Exhibit 3

Case 2:23-cv-00199-JRG Document 1-3 Filed 05/05/23 Page 1 of 51 PageID #: 37
Samsung – Smartphones and Tablets (models with IR cameras, models having cameras with IR 

sensitivity, and models with the Iris Scan feature. See Product List at end for models)

Infringement of the ‘413 patent

Claim 1 Evidence

1. A mobile 

communication device 

comprising a 

computational means 

and output means, 

The Samsung smartphone is a mobile communication device that has a 

computational means and an output means. 

For example, the smartphone is a communication that includes a system-onchip (SoC) device, which includes a main processor as a computational device,

and a touchscreen, which is an output device.

For example the Galaxy S4 includes a Qualcomm Snapdragon SoC CPU device 

and an AM-OLED touchscreen display: 

[6]

[6]

1

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[6]

For example, the Galaxy includes a Qualcomm Snapdragon SoC CPU device 

and an AM-OLED touchscreen:

[7]

2

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[7]

[7]

For example, the Galaxy S9+ includes a Qualcomm Snapdragon SoC CPU 

device and an AM-OLED touchscreen:

3

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[8]

[8]

4

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[8]

further comprising a 

module incorporating a 

non-contact 

temperature sensor for 

receiving from an 

external surface 

electromagnetic 

radiation in the infrared

spectral range, 

The Samsung smartphone further includes a module incorporating a noncontact temperature sensor for receiving from an external surface 

electromagnetic radiation in the infrared spectral range. 

For example, the Galaxy S4 and Note 3 models have an IR sensor, which is a 

smartphone module that is capable of sensing infrared electromagnetic 

radiation from an external source in a non-contact manner, thereby being 

operational as a non-contact temperature sensor.

5

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[1]

For example, the Galaxy S21 Plus smartphone includes an IR camera, which is 

a smartphone module that is capable of sensing infrared electromagnetic 

radiation from an external source in a non-contact manner, thereby being 

operational as a non-contact temperature sensor.

6

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[2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 models

is used for the Iris Scan feature, whereby infrared radiation which inherently 

includes temperature information, reflected by a user’s eyes is used to 

distinguish unique characteristics of the user’s eyes.

7

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[3]

8

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[4]

9

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[5]

such non-contact 

temperature sensor 

generates a signal.

The non-contact temperature sensor of the Samsung smartphone generates a 

signal.

For example the IR sensor in the Galaxy S4 and Note 3 models worked as a 

non-contact temperature sensor to enable a user to take an ambient 

temperature reading. The IR sensor produces a signal that is used by the SoC 

processor to provide a numeric temperature reading to the user via the 

10

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display.

[1]

For example the IR camera in the Galaxy S21 Plus model generates an IR 

image signal that inherently includes temperature information, e.g. hotter 

objects appear brighter in the image, which enables a user to distinguish hot 

objects from colder objects, bare earth from vegetation etc.

11

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[2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 models

used for the Iris Scan feature generates an image signal responsive to the 

infrared radiation received from the user’s iris and compares that image to 

previous images of the user’s iris. If the images match sufficiently, the SoC 

unlocks the smartphone. 

12

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[4]

13

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Samsung – Smartphones and Tablets (models with the Iris Scan feature. See Product List at end for 

models)

Infringement of the ‘413 patent

Claim 6 Evidence

6. The mobile 

communication device 

of claim 1, wherein said 

external surface is part of a 

head of a human.

The Samsung smartphone is capable of receiving electromagnetic 

radiation from an external surface, wherein the external surface is part of 

a head of a human.

For example, the Galaxy S8, S8+, S9, S9+ and Note 8 models have an Iris

Scan feature that receives electromagnetic radiation from a human eye, 

which is part of a human head.

14

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[4]

15

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Samsung – Smartphones and Tablets (models with IR cameras, models having cameras with IR 

sensitivity, and models with the Iris Scan feature. See Product List at end for models)

Infringement of the ‘413 patent

Claim 8 Evidence

8. A mobile communication 

device comprising a 

computational means and 

output means, further 

comprising:

The Samsung smartphone is a mobile communication device that has a 

computational means and an output means. 

For example, the smartphone is a communication that includes a systemon-chip (SoC) device, which includes a main processor as a computational

device, and a touchscreen, which is an output device.

For example the Galaxy S4 includes a Qualcomm Snapdragon SoC CPU 

device and an AM-OLED touchscreen display: 

[6]

[6]

16

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[6]

For example, the Galaxy includes a Qualcomm Snapdragon SoC CPU 

device and an AM-OLED touchscreen:

[7]

17

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[7]

[7]

For example, the Galaxy S9+ includes a Qualcomm Snapdragon SoC CPU 

device and an AM-OLED touchscreen:

18

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[8]

[8]

19

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[8]

a module for receiving and 

measuring a magnitude of 

electromagnetic radiation, 

wherein said 

electromagnetic radiation is 

generated by a source that 

is not being part of the 

mobile communication 

device, 

The Samsung smartphone further includes a module for receiving and 

measuring a magnitude of electromagnetic radiation, wherein the 

electromagnetic radiation is generated by a source that is not part of the 

mobile communication device.

For example, the central module of the smartphone (e.g. Samsung Galaxy

S21) is a module to which the Qualcomm Snapdragon SoC device and 

touchscreen are communicatively coupled during manufacturing of the 

smartphone. The main board of the smartphone includes an IR camera (or

IR sensor), which is capable of sensing and measuring infrared 

electromagnetic radiation from a source that is not part of the 

smartphone.

20

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[9]

Camera

21

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[9]

and such module 

comprising at least one 

antenna adapted for 

operation in the radio 

frequency range.

The Samsung the module of the smartphone includes at least one 

antenna adapted for operation in the radio frequency range.

For example, the central module includes an RF antenna for cellular 

communications by the smartphone. The RF antenna is positioned at one 

corner of the central module.

SoC 

CPU

22

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[9]

Antenn

a

23

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Samsung – Smartphones and Tablets (models with IR cameras, models having cameras with IR 

sensitivity, and models with the Iris Scan feature. See Product List at end for models)

Infringement of the ‘413 patent

Claim 9 Evidence

9. A method of 

measuring the 

magnitude of 

electromagnetic 

radiation in a selected 

location by a mobile 

communication device, 

consisting of the steps 

of:

The Samsung smartphone performs a method of measuring the magnitude of

electromagnetic radiation in a selected location.

For example, when the IR sensor is used for temperature sensing, or the IR 

camera is used to take an IR image (e.g. as in a scenic photo or for the Iris 

Scan feature) the smartphone measures the magnitude of infrared 

electromagnetic radiation received by the smartphone’s IR camera (or IR 

sensor) from the location at which the IR camera/sensor is aimed.

For example, the Galaxy S4 and Note 3 models have an IR sensor, which is a 

smartphone/tablet module that is capable of measuring the magnitude of 

infrared electromagnetic radiation from an external source.

[1]

For example, the Galaxy S21 Plus smartphone includes an IR camera, which 

24

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is a smartphone module that is capable of measuring the magnitude of 

infrared electromagnetic radiation from a location at which the camera is 

aimed.

[2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 

models is used for the Iris Scan feature, whereby the IR camera measures 

the magnitude of infrared radiation reflected by a user’s eyes, a location at 

which the camera is aimed, to distinguish unique characteristics of the user’s

eyes.

25

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[3]

26

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[4]

providing a mobile 

communication device 

that comprises a 

housing, a digital 

imaging sensor having a 

first field of view, such 

sensor is for generating 

a digital image of the 

selected location, 

The Samsung smartphone further provides a mobile communication device 

that comprises a housing and a digital imaging sensor having a first field of 

view. The sensor is for generating a digital image of the selected location.

For example, the smartphone includes a housing for enclosing a digital image

sensor, among other components of the smartphone. The digital image 

sensor has a field of view (e.g. outwards from the rear of the smartphone) 

and is for generating a digital image of a subject or location at which it is 

aimed. 

27

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For example the Galaxy S4 has 13.1 MP CMOS image sensor within a 

housing.

[6]

[6]

For example, the Galaxy S21 has 12MP BSI CMOS image sensor within a 

housing.

28

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[7]

 [7]

[7]

 [7]

For example, the Galaxy S9+ has a 12.2 MP BSI CMOS image sensor within a 

housing.

29

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[8]

 [8]

a computational means, The Samsung smartphone further provides a computational means.

30

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For example, the SoC CPU device includes a main processor for performing 

computational processing.

For example the Galaxy S4 includes a Qualcomm Snapdragon SoC CPU 

device: 

[6]

[6]

For example, the Galaxy includes a Qualcomm Snapdragon SoC CPU device:

[7]

31

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[7]

For example, the Galaxy S9+ includes a Qualcomm Snapdragon SoC CPU 

device:

[8]

[8]

and an output means for The Samsung smartphone further provides an output means for conveying 

32

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conveying information to

an operator;

information to an operator.

For example, the smartphone also includes a touchscreen display for 

conveying information to an operator.

For example the Galaxy S4 includes an AM-OLED touchscreen display: 

[6]

33

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[6]

For example, the Galaxy S21 includes an AM-OLED touchscreen display:

[7]

34

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[7]

For example, the Galaxy S9+ includes an AM-OLED touchscreen:

[8]

35

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[8]

incorporating into the 

housing a module that is

responsive to intensity 

of the electromagnetic 

radiation in a selected 

spectral range;

The Samsung smartphone incorporates into the housing a module that is 

responsive to intensity of the electromagnetic radiation in a selected spectral

range.

For example, the IR camera/sensor of the smartphone is responsive to 

electromagnetic radiation in the infrared range and is enclosed in the 

smartphone’s housing.

For example, the Galaxy S4 and Note 3 models have an IR sensor, which is a 

smartphone/tablet module that is capable of measuring the magnitude of 

electromagnetic radiation in the infrared range.

36

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[1]

For example, the Galaxy S21 Plus smartphone includes an IR wide angle 

camera, which is a smartphone module that is capable of measuring the 

magnitude of electromagnetic radiation in the infrared range.

37

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[2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 

models is used for the Iris Scan feature, whereby the IR camera measures 

the magnitude of electromagnetic radiation in the infrared range that is 

reflected by a user’s eyes to distinguish unique characteristics of the user’s 

eyes.

38

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[3]

39

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[4]

positioning the housing 

in a vicinity of the 

selected location;

As directed by marketing and operational instructions, a user of the Samsung

smartphone positioning the housing in a vicinity of the selected location 

when using the Iris Scan feature or the IR camera.

For example, an end user or Samsung test engineer, positions the 

smartphone such that it is in the vicinity of an external surface emitting 

infrared radiation in order to take a temperature reading, or in the vicinity of 

a subject and pointed thereat to take an IR wide angle image of the subject, 

or in the vicinity of a user and pointed at the user’s eyes to use the Iris Scan 

feature, as the case may be for a given smartphone model.

40

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For example, the Galaxy S4 and Note 3 models have an IR sensor. To take a 

temperature reading, the S4 or Note 3 tablet needs to be placed in the 

vicinity of infrared electromagnetic radiation from an external source.

[1]

For example, the Galaxy S21 Plus smartphone includes an IR camera. In 

order to take an IR photo of a subject, the smartphone needs to be 

positioned so that the IR camera is in the vicinity of the subject and pointed 

at the subject. 

41

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[2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 

models is used for the Iris Scan feature. In order to use the Iris Scan feature, 

the smartphone needs to be positioned in the vicinity of the user’s face with 

the IR camera pointed at the user’s eyes.

42

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[3]

43

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[4]

generating by the 

module a signal 

representative of the 

electromagnetic 

radiation;

The module of the Samsung smartphone generates a signal representative of

the electromagnetic radiation.

For example, the IR camera/sensor generates a signal responsive to the 

infrared electromagnetic radiation received from the location or subject at 

which the IR camera is pointed, or from the vicinity in which the smartphone 

is placed.

For example the IR sensor in the Galaxy S4 and Note 3 models produces a 

signal that is used by the SoC processor to provide a numeric temperature 

44

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reading to the user via the display. The temperature reading is 

representative of the infrared electromagnetic radiation received by the IR 

sensor.

[1]

For example the IR camera in the Galaxy S21 Plus model generates an IR 

image signal that is representative of the infrared electromagnetic radiation, 

e.g. hotter objects appear brighter in the image, which enables a user to 

distinguish hot objects from colder objects, bare earth from vegetation etc.

45

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[2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 

models used for the Iris Scan feature generates an image signal responsive 

to the infrared electromagnetic radiation received from the user’s iris. 

46

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[4]

processing said signal to

extract information 

The Samsung smartphone processes the signal to extract information related

to intensity of the electromagnetic radiation in the selected location.

47

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related to intensity of 

the electromagnetic 

radiation in the selected 

location, and

For example, the main processor in the SoC device processes the signal to 

extract information of the infrared electromagnetic radiation, in the location 

of the IR sensor or at which the IR camera is pointed in the case of the IR 

wide angle camera and Iris Scan feature. 

For example the IR sensor in the Galaxy S4 and Note 3 models produces a 

signal that is used by the SoC processor to provide a numeric temperature 

reading to the user via the display.[1]

For example the IR camera in the Galaxy S21 Plus model generates an IR 

image signal that is representative of the infrared electromagnetic radiation 

and provides the image to the user on the display of the smartphone. [2]

For example, the IR camera of the Galaxy S8, S8+, S9, S9+ and Note 8 

models used for the Iris Scan feature generates an image signal responsive 

to the infrared radiation received from the user’s iris. The SoC device 

processes the signal to extract information, based in part on the intensity of 

the received infrared electromagnetic radiation, to determine characteristics 

of the user’s iris. If the characteristics sufficiently match previously recorded 

characteristics, the SoC unlocks the smartphone. [3] [4] [5]

sending said information

to the output means for 

conveying the 

information to the 

operator.

The Samsung smartphone sends the information to the output means for 

conveying the information to the operator.

For example, depending on the feature being activated, the SoC processor 

sends the information to the touchscreen display, which causes the display to

be unlocked as in the case of the Iris Scan feature, or to display a 

temperature, or to display an IR image captured with the IR camera. [1] [2] 

[3] [4] [5]

Product List:

Smartphones with IR cameras: Galaxy S4 and Note3 smartphones

48

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Smartphones with wide camera having near IR sensitivity: Galaxy S21 Plus smartphone

Smartphones with the Iris Scan feature: Galaxy S8, S8+, S9, S9+ and Note 8 smartphones/tablets

References:

[1] Galaxy S4 and Note3 smartphones

https://www.phonearena.com/news/can-smartphone-take-temperature_id121600

[2] Galaxy S21 Plus smartphone

https://www.youtube.com/watch?v=l5rWDvzJJHQ#:~:text=Samsung%20Galaxy%20S21%20Plus%20%2D

%20Wide%20Camera%20Modified%20for%20Near%20Infrared%20Sensitivity,-761%20views%201

video at 0:08

[3] Galaxy S8, S8+, S9, S9+ and Note 8 smartphones/tablets

https://www.samsung.com/in/support/mobile-devices/why-do-we-use-ir-infrared-ray-for-iris-scan-insamsung-galaxy-s8-plus/

[4] Galaxy S8, S8+, S9, S9+ and Note 8 smartphones

https://www.howtogeek.com/404731/are-ir-scanners-in-phones-bad-for-your-eyes/

[5] Galaxy S8, S8+, S9, S9+ and Note 8 smartphones

https://www.samsung.com/ph/support/mobile-devices/what-is-iris-scanning-and-how-to-use-it-on-mysamsung-galaxy-device/

[6] PhoneDB: SM-T837T Galaxy Tab S4 10.5 2018 LTE-A US 64GB

https://phonedb.net/index.php?m=device&id=15072&c=samsung_sm-t837t_galaxy_tab_s4_10.5_2018_ltea_us_64gb__samsung_t830&d=detailed_specs

[7] PhoneDB: SM-G990U1 Galaxy S21 FE 5G UW TD-LTE US 128GB

https://phonedb.net/index.php?m=device&id=19575&c=samsung_sm-g990u1_galaxy_s21_fe_5g_uw_tdlte_us_128gb__samsung_g990&d=detailed_specs

49

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[8] PhoneDB: SM-G965U1 Galaxy S9+ TD-LTE US

https://phonedb.net/index.php?m=device&id=13349&c=samsung_sm-g965u1_galaxy_s9plus_tdlte_us__samsung_star_2

[9] IFIXIT: Samsung Galaxy S21 Ultra Teardown

https://www.ifixit.com/Teardown/Samsung+Galaxy+S21+Ultra+Teardown/141188

50

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