Exhibit 2.2

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 1 of 24 PageID #: 30
Infringement Claim Chart for U.S. Pat. No. US7130430B2 v. Bose (“Defendant”)

(See Accused Product List at end of chart for models)

Claim 2 Evidence

2. A speaker 

system for 

producing 

localized regions

of sound 

comprising:

The Bose Smart Soundbar 900 soundbar is a speaker system for producing localized

regions of sound.

For example, the Bose Smart Soundbar 900 soundbar produces a surround sound effect.

The surround sound effect causes a listener facing the soundbar to perceive that sound

emanating from the soundbar is originating at a location behind and to the left of the

listener, referred to as surround left, and at another location behind and to the right of

the listener, referred to as surround right.

Source: https://www.bose.com/en_us/products/speakers/soundbars.html

1

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 2 of 24 PageID #: 31
Source: https://www.bose.com/en_us/products/speakers/home_theater/bose-smartsoundbar-900.html#v=bose_smart_soundbar_900_white

a multiplicity of 

audio frequency 

speakers;

The Bose Smart Soundbar 900 includes a multiplicity of audio frequency speakers.

For example, the Bose Smart Soundbar 900 includes multiple full-range audio speakers

positioned along acoustic front face of the soundbar.

2

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 3 of 24 PageID #: 32
Source: https://www.bose.com/en_us/products/speakers/soundbars.html

3

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 4 of 24 PageID #: 33
Source: https://www.bose.com/en_us/products/speakers/home_theater/bose-smartsoundbar-900.html#v=bose_smart_soundbar_900_white

at least one 

defined sound 

target spaced 

from each of the

speakers of the 

multiplicity of 

speakers, 

wherein each 

speaker has a 

means for 

applying a time 

varying audio 

drive voltage 

which is 

substantially 

identical, except

The Bose Smart Soundbar 900 has at least one defined sound target spaced from each of

the speakers of the multiplicity of speakers. Each speaker has a means for applying a

time varying audio drive voltage which is substantially identical, except that each audio

drive voltage is offset in time by an amount which is related to the distance between

each speaker and the defined sound target. So that substantially identical sound from

each speaker reaches the sound target at the same time.

For example, each of the Bose Smart Soundbar 900 speakers is connected to an audio

amplifier. A speaker have multichannel sound i.e., a surround left channel signal is

provided to each speaker via the speaker’s respective amplifier. The surround left

channel is delayed slightly for speakers on the listener’s left compared to speakers on

the listener’s right. The amount of delay is such that sound waves emanating from each

of the speakers reach the surround left location at the same time, thereby interfering

constructively to produce a resultant sound wave having peak spatial amplitude at the

surround left location. When this wave reflects back to the listener, the listener perceives

that the sound originated from the surround left location.

4

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 5 of 24 PageID #: 34
that each audio 

drive voltage is 

offset in time by

an amount 

which is related 

to the distance 

between each 

speaker and the 

defined sound 

target, so that 

substantially 

identical sound 

from each 

speaker reaches

the sound target

at the same 

time;

5

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 6 of 24 PageID #: 35
Source: https://www.bose.com/en_us/products/speakers/soundbars.html

6

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 7 of 24 PageID #: 36
Source: https://www.bose.com/en_us/products/speakers/home_theater/bose-smartsoundbar-900.html#v=bose_smart_soundbar_900_white

at least a first 

defined sound 

target and a 

second defined 

sound target, 

the second 

sound target 

being spaced 

from the first 

sound target, 

and the first 

sound target 

and the second 

sound target 

The Bose Smart Soundbar 900 has at least a first defined sound target and a second

defined sound target. The second sound target is spaced from the first sound target. The

first sound target and the second sound target are spaced from each of the speakers.

For example, the Bose Smart Soundbar 900 speaker surround left location is at a rear

position on a left-side wall of a nominally sized room. The omni-direction speaker

surrounds multiple location i.e., right location is at a rear position on the right-side wall of

the room. Additionally, the Truespace feature enables the soundbar to adapt to the

dimensions of the room.

7

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 8 of 24 PageID #: 37
being spaced 

from each of the

speakers of the 

multiplicity of 

speakers, 

Source: https://www.bose.com/en_us/products/speakers/soundbars.html

8

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 9 of 24 PageID #: 38
Source: https://www.bose.com/en_us/products/speakers/home_theater/bose-smartsoundbar-900.html#v=bose_smart_soundbar_900_white

and wherein the

means for 

The means for applying a time varying audio drive voltage comprises at least a first

audio source which is offset in time by an amount which is related to the distance

9

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 10 of 24 PageID #: 39
applying a time 

varying audio 

drive voltage 

comprises:

at least a first 

audio source 

which is offset in

time by an 

amount which is

related to the 

distance 

between each 

speaker and the 

first defined 

sound target; 

and

between each Bose speaker and the first defined sound target.

For example, a delay is added to the surround left channel (e.g. first audio source) before

it is applied to a Bose speaker on the left-side of the soundbar, as viewed from the

listener’s position. The delay relates to the distance between the speaker and the

surround left location in the nominally sized room, whereby the speaker closest to the

surround left location has the most delay.

10

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 11 of 24 PageID #: 40
Source: https://www.bose.com/en_us/products/speakers/soundbars.html

11

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 12 of 24 PageID #: 41
Source: https://www.bose.com/en_us/products/speakers/home_theater/bose-smartsoundbar-900.html#v=bose_smart_soundbar_900_white

at least a 

second audio 

source which is 

offset in time by

an amount 

which is related 

to the distance 

between each 

speaker and the 

second defined 

sound target 

wherein a sum 

of the first audio

source which is 

offset in time 

and the second 

audio source 

which is offset in

The Bose Smart Soundbar 900 includes at least a second audio source which is offset in

time by an amount which is related to the distance between each speaker and the

second defined sound target. The sum of the first audio source and the second audio

source is used to produce the time varying audio drive voltage. Substantially identical

sound from the first audio source signal reaches the first sound target at the same time,

and substantially identical sound from the second audio source signal reaches the

second target at the same time.

For example, a delay is added to the surround right channel (e.g. second audio source)

before it is applied to a speaker on the right-side of the soundbar. The delay relates to

the distance between the speaker and the surround right location, whereby the speaker

closest to the surround right location has the most delay. Each speaker is provided, via

its amplifier, with a surround left channel signal and a surround right channel signal,

each signal having a respective delay. The signals are added together before being input

to the respective amplifier. Consequently, each Bose speaker emits a sound wave

comprising audio from the surround left channel and from the surround right channel,

the audio from each channel having an appropriate amount of delay such that the

surround left audio reaches the surround left location at the same time as the surround

12

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 13 of 24 PageID #: 42
time is used to 

produce the 

time varying 

audio drive 

voltage so that 

substantially 

identical sound 

from the first 

audio source 

signal reaches 

the first sound 

target at the 

same time, and 

substantially 

identical sound 

from the second

audio source 

signal reaches 

the second 

target at the 

same time.

right audio reaches the surround right location.

13

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 14 of 24 PageID #: 43
Source: https://www.bose.com/en_us/products/speakers/soundbars.html

14

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 15 of 24 PageID #: 44
Source: https://www.bose.com/en_us/products/speakers/home_theater/bose-smartsoundbar-900.html#v=bose_smart_soundbar_900_white

15

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 16 of 24 PageID #: 45
Infringement Claim Chart for U.S. Pat. No. US7130430B2 v. Bose (“Defendant”)

(See Accused Product List at end of chart for models)

Claim #3 Evidence

3. A speaker 

system for 

producing 

localized 

regions of 

sound 

comprising:

The Bose Smart Soundbar 900 is speaker a system for producing localized regions of 

sound.

For example, the soundbar produces a surround sound effect. The surround sound effect 

causes a listener facing the soundbar to perceive that sound emanating from the 

soundbar is originating at a location behind and to the left of the listener, referred to as 

surround left, and at another location behind and to the right of the listener, referred to 

as surround right.

Source: https://www.bose.com/en_us/products/speakers/soundbars.html

16

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 17 of 24 PageID #: 46
Source: https://www.bose.com/en_us/products/speakers/home_theater/bose-smartsoundbar-900.html#v=bose_smart_soundbar_900_white

a multiplicity 

of audio 

frequency 

speakers;

The Bose Smart Soundbar 900 soundbar includes a multiplicity of audio frequency 

speakers.

For example, the soundbar includes multiple full-range audio speakers positioned along a

front face of the soundbar.

17

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 18 of 24 PageID #: 47
Source: https://www.bose.com/en_us/products/speakers/home_theater/bose-smartsoundbar-900.html#v=bose_smart_soundbar_900_white

at least one 

defined 

sound target 

spaced from 

each of the 

speakers of 

the 

multiplicity of

speakers, 

wherein each

speaker has a

means for 

applying a 

time varying 

audio drive 

voltage which

is 

substantially 

identical, 

except that 

each audio 

drive voltage 

is offset in 

time by an 

The Bose Smart Soundbar 900 has at least one defined sound target spaced from each of

the speakers of the multiplicity of speakers. Each speaker has a means for applying a 

time varying audio drive voltage which is substantially identical, except that each audio 

drive voltage is offset in time by an amount which is related to the distance between 

each speaker and the defined sound target. So that substantially identical sound from 

each speaker reaches the sound target at the same time.

For example, each of the speakers is connected to an audio amplifier. A surround left 

channel signal is provided to each speaker via the speaker’s respective amplifier. The 

surround left channel is delayed slightly for speakers on the listener’s left compared to 

speakers on the listener’s right. The amount of delay is such that sound waves 

emanating from each of the speakers reaches the surround left location at the same 

time, thereby interfering constructively to produce a resultant sound wave having a peak

spatial amplitude at the surround left location. When this wave reflects back to the 

listener, the listener perceives that the sound originated from the surround left location.

18

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 19 of 24 PageID #: 48
amount 

which is 

related to the

distance 

between 

each speaker

and the 

defined 

sound target,

so that 

substantially 

identical 

sound from 

each speaker

reaches the 

sound target 

at the same 

time; and

19

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 20 of 24 PageID #: 49
Source: https://www.bose.com/en_us/products/speakers/soundbars.html

20

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 21 of 24 PageID #: 50
Source: https://www.bose.com/en_us/products/speakers/home_theater/bose-smartsoundbar-900.html#v=bose_smart_soundbar_900_white

wherein the 

means for 

applying a 

time varying 

audio drive 

voltage 

includes a 

class D 

amplifier.

The means for applying a time varying audio drive voltage includes a class D amplifier.

For example, each amplifier connected to a respective speaker is a class D audio 

amplifier.

21

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 22 of 24 PageID #: 51
Source:https://www.techhive.com/article/620621/bose-smart-soundbar-900-

review.html

Accused Product List

Bose Smart Soundbar 900

Bose Smart Soundbar 700

Bose Smart Soundbar 600

Bose Smart Soundbar 300

Bose TV Speaker

References

[1] Bose Soundbars

https://www.bose.com/en_us/products/speakers/soundbars.html

22

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 23 of 24 PageID #: 52
[2] Bose Smart Soundbar 900

https://www.bose.com/en_us/products/speakers/home_theater/bose-smart-soundbar900.html#ProductTabs_tab1

[3] Bose TV Speaker

https://www.bose.com/en_us/products/speakers/home_theater/bose-tv-speaker.html#ProductTabs_tab1

[3] Bose Smart Soundbar 600

https://www.bose.com/en_us/products/speakers/home_theater/bose-smart-soundbar600.html#v=bose_smart_soundbar_600_black

[4] Bose Smart Soundbar 300

https://www.bose.com/en_us/products/speakers/home_theater/bose-smart-soundbar300.html#v=bose_smart_soundbar_300_club_black_ast

[5] Bose Smart Soundbar 700

https://www.bose.com/en_us/products/speakers/home_theater/bose-soundbar700.html#v=bose_soundbar_700_black

[6] Bose Smart Soundbar 900 review

https://www.soundguys.com/bose-smart-soundbar-900-review-83592/

[7] TechHive - Bose Smart Soundbar 900 review

https://www.techhive.com/article/620621/bose-smart-soundbar-900-review.html

23

Case 2:23-cv-00335-JRG Document 1-3 Filed 07/18/23 Page 24 of 24 PageID #: 53