Exhibit 3.3

Case 2:23-cv-00199-JRG Document 8-5 Filed 06/19/23 Page 1 of 13 PageID #: 179
Samsung – Soundbar 

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

Infringement of the ‘430 patent

Claim #2 Evidence

2. A speaker system for producing

localized regions of sound 

comprising:

The Samsung soundbar is a speaker 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. 

[3]

 [3]

1

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[3]

a multiplicity of audio frequency 

speakers;

The Samsung soundbar includes a multiplicity of audio frequency 

speakers.

For example, the soundbar includes multiple audio speakers 

positioned along a front face of the soundbar.

[3]

at least one defined sound target 

spaced from each of the speakers 

of the multiplicity of speakers, 

The Samsung soundbar 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 

2

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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 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;

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. [A]

[3]

3

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[2]

[2]

According to the specification the term: “substantially identical” 

means:

“It should be understood that when, a means for applying a time 

varying audio drive voltage, i.e. the signal used to drive individual 

speakers is described as substantially identical, the signals are 

defined as being substantially identical, although they vary in 

amplitude. The term, substantially identical, means capable of 

constructive interference when used in the sound system 36 of this 

invention.” [col.12 lines 18-24]

4

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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 being spaced from each of 

the speakers of the multiplicity of 

speakers, 

The Samsung soundbar 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 surround left location is at a rear position on a leftside wall of a nominally sized room e.g. 10 ft x 15 ft. The surround 

right location is at a rear position on the right-side wall of the room. 

Additionally, the SpaceFit feature enables the soundbar to adapt to 

the dimensions of the room.

[3]

[3]

5

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[4]

[4]

[4]

and wherein 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 

between each speaker and the 

first defined sound target; and

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 between each 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 speaker on the left-side of the 

soundbar, as viewed from the listener’s position. The delay relates 

6

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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. This enables the soundbar

to produce directional audio. [A]

[2]

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 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.

The Samsung soundbar 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 rightside 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 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 

7

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surround right audio reaches the surround right location. [A]

[3]

Samsung – HW-Q800 soundbar 

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

Infringement of the ‘430 patent

Claim #3 Evidence

3. A speaker system for producing

localized regions of sound 

comprising:

The Samsung soundbar 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

8

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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.

[2]

a multiplicity of audio frequency 

speakers;

The Samsung soundbar includes a multiplicity of audio frequency 

speakers.

For example, the soundbar includes five audio speakers positioned 

along a front face of the soundbar and two audio speakers facing 

upwards.

[2]

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 

The Samsung soundbar 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.

9

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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; and

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. [A]

[2]

According to the specification the term: “substantially identical” 

means:

“It should be understood that when, a means for applying a time 

varying audio drive voltage, i.e. the signal used to drive individual 

speakers is described as substantially identical, the signals are 

defined as being substantially identical, although they vary in 

amplitude. The term, substantially identical, means capable of 

constructive interference when used in the sound system 36 of this 

invention.” [col.12 lines 18-24]

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 speaker is a class D 

audio amplifier.

10

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[2]

Accused Product List

Q series: HW-Q990C, HW-Q950A, HW-Q930C, HW-Q900A, HW-Q800A, HW-Q800C, HW-Q700A, HW-Q700C, 

HW-Q67CB, HW-Q600A, HW-Q600B

C series: HW-C450/ZC, HW-C400

B series: HW-B650, HW-B550, HW-B450

S series: HW-S801B, HWS61B, HW-S50B

T series: HW-T415, HW-T400

References

[1] Samsung – Audio Devices – Soundbar

https://www.samsung.com/ca/audio-devices/soundbar/

[2] TechHive - Samsung HW-Q800 Review

https://www.techhive.com/article/579482/samsung-hw-q800a-review.html

[3] Samsung – Soundbar Overview

https://www.samsung.com/ca/audio-devices/soundbar-overview/

[4] Samsung – Q Series Soundbar

https://www.samsung.com/africa_en/audio-devices/q-series-soundbar/

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General Reference:

[A] Build – How a Soundbar works

https://build.com.au/how-soundbar-works

[B] LifeWire - The Yamaha YSP-5600 Dolby Atmos Digital Sound Projector

https://www.lifewire.com/ysp-5600-atmos-digital-sound-projector-3963655

[C] Yamaha – An Evolutionary History of the YSP series

https://usa.yamaha.com/products/contents/audio_visual/ysp10th/chapter04/index.html

[D] Digital Smart Homes – Yamaha Digital Sound Projector

http://www.digitalsmarthomes.com/products/yamahaysp/digital_sound_projector.html

[E] Electronic Design - Soundbar Design from Start to Finish: Power Amplifiers, Power Supplies, And ESD 

Protection

https://www.electronicdesign.com/technologies/analog/article/21795245/soundbar-design-from-start-tofinish-power-amplifiers-power-supplies-and-esd-protection

[F] Texas Instruments - TIDA-00089 Value Soundbar Reference Design Kit for Stereo or 2.1 Applications

https://www.ti.com/tool/TIDA-00089

[G] Wikipedia – Class-D Amplifier

https://en.wikipedia.org/wiki/Class-D_amplifier

12

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