Exhibit 3

Case 6:20-cv-00523-ADA Document 1-3 Filed 06/12/20 Page 1 of 10
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U.S. Patent No. 8,054,090 (“’090 Patent”)

Exemplary Accused Product

Cypress products, including at least each of the following products (and their variations) infringe at least Claim 1 of the ’090

Patent: Capsense enabled Cypress products, including MBR3, CY8CMBR2110, CY8CMBR2044, CY8CMBR2016, CY8CMBR2010, 

CY8CMBR3XXX, and Capsense-enabled PSoC. The infringement chart below is based on the Cypress PSoC with CapSense

(“CapSense”), which is exemplary of the infringement of the ’090 Patent.

Claims CapSense 

[1pre] A method comprising: The CapSense touchcontroller provides capacitive touch sensing functionality, 

including in noisy and moist environments.

For example, a CapSense-enabled touch sensor may exhibit noise sources impacting 

signal to noise (SNR) parameters. CapSense utilizes capacitor raw capacitor charge 

counts to distinguish touch from noise. 

See https://www.cypress.com/file/41076/download

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See https://www.cypress.com/file/41076/download

See https://www.cypress.com/file/41076/download

See https://www.cypress.com/file/46081/download

[1a] grounding a first plate of a chargeaccumulation capacitor;The CapSense touchcontroller grounds a first plate of a charge-accumulation capacitor.

See https://www.cypress.com/file/41076/download

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See https://www.cypress.com/file/46081/download

[1b] injecting, through a resistor coupled 

to a voltage source, a predetermined 

amount of charge onto a chargemeasurement capacitor;

The CapSense touchcontroller injects, through a resistor coupled to a voltage source, a 

predetermined amount of charge onto a charge-measurement capacitor. 

For example, CapSense charges CINTA to a predetermined voltage Vref.

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See https://www.cypress.com/file/46081/download

See https://www.cypress.com/file/46081/download

[1c] transferring an amount of charge 

accumulated on a second plate of the 

charge-accumulation capacitor to a first 

plate of the charge-measurement 

capacitor, the charge having accumulated 

on the second plate of the chargeThe CapSense touchcontroller transfers an amount of charge accumulated on a second 

plate of the charge-accumulation capacitor to a first plate of the charge-measurement 

capacitor, the charge having accumulated on the second plate of the chargeaccumulation capacitor due at least in part to noise.

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accumulation capacitor due at least in 

part to noise; and

For example, CapSense transfers charge accumulated on the Rx electrode to the CINTA

external capacitor. The total charge court includes charges accumulated due to the 

parasitic capacitance and noise in the touch sensor. 

See https://www.cypress.com/file/41076/download

See https://www.cypress.com/file/46081/download

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See https://www.cypress.com/file/46081/download

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See https://www.cypress.com/file/46081/download

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See https://www.cypress.com/file/46081/download

See https://www.cypress.com/file/46081/download

See https://www.cypress.com/file/41076/download

[1d] determining, through a measured 

voltage across the charge-measurement 

capacitor, the amount of charge.

The CapSense touchcontroller determines, through a measured voltage across the 

charge-measurement capacitor, the amount of charge.

For example, CapSense sensor detects a touch by measuring voltage across CINTA.

See https://www.cypress.com/file/41076/download

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