Exhibit 4 to the Original Complaint.

1

U.S. Patent No. 8,936,190 v. Hoffmann-La Roche

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 1 of 23 PageID #: 68
Exhibit 4 to the Original Complaint.

2

1. Claim Chart

Claim Analysis

[1.P] A method, 

comprising:

Hoffmann-La Roche (“Company”) performs and induces others to perform a method for enabling an 

electronic device to retrieve and display information by detecting the symbology.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the Company provides a ‘NAVIFY Pass Professional’ mobile application for allowing/denying 

access to a visitor by authenticating a QR code displayed on a ‘NAVIFY Pass’ mobile application. 

Particularly, ‘NAVIFY Pass Professional’ mobile application (authenticators or user’s application) is 

installed on an authenticator’s (user) device such as, a mobile phone and tablet, and the ‘NAVIFY Pass’ 

mobile application (visitor’s application) is installed on a visitor’s device.

Source: https://play.google.com/store/apps/details?id=com.rochedhs.nrm.passport.nurse&hl=en_IN&gl=US

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 2 of 23 PageID #: 69
Exhibit 4 to the Original Complaint.

3

Source: 

https://play.google.com/store/apps/details?id=com.rochedhs.nrm.passport.patient&hl=en_IN&gl=US

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 3 of 23 PageID #: 70
Exhibit 4 to the Original Complaint.

4

Source: 

https://play.google.com/store/apps/details?id=com.rochedhs.nrm.passport.patient&hl=en_IN&gl=US

(Annotated)

Symbology (QR code) displayed 

on NAVIFY Pass mobile 

application (visitor’s interface)

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 4 of 23 PageID #: 71
Exhibit 4 to the Original Complaint.

5

Source: https://www.wellbeing365.com.au/wp-content/uploads/2021/10/NAVIFY-Pass-Brochure-.pdf, Page 

2 (Annotated)

Scanning of QR code in ‘NAVIFY 

Pass Professional’ mobile application 

(authenticator’s interface)

QR code displayed on NAVIFY Pass mobile 

application (visitor’s interface)

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 5 of 23 PageID #: 72
Exhibit 4 to the Original Complaint.

6

Source: https://diagnostics.roche.com/nl/en/innovation/navify-pass.html

Source: https://www.wellbeing365.com.au/wp-content/uploads/2021/10/NAVIFY-Pass-Brochure-.pdf, Page 

2 (Annotated)

Visitor

User (Authenticator)

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 6 of 23 PageID #: 73
Exhibit 4 to the Original Complaint.

7

Source: https://www.wellbeing365.com.au/wp-content/uploads/2021/10/NAVIFY-Pass-Brochure-.pdf, Page 

2

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 7 of 23 PageID #: 74
Exhibit 4 to the Original Complaint.

8

Source: https://vimeo.com/538550959

Further, to the extent this element is performed at least in part by Defendant's software source code, Plaintiff 

shall supplement these contentions pursuant to production of such source code by the Defendant.

[1.1] capturing a digital 

image using a digital 

image capturing device 

that is part of an 

electronic device;

Company performs and induces others to perform the step of capturing a digital image using a digital image 

capturing device that is part of an electronic device.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the ‘NAVIFY Pass Professional’ mobile application allows a user to capture and scan the QR 

code image (“digital image”) available on the visitor’s application through a built-in camera (“digital image 

capturing device”) of the user’s mobile phone (“electronic device”) for allowing/denying access.

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 8 of 23 PageID #: 75
Exhibit 4 to the Original Complaint.

9

Source: https://www.youtube.com/watch?v=wCUivFJHAc0 (Annotated)

Symbology (QR code) Capturing an image

of QR code

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 9 of 23 PageID #: 76
Exhibit 4 to the Original Complaint.

10

Source: https://www.wellbeing365.com.au/wp-content/uploads/2021/10/NAVIFY-Pass-Brochure-.pdf, Page 

2 (Annotated)

Capturing an image in ‘NAVIFY Pass 

Professional’ mobile application 

(authenticator’s interface)

Image displayed on NAVIFY Pass mobile 

application (visitor’s interface)

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 10 of 23 PageID #: 77
Exhibit 4 to the Original Complaint.

11

Further, to the extent this element is performed at least in part by Defendant's software source code, Plaintiff 

shall supplement these contentions pursuant to production of such source code by the Defendant.

[1.2] detecting 

symbology associated 

with the digital image 

using the electronic 

device;

Company performs and induces others to perform the step of detecting symbology associated with the digital 

image using the electronic device.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, ‘NAVIFY Pass Professional’ mobile application allows the user to capture an image of 

‘NAVIFY Pass’ mobile application’s interface through build in camera of user’s mobile phone. Further, the 

‘NAVIFY Pass Professional’ mobile application detects and scan the QR code (“symbology”) from the digital 

image displayed on the ‘NAVIFY Pass’ mobile application’s interface.

Source: https://www.youtube.com/watch?v=wCUivFJHAc0 (Annotated)

Symbology (QR code) Detection of 

QR code

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 11 of 23 PageID #: 78
Exhibit 4 to the Original Complaint.

12

Source: https://www.wellbeing365.com.au/wp-content/uploads/2021/10/NAVIFY-Pass-Brochure-.pdf, Page 

2 (Annotated)

Capturing an image in ‘NAVIFY Pass 

Professional’ mobile application 

(authenticator’s interface)

Image displayed on NAVIFY Pass mobile 

application (visitor’s interface)

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 12 of 23 PageID #: 79
Exhibit 4 to the Original Complaint.

13

Further, to the extent this element is performed at least in part by Defendant's software source code, Plaintiff 

shall supplement these contentions pursuant to production of such source code by the Defendant.

[1.3] decoding the 

symbology to obtain a 

decode string using one 

or more visual detection 

applications residing on 

the electronic device;

Company performs and induces others to perform the step of decoding the symbology to obtain a decode 

string using one or more visual detection applications residing on the electronic device.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the ‘NAVIFY Pass Professional’ (“visual detection applications”) mobile application installed 

(“residing”) on the mobile phone (“electronic device”) scans the QR code and decodes it at the backend. 

Further, the scanning involves interpretation of the black and white patterns of the QR code to extract the 

embedded data. The extracted data is converted into a machine-readable data which contains a unique 

identifier (“decode string”) that corresponds to the user’s account. Therefore, it would be apparent to a person 

of ordinary skill in the art that the NAVIFY Pass Professional mobile application decodes the QR code to 

obtain the unique identifier at the backend that corresponds to the test results of a visitor for allowing/denying 

access.

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 13 of 23 PageID #: 80
Exhibit 4 to the Original Complaint.

14

Source: https://www.youtube.com/watch?v=wCUivFJHAc0 (Annotated)

Symbology (QR code) Scanning of 

QR code

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 14 of 23 PageID #: 81
Exhibit 4 to the Original Complaint.

15

Source: https://www.sproutqr.com/blog/how-do-qr-codeswork#:~:text=In%20the%20QR%20code%2C%20the,back%20to%20the%20original%20URL.

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 15 of 23 PageID #: 82
Exhibit 4 to the Original Complaint.

16

Source: https://www.sproutqr.com/blog/how-do-qr-codeswork#:~:text=In%20the%20QR%20code%2C%20the,back%20to%20the%20original%20URL.

Source: https://www.investopedia.com/terms/q/quick-response-qr-code.asp

Further, to the extent this element is performed at least in part by Defendant's software source code, Plaintiff 

shall supplement these contentions pursuant to production of such source code by the Defendant.

[1.4] sending the decode 

string to a remote server 

for processing;

Company performs and induces others to perform the step of sending the decode string to a remote server for 

processing.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, upon detecting the QR code and obtaining a decode string, the ‘NAVIFY Pass Professional’ 

mobile application sends the decode string to NAVIFY cloud (“remote server”) for retrieving the information 

such as test results of the visitor.

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 16 of 23 PageID #: 83
Exhibit 4 to the Original Complaint.

17

Source: https://www.wellbeing365.com.au/wp-content/uploads/2021/10/NAVIFY-Pass-Brochure-.pdf, Page 

2 (Annotated)

Receiving information 

from server

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 17 of 23 PageID #: 84
Exhibit 4 to the Original Complaint.

18

Source: https://play.google.com/store/apps/details?id=com.rochedhs.nrm.passport.nurse&hl=en_IN&gl=US

(Annotated)

Further, to the extent this element is performed at least in part by Defendant's software source code, Plaintiff 

shall supplement these contentions pursuant to production of such source code by the Defendant.

[1.5] receiving 

information about the 

digital image from the 

remote server wherein 

Company performs and induces others to perform the step of receiving information about the digital image 

from the remote server wherein the information is based on the decode string.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

Authenticator’s interface 

for allowing/denying 

visitor’s access

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 18 of 23 PageID #: 85
Exhibit 4 to the Original Complaint.

19

the information is based 

on the decode string;

For example, the ‘NAVIFY Pass Professional’ mobile application accessible on the user’s mobile phone 

receives the information such as test results from the remote server based on the decoded QR code.

Source: https://www.wellbeing365.com.au/wp-content/uploads/2021/10/NAVIFY-Pass-Brochure-.pdf, Page 

2 (Annotated)

Receiving information 

from server

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 19 of 23 PageID #: 86
Exhibit 4 to the Original Complaint.

20

Source: https://play.google.com/store/apps/details?id=com.rochedhs.nrm.passport.nurse&hl=en_IN&gl=US

(Annotated)

Source: https://diagnostics.roche.com/nl/en/innovation/navify-pass.html

Further, to the extent this element is performed at least in part by Defendant's software source code, Plaintiff 

shall supplement these contentions pursuant to production of such source code by the Defendant.

Information received 

from remote server

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 20 of 23 PageID #: 87
Exhibit 4 to the Original Complaint.

21

[1.6] displaying the 

information on a display 

device associated with 

the electronic device.

Company performs and induces others to perform the step of displaying the information on a display device 

associated with the electronic device.

This element is infringed literally, or in the alternative, under the doctrine of equivalents.

For example, the received information is displayed on the screen (“display device”) of (“associated with”) 

the user’s mobile phone (“electronic device”).

Source: https://play.google.com/store/apps/details?id=com.rochedhs.nrm.passport.nurse&hl=en_IN&gl=US

(Annotated)

Information displayed on NAVIFY Pass 

Professional mobile application 

(authenticator’s interface)

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 21 of 23 PageID #: 88
Exhibit 4 to the Original Complaint.

22

Source: https://www.youtube.com/watch?v=wCUivFJHAc0 (Annotated)

Further, to the extent this element is performed at least in part by Defendant's software source code, Plaintiff 

shall supplement these contentions pursuant to production of such source code by the Defendant.

Information displayed on NAVIFY 

Pass Professional mobile 

application (authenticator’s

interface)

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 22 of 23 PageID #: 89
Exhibit 4 to the Original Complaint.

23

2. List of References

1. https://play.google.com/store/apps/details?id=com.rochedhs.nrm.passport.nurse&hl=en_IN&gl=US, last accessed on December 

18, 2023.

2. https://play.google.com/store/apps/details?id=com.rochedhs.nrm.passport.patient&hl=en_IN&gl=US, last accessed on December 

18, 2023.

3. https://www.wellbeing365.com.au/wp-content/uploads/2021/10/NAVIFY-Pass-Brochure-.pdf, last accessed on December 18, 

2023.

4. https://diagnostics.roche.com/nl/en/innovation/navify-pass.html , last accessed on December 18, 2023.

5. https://www.youtube.com/watch?v=wCUivFJHAc0, last accessed on December 18, 2023.

6. https://www.sproutqr.com/blog/how-do-qr-codeswork#:~:text=In%20the%20QR%20code%2C%20the,back%20to%20the%20original%20URL., last accessed on December 18, 

2023.

7. https://www.investopedia.com/terms/q/quick-response-qr-code.asp, last accessed on December 18, 2023.

8. https://vimeo.com/538550959, last accessed on December 18, 2023.

Case 2:23-cv-00630-JRG Document 1-5 Filed 12/27/23 Page 23 of 23 PageID #: 90