the value of the idle timeout parameter field, etc.) in the idle time period p

for an idle time period, where, after the idle time period is detected, the second protocol c

deemed inactive; and creating or modifying, by the client computer and based on the meta

timeout attribute associated with the second protocol connection.

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

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CLAIM CHARTS

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U.S. Patent No. 10,075,565

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period parameter field in the

packet; identifying metadata in

the idle time period parameter

field for an idle time period,

where, after the idle time period

is detected, the second protocol

connection is deemed inactive;

and creating or modifying, by the

client computer and based on the

metadata, a timeout attribute

associated with the second

protocol connection.

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

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

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CLAIM CHARTS

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Note: As set forth below, a QUIC negotiation packet is received by the client node from a se

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

using the aforementioned handshake.

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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CLAIM CHARTS

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CLAIM CHARTS

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Note: As set forth below, since the idle_timeout value sets the duration of idleness, after wconnection is shutdown, a timeout attribute of the connection is necessarily modified base

received in the idle_timeout field of the connection negotiation packet.

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CLAIM CHARTS

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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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