Complaint, Exhibit 4.

1

U.S. Patent No. US 9,300,723 v. Vivint Inc.

Claims 1, 6, 8, 9, 12, 17, 19, 20, 22, 27, 30, 32, 37, 39, 42, 47, 49, 50.

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 1 of 87 PageID #: 104
Complaint, Exhibit 4.

2

1. Claim Chart

Claim Analysis

[1.P] A 

media 

system, 

comprising:

Vivint (“Company”) makes, uses, sells, and/or offers to sell a media system.

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

For example, Company offers a Home Security System that comprises a Smart Hub (“media system”) that allows users 

to watch live camera feeds, close the garage, lock and unlock doors, control a smart thermostat, or turn on an alarm 

system.

Source: https://www.vivint.com/packages/home-security

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 2 of 87 PageID #: 105
Complaint, Exhibit 4.

3

Source: https://www.vivint.com/packages/home-automation

Source: https://www.vivint.com/packages/home-security

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 3 of 87 PageID #: 106
Complaint, Exhibit 4.

4

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (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 Company.

[1.1] at least 

one media 

terminal 

disposed in 

an accessible 

relation to at 

least one 

interactive 

computer 

network,

Company provides at least one media terminal disposed in an accessible relation to at least one interactive computer 

network.

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

For example, the smart thermostat is connected (“accessible relation”) to the Vivint smart hub (“one media terminal”) 

through the Z-wave smart home protocol (“at least one interactive computer network”).

Media System

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 4 of 87 PageID #: 107
Complaint, Exhibit 4.

5

Source: https://www.vivint.com/products/smart-thermostat (annotated) 

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company. 

[1.2] a 

wireless 

range 

Company provides a wireless range structured to permit authorized access to said at least one interactive computer 

network. 

Thermostat

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 5 of 87 PageID #: 108
Complaint, Exhibit 4.

6

structured to 

permit 

authorized 

access to said 

at least one 

interactive 

computer 

network,

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

For example, to pair the thermostat device with the smart hub, the thermostat device must be within the range of 100 

meters (“a wireless range”) of the Z-wave protocol. Further, Z-Wave network and devices in the Z-wave network are 

identified with their respective unique IDs. The unique IDs prevents unauthorized devices to access the Z-wave network. 

Therefore, upon information and belief, the thermostat devices that are within the wireless range of the Z-wave protocol 

are structured to permit authorized access to pair with the smart hub.

Source: https://www.z-wave.com/learn

Source: https://www.techtarget.com/iotagenda/definition/Z-Wave

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 Company.

[1.3] at least 

one media 

node 

Company provides at least one media node disposable within said wireless range, wherein said at least one media node 

is detectable by said at least one media terminal.

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 6 of 87 PageID #: 109
Complaint, Exhibit 4.

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disposable 

within said 

wireless 

range, 

wherein said 

at least one 

media node is 

detectable by 

said at least 

one media 

terminal,

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

For example, the smart hub is paired to the thermostat (“one media node”) when it is located within the range of the ZWave protocol (“disposable within said wireless range”). Further, during pairing, the smart hub searches for the nearby 

thermostat devices to get paired (“one media node is detectable by said at least one media terminal”).

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat (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 Company.

[1.4] at least 

one digital 

media file 

initially 

disposed on 

at least one of 

said at least 

one media 

terminal or 

Company provides at least one digital media file initially disposed on at least one of said at least one media terminal or 

said at least one media node, said at least one media terminal being structured to detect said at least one media node 

disposed within said wireless range. 

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

For example, to pair the thermostat to the smart hub, ‘smart home devices’ settings followed by “Z-wave” and “Add 

Node” settings are selected on the hub to pair with the thermostat. Further, when the thermostat’s side button is held for 

6 seconds, it starts searching (“said at least one media terminal being structured to detect said at least one media node”) 

Media terminal

Media Node

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 7 of 87 PageID #: 110
Complaint, Exhibit 4.

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said at least 

one media 

node, said at 

least one 

media 

terminal 

being 

structured to 

detect said at 

least one 

media node 

disposed 

within said 

wireless 

range,

for the Z-wave network, and upon clicking the Connect button for the searched network, the thermostat is paired with 

the smart hub. 

Furthermore, once the thermostat is connected to the smart hub, the smart hub allows users to control the thermostat by 

providing various functionalities on the smart hub such as changing room temperature, selecting different modes, and 

adjusting heating types. Therefore, it would be apparent to a person having ordinary skill in the art that the smart hub 

stores the settings to adjust the temperature on the thermostat. 

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 8 of 87 PageID #: 111
Complaint, Exhibit 4.

9

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

Adjust Temperature

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 9 of 87 PageID #: 112
Complaint, Exhibit 4.

10

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated) 

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[1.5] a 

communicati

on link 

structured to 

dispose said 

at least one 

media 

terminal and 

said at least 

one media 

node in a 

communicati

ve relation 

Company provides a communication link structured to dispose said at least one media terminal and said at least one 

media node in a communicative relation with one another via said at least one interactive computer network, where said 

communication link being initiated by said at least one media terminal.

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

For example, to pair the thermostat to the smart hub, ‘smart home devices’ settings are selected on the hub. Further, “Zwave” and “Add Node” settings are selected to pair with the thermostat (“said communication link being initiated by 

said at least one media terminal”). Further, when the pairing process is complete, a link ("communicative relation”) is 

established between the thermostat and the smart hub via Z-wave protocol (“said at least one interactive computer 

network”) such that the user adjusts the temperature on the thermostat via the smart hub. 

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 10 of 87 PageID #: 113
Complaint, Exhibit 4.

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with one 

another via 

said at least 

one 

interactive 

computer 

network,

said 

communicati

on link being 

initiated by 

said at least 

one media 

terminal,

Source: https://www.vivint.com/resources/article/smart-home-technologies-guide

Source: https://www.vivint.com/resources/article/smart-home-technologies-guide

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 11 of 87 PageID #: 114
Complaint, Exhibit 4.

12

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[1.6] said at 

least one 

media node 

and said at 

least one 

media 

terminal 

being 

structured to 

transmit said 

at least one 

digital media 

file 

therebetween 

via said 

communicati

on link, and

Company provides at least one media node and said at least one media terminal being structured to transmit said at least 

one digital media file therebetween via said communication link.

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

For example, after the pairing process is complete, the smart hub allows the users to adjust the temperature settings for 

the thermostat directly from the smart hub. When the user modifies the room temperature using the smart hub, the 

adjusted temperature is reflected on the connected thermostat device as the target temperature. Therefore, it would be 

apparent to a person having ordinary skill in the art that the modified temperature instruction (“digital media file”) is 

transmitted from the smart hub to the thermostat via the established link. 

User adjusting 

temperature to 73° F via 

smart hub

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Complaint, Exhibit 4.

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Source: https://www.youtube.com/watch?v=NT36UmzH1A0, at 0:10 (annotated)

Source: https://www.youtube.com/watch?v=NT36UmzH1A0, at 0:57 (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 Company.

[1.7] said 

communicati

on link is 

structured to 

bypass at 

least one 

media 

terminal 

security 

measure for a 

limited 

permissible 

Company provides a media system, wherein said communication link is structured to bypass at least one media terminal 

security measure for a limited permissible use of the communication link by the media node to only transferring the at 

least one digital media file to, and displaying the at least one digital media file on, the at least one media terminal.

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

For example, once the devices are paired, a link is established between them, enabling the users to adjust the thermostat's 

temperature settings directly from the smart hub without the need to regularly pair the devices. As pairing is not necessary 

each time to make temperature adjustments via the smart hub, it would be apparent to a person having ordinary skill in 

the art that the established communication link is designed to bypass security measures related to the smart hub.

Additionally, the adjusted temperature is reflected on the smart hub as the target temperature (“displaying the at least 

one digital media file on, the at least one media terminal”).

Modified temperature

(73° F) being displayed 

on thermostat device

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Complaint, Exhibit 4.

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use of the 

communicati

on link by the 

media node to 

only 

transferring 

the at least 

one digital 

media file to, 

and 

displaying 

the at least 

one digital 

media file on, 

the at least 

one media 

terminal.

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (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 Company.

displaying the at least one digital 

media file on, the at least one media 

terminal

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[6] The 

system of 

claim 1, 

wherein the 

communicati

on link is at 

least one of a 

peer-to-peer 

connection, 

bluetooth 

connection, 

and a WiFi 

connection.

Company provides the system of claim 1, wherein the communication link is at least one of a peer-to-peer connection, 

bluetooth connection, and a WiFi connection.

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

For example, the smart home devices such as the thermostat communicates wirelessly with the smart hub using Z-Wave

protocol (‘peer-to-peer connection”).

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat (annotated) 

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Peer-to-peer connection

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Complaint, Exhibit 4.

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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 Company

[8] The 

system of 

claim 1, 

further 

comprising 

presenting 

the at least 

one digital 

media file on 

a display.

Company provides the system of claim 1, further comprising presenting the at least one digital media file on a display.

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

For example, the adjusted temperature reading is reflected on the smart hub (“presenting the at least one digital media 

file on a display”).

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (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 Company

[9] The 

system of 

claim 1, 

Company provides the system of claim 1, wherein the at least one digital media file is provided by the at least one media 

node.

Media file on a display

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 16 of 87 PageID #: 119
Complaint, Exhibit 4.

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wherein the at 

least one 

digital media 

file is 

provided by 

the at least 

one media 

node.

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

For example, the thermostat provides features to adjust the temperature. Therefore, it would be apparent to a person 

having ordinary skill in the art that the digital media file is provided by the media node.

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company

[12] A media 

system 

configured to 

receive a 

media file 

from a 

wireless 

mobile 

device over 

communicati

Vivint (“Company”) makes, uses, sells and/or offers to sell a media system configured to receive a media file from a 

wireless mobile device over communication network. 

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

For example, Company offers a Home security system which comprises a Smart Hub (“media system”) which is further 

paired with smart devices such as door locks, security camera and, thermostat (“wireless mobile device”) via Z-Wave 

Technology (“communication network”). Since the smart hub and the thermostat are fully integrated, therefore, the 

reading on/measured by the thermostat (“media file”) is reflected (“configured to receive”) on the smart hub.

Media file

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on network, 

comprising:

Source: https://www.vivint.com/packages/home-security

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated)

Media System

Thermostat reading reflected on the smart hub

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Complaint, Exhibit 4.

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Source: https://www.vivint.com/products/smart-thermostat (annotated) 

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Wireless 

mobile 

device

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Source: https://www.vivint.com/products/smart-thermostat

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 Company.

[12.1] a 

wireless 

receiver;

Company provides a wireless receiver.

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

For example, the reading on/measured by the thermostat is reflected on the smart hub via Z-Wave network. Therefore, 

it would be apparent to a person having ordinary skill in the art that a wireless receiver is embedded inside the smart hub.

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

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 Company.

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[12.2] a 

security 

measure; and

Company provides a security measure.

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

For example, to pair the thermostat and the smart hub, ‘smart home devices’ settings followed by “Z-wave” and “Add 

Node” settings are selected on the hub to pair with the thermostat. Further, when the thermostat’s side button is held for 

6 seconds, it becomes detectable for the Z-wave network, and upon clicking the Connect button for the searched network, 

the thermostat is paired with the smart hub. Therefore, the pairing procedure between the smart hub and the thermostat 

indicates a presence of a security measure.

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[12.3] the 

media system 

disposed in 

an accessible 

relation to at 

Company provides the media system disposed in an accessible relation to at least one interactive computer network that 

has a wireless range structured to permit authorized access to said at least one interactive computer network.

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

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least one 

interactive 

computer 

network that 

has a wireless 

range 

structured to 

permit 

authorized 

access to said 

at least one 

interactive 

computer 

network,

For example, to pair (“accessible relation”) the smart hub and the thermostat, the devices must be within a range of 100 

meters (“a wireless range structured to permit authorized access”) of the Z-wave protocol (“computer network”). Further, 

Z-Wave network and devices in the Z-wave network are identified with their respective unique IDs. The unique IDs

prevents unauthorized devices to access the Z-wave network. Therefore, upon information and belief, the thermostat 

devices that are within the wireless range of the Z-wave protocol are structured to permit authorized access to pair with 

the smart hub.

Source: https://www.z-wave.com/learn

Source: https://www.techtarget.com/iotagenda/definition/Z-Wave

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Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Source: https://www.vivint.com/products/smart-thermostat (annotated) 

Thermostat

Media system

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Complaint, Exhibit 4.

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Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[12.4] the 

wireless 

mobile 

device within 

said wireless 

range, 

wherein said 

wireless 

mobile 

device is 

detectable by 

said media 

system,

Company provides the wireless mobile device within said wireless range, wherein said wireless mobile device is 

detectable by said media system.

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

For example, on the smart hub, ‘smart home devices’ settings followed by “Z-wave” and “Add Node” settings are 

selected on the hub to pair with the thermostat (“the wireless mobile device”). Further, the thermostat's side button is 

held for 6 seconds to make it detectable for pairing with the hub (“said wireless mobile device is detectable by said media 

system”).

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 24 of 87 PageID #: 127
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Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[12.5] at least 

one digital 

media file

initially 

disposed on 

the wireless 

mobile 

device, said 

media system 

being 

structured to 

detect said 

wireless 

mobile 

Company provides a system wherein at least one digital media file initially disposed on the wireless mobile device, said 

media system being structured to detect said wireless mobile device disposed within said wireless range.

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

For example, the thermostat displays a current temperature and a target temperature (“digital media file initially disposed 

on the wireless mobile device”) and the same reading is reflected on the smart hub.

Further, to pair the thermostat and the smart hub, ‘smart home devices’ settings followed by “Z-wave” and “Add Node” 

settings are selected on the hub to pair with the thermostat. Furthermore, when the thermostat’s side button is held for 6 

seconds, it becomes detectable for the Z-wave network (“said media system being structured to detect said wireless 

mobile device within said wireless range”), and upon clicking the Connect button for the searched network, the 

thermostat is paired with the smart hub.

Media system

Wireless mobile Device

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device 

disposed 

within said 

wireless 

range,

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

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Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[12.6] a 

communicati

on link 

structured to 

dispose said 

media system 

and said 

wireless 

mobile 

device in a 

communicati

ve relation 

with one 

another via 

said at least 

Company provides a communication link structured to dispose said media system and said wireless mobile device in a 

communicative relation with one another via said at least one interactive computer network and said communication link 

being initiated by said media system.

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

For example, to pair the thermostat with the smart hub, ‘smart home devices’ settings are selected on the hub. Further, 

“Z-wave” and “Add Node” settings are selected to pair with the thermostat (“said communication link being initiated by 

said at least one media system”). 

Further, when the pairing process is complete, a link ("communicative relation”) is established between the thermostat 

and the smart hub via Z-wave protocol (“said at least one interactive computer network”). 

Media system

Wireless mobile device

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one 

interactive 

computer 

network,

said 

communicati

on link being 

initiated by 

said media 

system,

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Source: https://www.vivint.com/resources/article/smart-home-technologies-guide

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 Company.

[12.7] said 

wireless 

mobile 

device and 

Company provides a system for transmitting by said wireless mobile device and media system being structured to 

transmit said at least one digital media file therebetween via said communication link.

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

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media system 

being 

structured to 

transmit said 

at least one 

digital media 

file 

therebetween 

via said 

communicati

on link, and

For example, after the pairing process is complete, the temperature measured by the thermostat, is reflected on the bottom 

of the smart hub screen. Therefore, it would be apparent to a person having ordinary skill in the art that the thermostat 

constantly syncs (“transmit said at least one digital media file therebetween via said communication link”) the 

temperature reading with the smart hub. 

Source: https://www.vivint.com/products/smart-thermostat

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

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 Company.

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[12.8] said 

communicati

on link is 

structured to 

bypass the 

security 

measure of 

the media 

system for a 

limited 

permissible 

use of the 

communicati

on link by the 

wireless 

mobile 

device for 

only 

transferring 

the at least 

one digital 

media file to, 

and 

displaying 

the at least 

one digital 

media file on, 

the media 

system.

Company provides a system wherein said communication link is structured to bypass the security measure of the media 

system for a limited permissible use of the communication link by the wireless mobile device for only transferring the at 

least one digital media file to, and displaying the at least one digital media file on, the media system.

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

For example, once the devices are paired, a link is established between them, enabling the users to adjust the thermostat's 

temperature settings both from the thermostat and the smart hub as they are integrated with each other. As pairing is not 

necessary each time to make temperature adjustments via the smart hub, it would be apparent to a person having ordinary 

skill in the art that the established communication link is designed to bypass security measures related to the smart hub.

Additionally, the temperature reading from the connected thermostat device is constantly synced and reflected on the

smart hub (“displaying the at least one digital media file on, the media system”).

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (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 Company.

[17] The 

system of 

claim 12, 

wherein the 

communicati

on link is at 

least one of a 

peer-to-peer 

connection, 

bluetooth 

connection, 

Company provides the system of claim 12, wherein the communication link is at least one of a peer-to-peer connection, 

bluetooth connection, and a WiFi connection.

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

For example, the smart home devices such as thermostat communicate wirelessly with the smart hub using Z-Wave 

(‘peer-to-peer connection”).

digital media file on, the media system

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 31 of 87 PageID #: 134
Complaint, Exhibit 4.

32

and a WiFi 

connection.

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat (annotated)

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company

[19] The 

system of 

claim 12, 

further 

comprising 

Company provides the system of claim 12, further comprising presenting the at least one digital media file on a display.

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

Peer-to-peer connection

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 32 of 87 PageID #: 135
Complaint, Exhibit 4.

33

presenting 

the at least 

one digital 

media file on 

a display.

For example, the temperature reading is reflected on the smart hub (“displaying the at least one digital media file on, the 

media system”).

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (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 Company.

[20] The 

system of 

claim 12, 

wherein the at 

least one 

digital media 

file is 

provided by 

the wireless 

Company provides the system of claim 12, wherein the at least one digital media file is provided by the wireless mobile 

device.

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

For example, the thermostat provides features to adjust the temperature. Therefore, it would be apparent to a person 

having ordinary skill in the art that the digital media file is provided by the media node.

Media file on display

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 33 of 87 PageID #: 136
Complaint, Exhibit 4.

34

mobile 

device.

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

Media file

Adjust Temperature

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 34 of 87 PageID #: 137
Complaint, Exhibit 4.

35

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated)

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company

[22.P] A 

method of 

transferring a 

media file 

from a 

wireless 

mobile 

device to a 

media system 

over a 

communicati

on network, 

the media 

Vivint (“Company”) performs and/or induces others to perform a method of transferring a media file from a wireless 

mobile device to a media system over a communication network, the media system including a security measure.

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

For example, Company offers a Home security system which comprises a Smart Hub (“media system”) which is paired 

with smart devices such as door locks, security camera and, thermostat (“wireless mobile device”) via Z-Wave 

Technology (“communication network”). Since the smart hub and the thermostat are fully integrated therefore, the 

reading on/measured by the thermostat (“media file”) is reflected on the smart hub. The pairing procedure between the 

smart hub and the thermostat indicates a presence of a security measure.

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 35 of 87 PageID #: 138
Complaint, Exhibit 4.

36

system 

including a 

security 

measure, 

comprising:

Source: https://www.vivint.com/packages/home-security

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated)

Media System

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 36 of 87 PageID #: 139
Complaint, Exhibit 4.

37

Source: https://www.vivint.com/products/smart-thermostat (annotated) 

Source:

https://wwwassets.s3.amazonaws.com/global/vivint.com/Support/images/Vivint_SmartHubV2_GettingStartedGuide_E

NU%20-%20revA.2.pdf , Page 13

Source: https://www.vivint.com/products/smart-thermostat

Mobile 

device

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 37 of 87 PageID #: 140
Complaint, Exhibit 4.

38

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 Company.

[22.1] 

disposing the 

media system 

in an 

accessible 

relation to at 

least one 

interactive 

computer 

network that 

has a wireless 

range 

structured to 

permit 

authorized 

access to said 

at least one 

interactive 

computer 

network, 

wherein the 

wireless 

mobile 

device within 

said wireless 

range, 

wherein said 

wireless 

mobile 

device is 

Company performs and/or induces others to perform a step of disposing the media system in an accessible relation to at 

least one interactive computer network that has a wireless range structured to permit authorized access to said at least 

one interactive computer network, wherein the wireless mobile device within said wireless range, wherein said wireless 

mobile device is detectable by said media system.

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

For example, to pair (“accessible relation”) the smart hub and the thermostat, the devices must be within a range of 100 

meters (“a wireless range”) of the Z-wave protocol (“computer network”). Further, Z-Wave network and devices in the 

Z-wave network are identified with their respective unique IDs. The unique IDs prevents unauthorized devices to access 

the Z-wave network. Therefore, upon information and belief, the thermostat devices that are within the wireless range of 

the Z-wave protocol are structured to permit authorized access to pair with the smart hub.

Further, on the smart hub, ‘smart home devices’ settings followed by “Z-wave” and “Add Node” settings are selected on 

the hub to pair with the thermostat. Further, the thermostat's side button is held for 6 seconds to make it detectable for 

pairing with the hub (“wireless mobile device is detectable by said media system”).

Source: https://www.z-wave.com/learn

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 38 of 87 PageID #: 141
Complaint, Exhibit 4.

39

detectable by 

said media 

system,

Source: https://www.techtarget.com/iotagenda/definition/Z-Wave

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Media System

Mobile device

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 39 of 87 PageID #: 142
Complaint, Exhibit 4.

40

Source: https://www.vivint.com/products/smart-thermostat (annotated) 

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[22.2] 

initially 

disposing at 

least one 

Company performs and/or induces others to perform a step of initially disposing at least one digital media file on the 

wireless mobile device, said media system being structured to detect said wireless mobile device disposed within said 

wireless range.

Thermostat

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 40 of 87 PageID #: 143
Complaint, Exhibit 4.

41

digital media 

file on the 

wireless 

mobile 

device, said 

media system 

being 

structured to 

detect said 

wireless 

mobile 

device 

disposed 

within said 

wireless 

range,

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

For example, the thermostat displays a current temperature and a target temperature (“initially disposing at least one 

digital media file on the wireless mobile device”) and the same reading is reflected on the smart hub.

Further, to pair the thermostat and the smart hub, ‘smart home devices’ settings followed by “Z-wave” and “Add Node” 

settings are selected on the hub to pair with the thermostat. Furthermore, when the thermostat’s side button is held for 6 

seconds, it becomes detectable for the Z-wave network (“said media system being structured to detect said wireless 

mobile device disposed within said wireless range”), and upon clicking the Connect button for the searched network, the 

thermostat is paired with the smart hub.

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 41 of 87 PageID #: 144
Complaint, Exhibit 4.

42

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Media system

Wireless mobile device

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 42 of 87 PageID #: 145
Complaint, Exhibit 4.

43

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 Company.

[22.3] 

structuring a 

communicati

on link to 

dispose said 

media system 

and said 

wireless 

mobile 

device in a 

communicati

ve relation 

with one 

another via 

said at least 

one 

interactive 

computer 

network, 

initiating said 

communicati

on link by 

said media 

system,

Company performs and/or induces others to perform a step of structuring a communication link to dispose said media 

system and said wireless mobile device in a communicative relation with one another via said at least one interactive 

computer network, initiating said communication link by said media system.

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

For example, to pair the thermostat with the smart hub, ‘smart home devices’ settings are selected on the hub. Further, 

“Z-wave” and “Add Node” settings are selected to pair with the thermostat (“initiating said communication link by said 

media system”). 

Further, when the pairing process is complete, a link ("communicative relation”) is established between the thermostat 

and the smart hub via Z-wave protocol (“said at least one interactive computer network”). 

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 43 of 87 PageID #: 146
Complaint, Exhibit 4.

44

Source: https://www.vivint.com/resources/article/smart-home-technologies-guide

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 Company.

[22.4] 

transmitting 

by said 

wireless 

mobile 

device to the 

media system 

said at least 

one digital 

media file 

therebetween 

via said 

communicati

on link, and

Company performs and/or induces others to perform a step of transmitting by said wireless mobile device to the media 

system said at least one digital media file therebetween via said communication link.

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

For example, after the pairing process is complete, the temperature measured by the thermostat, is reflected on the bottom 

of the smart hub screen. Therefore, it would be apparent to a person having ordinary skill in the art that the thermostat 

constantly syncs (“transmitting by said wireless mobile device to the media system said at least one digital media file”) 

the temperature reading with the smart hub. 

Source: https://www.vivint.com/products/smart-thermostat

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 44 of 87 PageID #: 147
Complaint, Exhibit 4.

45

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

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 Company.

[22.5] 

wherein said 

communicati

on link is 

structured to 

bypass the 

security 

measure of 

the media 

system for a 

limited 

permissible 

use of the 

Company performs and/or induces others to perform a step wherein said communication link is structured to bypass the 

security measure of the media system for a limited permissible use of the communication link by the wireless mobile 

device for only transferring the at least one digital media file to, and displaying the at least one digital media file on, the 

media system.

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

For example, once the devices are paired, a link is established between them, enabling the users to adjust the thermostat's 

temperature settings both from the thermostat and the smart hub as they are integrated with each other. As pairing is not 

necessary each time to make temperature adjustments via the smart hub, it would be apparent to a person having ordinary 

skill in the art that the established communication link is structured to bypass the security measure related to the smart 

hub. Additionally, the temperature reading from the connected thermostat device is constantly synced and reflected on 

the smart hub (“displaying the at least one digital media file on, the media system”).

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 45 of 87 PageID #: 148
Complaint, Exhibit 4.

46

communicati

on link by the 

wireless 

mobile 

device for 

only 

transferring 

the at least 

one digital 

media file to, 

and 

displaying 

the at least 

one digital 

media file on, 

the media 

system.

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated) 

digital media file on, the media system

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 46 of 87 PageID #: 149
Complaint, Exhibit 4.

47

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 Company.

[27] The 

method of 

claim 22, 

wherein the 

communicati

on link is at 

least one of a 

peer-to-peer 

connection, 

bluetooth 

connection, 

and a WiFi 

connection.

Company performs and induces others to perform the method of claim 22, wherein the communication link is at least 

one of a peer-to-peer connection, bluetooth connection, and a WiFi connection.

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

For example, the smart home devices such as thermostat communicate wirelessly with the smart hub using Z-Wave 

(‘peer-to-peer connection”).

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat (annotated)

Peer-to-peer connection

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 47 of 87 PageID #: 150
Complaint, Exhibit 4.

48

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[29] The 

method of 

claim 22, 

further 

comprising 

presenting 

the at least 

one digital 

media file on 

a display.

Company performs and induces others to perform the method of claim 22, further comprising presenting the at least one 

digital media file on a display.

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

For example, the temperature reading is reflected on the smart hub (“presenting the at least one digital media file on a 

display”).

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 48 of 87 PageID #: 151
Complaint, Exhibit 4.

49

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (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 Company.

[30] The 

method of 

claim 22, 

wherein the at 

least one 

digital media 

file is 

provided by 

the wireless 

mobile 

device.

Company performs and induces others to perform the method of claim 22, wherein the at least one digital media file is 

provided by the wireless mobile device.

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

For example, the thermostat provides features to adjust the temperature. Therefore, it would be apparent to a person 

having ordinary skill in the art that the digital media file is provided by the media node.

Media file on display

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 49 of 87 PageID #: 152
Complaint, Exhibit 4.

50

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated)

Media file

Adjust Temperature

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 50 of 87 PageID #: 153
Complaint, Exhibit 4.

51

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[32.P] A 

wireless 

mobile 

device 

configured to 

transmit a 

media file to 

a media 

system over a 

communicati

on network 

having a 

security 

measure 

comprising:

Vivint (“Company”) makes, uses, sells and/or offers to sell a wireless mobile device configured to transmit a media file 

to a media system over a communication network having a security measure.

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

For example, Company offers a Home security system which comprises a Smart Hub (“media system”) which is paired 

with smart devices such as door locks, security camera and, thermostat (“wireless mobile device”) via Z-Wave 

Technology (“communication network”). Since the smart hub and the thermostat are fully integrated therefore, the 

reading on/measured by the thermostat (“media file”) is reflected on the smart hub. The pairing procedure between the 

smart hub and the thermostat indicates a presence of a security measure.

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 51 of 87 PageID #: 154
Complaint, Exhibit 4.

52

Source: https://www.vivint.com/packages/home-security

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated)

Media System

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 52 of 87 PageID #: 155
Complaint, Exhibit 4.

53

Source: https://www.vivint.com/products/smart-thermostat (annotated) 

Source:

https://wwwassets.s3.amazonaws.com/global/vivint.com/Support/images/Vivint_SmartHubV2_GettingStartedGuide_E

NU%20-%20revA.2.pdf , Page 13

Source: https://www.vivint.com/products/smart-thermostat

Mobile 

device

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 53 of 87 PageID #: 156
Complaint, Exhibit 4.

54

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 Company.

[32.1] the 

media system 

disposed in 

an accessible 

relation to at 

least one 

interactive 

computer 

network that 

has a wireless 

range 

structured to 

permit 

authorized 

access to said 

at least one 

interactive 

computer 

network,

Company provides the media system disposed in an accessible relation to at least one interactive computer network that 

has a wireless range structured to permit authorized access to said at least one interactive computer network.

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

For example, to pair (“accessible relation”) the smart hub and the thermostat, the devices must be within a range of 100 

meters (“a wireless range”) of the Z-wave protocol (“computer network”). Further, Z-Wave network and devices in the 

Z-wave network are identified with their respective unique IDs. The unique IDs prevents unauthorized devices to access 

the Z-wave network. Therefore, upon information and belief, the thermostat devices that are within the wireless range of 

the Z-wave protocol are structured to permit authorized access to pair with the smart hub.

Source: https://www.z-wave.com/learn

Source: https://www.techtarget.com/iotagenda/definition/Z-Wave

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 54 of 87 PageID #: 157
Complaint, Exhibit 4.

55

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[32.2] the 

wireless 

Company provides the wireless mobile device within said wireless range, wherein said wireless mobile device is 

detectable by said media system. 

Media system

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 55 of 87 PageID #: 158
Complaint, Exhibit 4.

56

mobile 

device within 

said wireless 

range, 

wherein said 

wireless 

mobile 

device is 

detectable by 

said media 

system,

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

For example, on the smart hub, ‘smart home devices’ settings followed by “Z-wave” and “Add Node” settings are 

selected on the hub to pair with the thermostat. Further, the thermostat's side button is held for 6 seconds to make it 

detectable for pairing with the hub (“wireless mobile device is detectable by said media system”).

Source: https://www.z-wave.com/learn

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 Company.

[32.3] at least 

one digital 

media file 

initially 

disposed on 

the wireless 

mobile 

device, said 

media system 

being 

structured to 

detect said 

wireless 

Company provides at least one digital media file initially disposed on the wireless mobile device, said media system 

being structured to detect said wireless mobile device disposed within said wireless range. 

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

For example, the thermostat displays a current temperature and a target temperature (“digital media file initially disposed 

on the wireless mobile device”) and the same reading is reflected on the smart hub.

Further, to pair the thermostat and the smart hub, ‘smart home devices’ settings followed by “Z-wave” and “Add Node” 

settings are selected on the hub to pair with the thermostat. Furthermore, when the thermostat’s side button is held for 6 

seconds, it becomes detectable for the Z-wave network (“said media system being structured to detect said wireless 

mobile device within said wireless range”), and upon clicking the Connect button for the searched network, the 

thermostat is paired with the smart hub.

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 56 of 87 PageID #: 159
Complaint, Exhibit 4.

57

mobile 

device 

disposed 

within said 

wireless 

range,

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 57 of 87 PageID #: 160
Complaint, Exhibit 4.

58

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[32.4] a 

communicati

on link 

structured to 

dispose said 

media system 

and said 

wireless 

mobile 

device in a 

communicati

ve relation 

with one 

another via 

said at least 

one 

Company provides a communication link structured to dispose said media system and said wireless mobile device in a 

communicative relation with one another via said at least one interactive computer network, said communication link 

being initiated by said media system.

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

For example, to pair the thermostat with the smart hub, ‘smart home devices’ settings are selected on the hub. Further, 

“Z-wave” and “Add Node” settings are selected to pair with the thermostat (“said communication link being initiated by 

said at least one media system”). 

Further, when the pairing process is complete, a link ("communicative relation”) is established between the thermostat 

and the smart hub via Z-wave protocol (“said at least one interactive computer network”). 

Media system

Wireless mobile device

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 58 of 87 PageID #: 161
Complaint, Exhibit 4.

59

interactive 

computer 

network, said 

communicati

on link being 

initiated by 

said media 

system,

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Source: https://www.vivint.com/resources/article/smart-home-technologies-guide

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 Company.

[32.5] said 

wireless 

mobile 

device and 

media system 

Company provides said wireless mobile device and media system being structured to transmit said at least one digital 

media file therebetween via said communication link. 

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

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 59 of 87 PageID #: 162
Complaint, Exhibit 4.

60

being 

structured to 

transmit said 

at least one 

digital media 

file 

therebetween 

via said 

communicati

on link, and

For example, after the pairing process is complete, the temperature measured by the thermostat, is reflected on the bottom 

of the smart hub screen. Therefore, it would be apparent to a person having ordinary skill in the art that the thermostat 

constantly syncs (“transmit said at least one digital media file therebetween via said communication link”) the 

temperature reading with the smart hub. 

Source: https://www.vivint.com/products/smart-thermostat

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

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 Company.

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 60 of 87 PageID #: 163
Complaint, Exhibit 4.

61

[32.6] said 

communicati

on link is 

structured to 

bypass the 

security 

measure of 

the media 

system for a 

limited 

permissible 

use of the 

communicati

on link by the 

wireless 

mobile 

device for 

only 

transferring 

the at least 

one digital 

media file to, 

and 

displaying 

the at least 

one digital 

media file on, 

the media 

system.

Company provides said communication link is structured to bypass the security measure of the media system for a limited 

permissible use of the communication link by the wireless mobile device for only transferring the at least one digital 

media file to, and displaying the at least one digital media file on, the media system.

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

For example, once the devices are paired, a link is established between them, enabling the users to adjust the thermostat's 

temperature settings both from the thermostat and the smart hub as they are integrated with each other. As pairing is not 

necessary each time to make temperature adjustments via the smart hub, it would be apparent to a person having ordinary 

skill in the art that the established communication link is designed to bypass security measures related to the smart hub.

Additionally, the temperature reading from the connected thermostat device is constantly synced and reflected on the

smart hub (“displaying the at least one digital media file on, the media system”).

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 61 of 87 PageID #: 164
Complaint, Exhibit 4.

62

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (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 Company.

[37] The 

system of 

claim 32, 

wherein the 

communicati

on link is at 

least one of a 

peer-to-peer 

connection, 

bluetooth 

connection, 

and a WiFi 

connection.

Company provides the system of claim 32, wherein the communication link is at least one of a peer-to-peer connection, 

bluetooth connection, and a WiFi connection.

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

For example, the smart home devices such as thermostat communicate wirelessly with the smart hub using Z-Wave 

(‘peer-to-peer connection”).

digital media file on, the media system

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 62 of 87 PageID #: 165
Complaint, Exhibit 4.

63

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat (annotated)

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company

[39] The 

system of 

claim 32, 

further 

comprising 

presenting 

Company provides the system of claim 32, further comprising presenting the at least one digital media file on a display.

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

For example, the temperature reading is reflected on the smart hub (“presenting the at least one digital media file on a 

display.”)

Peer-to-peer connection

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 63 of 87 PageID #: 166
Complaint, Exhibit 4.

64

the at least 

one digital 

media file on 

a display.

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (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 Company

[40] The 

system of 

claim 32, 

wherein the at 

least one 

digital media 

file is 

provided by 

the wireless 

mobile 

device.

Company provides the system of claim 32, wherein the at least one digital media file is provided by the wireless mobile 

device.

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

For example, the thermostat provides features to adjust the temperature. Therefore, it would be apparent to a person 

having ordinary skill in the art that the digital media file is provided by the media node.

Media file on display

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 64 of 87 PageID #: 167
Complaint, Exhibit 4.

65

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated)

Media file

Adjust Temperature

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 65 of 87 PageID #: 168
Complaint, Exhibit 4.

66

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company

[42] A 

transfer 

system from 

transferring a 

media file 

over a 

communicati

on network, 

comprising a 

media 

system; and a 

wireless 

mobile 

device, 

wherein the 

Vivint (“Company”) makes, uses, sells and/or offers to sell a wireless mobile device configured to transmit a media file 

to a media system over a communication network having a security measure.

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

For example, Company offers a Home security system which comprises a Smart Hub (“media system”) which is paired 

with smart devices such as door locks, security camera and, thermostat (“wireless mobile device”) via Z-Wave 

Technology (“communication network”). Since the smart hub and the thermostat are fully integrated therefore, the 

reading on/measured by the thermostat (“media file”) is reflected on the smart hub. The pairing procedure between the 

smart hub and the thermostat indicates a presence of a security measure.

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 66 of 87 PageID #: 169
Complaint, Exhibit 4.

67

media system 

includes:

Source: https://www.vivint.com/packages/home-security

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated)

Media System

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 67 of 87 PageID #: 170
Complaint, Exhibit 4.

68

Source: https://www.vivint.com/products/smart-thermostat (annotated) 

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Mobile 

device

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 68 of 87 PageID #: 171
Complaint, Exhibit 4.

69

Source:

https://wwwassets.s3.amazonaws.com/global/vivint.com/Support/images/Vivint_SmartHubV2_GettingStartedGuide_E

NU%20-%20revA.2.pdf , Page 13

Source: https://www.vivint.com/products/smart-thermostat

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 Company.

[42.1] a 

wireless 

receiver,

Company provides a wireless receiver.

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

For example, the reading on/measured by the thermostat is reflected on the smart hub via Z-Wave network. Therefore, 

it would be apparent to a person having ordinary skill in the art that a wireless receiver is embedded inside the smart 

hub.

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 69 of 87 PageID #: 172
Complaint, Exhibit 4.

70

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated)

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated)

Media file

Adjust Temperature

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 70 of 87 PageID #: 173
Complaint, Exhibit 4.

71

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[42.2] a 

security 

measure; and

Company provides a security measure.

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

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 71 of 87 PageID #: 174
Complaint, Exhibit 4.

72

For example, to pair the thermostat and the smart hub, ‘smart home devices’ settings followed by “Z-wave” and “Add 

Node” settings are selected on the hub to pair with the thermostat. Further, when the thermostat’s side button is held for 

6 seconds, it becomes detectable for the Z-wave network, and upon clicking the Connect button for the searched network, 

the thermostat is paired with the smart hub. Therefore, the pairing procedure between the smart hub and the thermostat 

indicates a presence of a security measure.

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[42.2] a 

processor 

configured to

Company provides a processor.

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

For example, the smart hub receives the information from sensors such as thermostat and allows the user to adjust the 

temperature accordingly. Therefore, it would be apparent to a person having ordinary skill in the art that a processor is 

embedded inside the smart hub to process the gathered information.

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 72 of 87 PageID #: 175
Complaint, Exhibit 4.

73

Source: https://www.vivint.com/packages/home-automation (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 Company.

[42.3] the 

media system 

disposed in 

an accessible 

relation to at 

least one 

interactive 

computer 

network that 

has a wireless 

range 

structured to 

permit 

authorized 

access to said 

at least one 

interactive 

computer 

network,

Company provides the media system disposed in an accessible relation to at least one interactive computer network that 

has a wireless range structured to permit authorized access to said at least one interactive computer network.

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

For example, to pair (“accessible relation”) the smart hub and the thermostat, the devices must be within a range of 100 

meters (“a wireless range structured to permit authorized access”) of the Z-wave protocol (“computer network”). Further, 

Z-Wave network and devices in the Z-wave network are identified with their respective unique IDs. The unique IDs

prevents unauthorized devices to access the Z-wave network. Therefore, upon information and belief, the thermostat 

devices that are within the wireless range of the Z-wave protocol are structured to permit authorized access to pair with 

the smart hub.

Media System

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 73 of 87 PageID #: 176
Complaint, Exhibit 4.

74

Source: https://www.z-wave.com/learn

Source: https://www.techtarget.com/iotagenda/definition/Z-Wave

Source: https://www.vivint.com/resources/article/smart-home-technologies-guide

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 74 of 87 PageID #: 177
Complaint, Exhibit 4.

75

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[42.4] the 

wireless 

Company provides the wireless mobile device within said wireless range, wherein said wireless mobile device is 

detectable by said media system. 

Media terminal

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 75 of 87 PageID #: 178
Complaint, Exhibit 4.

76

mobile 

device within 

said wireless 

range, 

wherein said 

wireless 

mobile 

device is 

detectable by 

said media 

system,

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

For example, on the smart hub, ‘smart home devices’ settings followed by “Z-wave” and “Add Node” settings are 

selected on the hub to pair with the thermostat. Further, the thermostat's side button is held for 6 seconds to make it 

detectable for pairing with the hub (“wireless mobile device is detectable by said media system”).

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company.

[42.5] at least 

one digital 

media file 

initially 

disposed on 

the wireless 

mobile 

device, said 

media system 

Company provides at least one digital media file initially disposed on the wireless mobile device, said media system 

being structured to detect said wireless mobile device disposed within said wireless range. 

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

For example, the thermostat displays a current temperature and a target temperature (“digital media file initially disposed 

on the wireless mobile device”) and the same reading is reflected on the smart hub.

Media terminal

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 76 of 87 PageID #: 179
Complaint, Exhibit 4.

77

being 

structured to 

detect said 

wireless 

mobile 

device 

disposed 

within said 

wireless 

range,

Further, to pair the thermostat and the smart hub, ‘smart home devices’ settings followed by “Z-wave” and “Add Node” 

settings are selected on the hub to pair with the thermostat. Furthermore, when the thermostat’s side button is held for 6 

seconds, it becomes detectable for the Z-wave network (“said media system being structured to detect said wireless 

mobile device within said wireless range”), and upon clicking the Connect button for the searched network, the 

thermostat is paired with the smart hub.

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 77 of 87 PageID #: 180
Complaint, Exhibit 4.

78

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Media system

Wireless mobile device

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 78 of 87 PageID #: 181
Complaint, Exhibit 4.

79

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 Company.

[42.6] a 

communicati

on link 

structured to 

dispose said 

media system 

and said 

wireless 

mobile 

device in a 

communicati

ve relation 

with one 

another via 

said at least 

one 

interactive 

computer 

network,

said 

communicati

on link being 

initiated by 

said media 

system,

Company provides a communication link structured to dispose said media system and said wireless mobile device in a 

communicative relation with one another via said at least one interactive computer network, said communication link 

being initiated by said media system.

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

For example, to pair the thermostat with the smart hub, ‘smart home devices’ settings are selected on the hub. Further, 

“Z-wave” and “Add Node” settings are selected to pair with the thermostat (“said communication link being initiated by 

said at least one media system”). 

Further, when the pairing process is complete, a link ("communicative relation”) is established between the thermostat 

and the smart hub via Z-wave protocol (“said at least one interactive computer network”). 

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 79 of 87 PageID #: 182
Complaint, Exhibit 4.

80

Source: https://www.vivint.com/resources/article/smart-home-technologies-guide

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 Company.

[42.7] said 

wireless 

mobile 

device and 

media system 

being 

structured to 

transmit said 

at least one 

digital media 

file 

therebetween 

via said 

communicati

on link, and

Company provides said wireless mobile device and media system being structured to transmit said at least one digital 

media file therebetween via said communication link. 

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

For example, after the pairing process is complete, the temperature measured by the thermostat, is reflected on the bottom 

of the smart hub screen. Therefore, it would be apparent to a person having ordinary skill in the art that the thermostat 

constantly syncs (“transmit said at least one digital media file therebetween via said communication link”) the 

temperature reading with the smart hub. 

Source: https://www.vivint.com/products/smart-thermostat

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 80 of 87 PageID #: 183
Complaint, Exhibit 4.

81

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

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 Company.

[42.8] said 

communicati

on link is 

structured to 

bypass the 

security 

measure of 

the media 

system for a 

limited 

permissible 

use of the 

communicati

Company provides said communication link is structured to bypass the security measure of the media system for a limited 

permissible use of the communication link by the wireless mobile device for only transferring the at least one digital 

media file to, and displaying the at least one digital media file on, the media system.

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

For example, once the devices are paired, a link is established between them, enabling the users to adjust the thermostat’s 

temperature settings directly from the smart hub without the need to regularly pair the devices. As pairing is not necessary 

each time to make temperature adjustments via the smart hub, it would be apparent to a person having ordinary skill in 

the art that the established communication link is designed to bypass security measures related to the smart hub.

Additonally, the adjusted temperature from the connected thermostat device is reflected on the smart hub as the target 

temperature (“displaying the at least one digital media file on, the media system.”).

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 81 of 87 PageID #: 184
Complaint, Exhibit 4.

82

on link by the 

wireless 

mobile 

device for 

only 

transferring 

the at least 

one digital 

media file to, 

and 

displaying 

the at least 

one digital 

media file on, 

the media 

system.

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (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 Company.

[47] The 

system of 

Company provides the system of claim 42, wherein the communication link is at least one of a peer-to-peer connection, 

Bluetooth connection, and a WiFi connection.

Media file on display

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 82 of 87 PageID #: 185
Complaint, Exhibit 4.

83

claim 42, 

wherein the 

communicati

on link is at 

least one of a 

peer-to-peer 

connection, 

83luetooth

connection, 

and a WiFi 

connection.

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

For example, the smart home devices such as thermostat communicate wirelessly with the smart hub using Z-Wave 

(‘peer-to-peer connection”).

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat (annotated)

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company

Peer-to-peer connection

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 83 of 87 PageID #: 186
Complaint, Exhibit 4.

84

[49] The 

system of 

claim 42, 

further 

comprising 

presenting 

the at least 

one digital 

media file on 

a display.

Company provides the system of claim 42, further comprising presenting the at least one digital media file on a display.

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

For example, the temperature reading is reflected on the smart hub (“presenting the at least one digital media file on a 

display”).

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (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 Company

[50] The 

system of 

claim 32, 

wherein the at 

least one 

digital media 

file is 

Company provides the system of claim 32, wherein the at least one digital media file is provided by the wireless mobile 

device.

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

For example, the thermostat provides features to adjust the temperature. Therefore, it would be apparent to a person 

having ordinary skill in the art that the digital media file is provided by the media node.

Media file on display

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 84 of 87 PageID #: 187
Complaint, Exhibit 4.

85

provided by 

the wireless 

mobile 

device.

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat

Source: https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat (annotated)

Media file

Adjust Temperature

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 85 of 87 PageID #: 188
Complaint, Exhibit 4.

86

Source: https://support.vivint.com/article/Smart-Properties-Element-Thermostat

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 Company

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 86 of 87 PageID #: 189
Complaint, Exhibit 4.

87

2. List of References

1. https://www.vivint.com/packages/home-security, last accessed on 05th February, 2023.

2. https://www.vivint.com/products/smart-thermostat, last accessed on 05th February, 2023.

3. https://www.vivint.com/resources/article/smart-home-technologies-guide, last accessed on 05th February, 2023.

4. https://support.vivint.com/article/Smart-Properties-Element-Thermostat, last accessed on 05th February, 2023.

5. https://support.vivint.com/article/Smart-Hub-Adjust-Thermostat, last accessed on 05th February, 2023.

6. https://www.youtube.com/watch?v=NT36UmzH1A0, last accessed on 05th February, 2023.

7. https://support.vivint.com/article/element-change-temperature, last accessed on 05th February, 2023.

8. https://www.z-wave.com/learn, last accessed on 05th February, 2023.

9. https://www.techtarget.com/iotagenda/definition/Z-Wave, last accessed on 05th February, 2023.

Case 2:24-cv-00098-JRG-RSP Document 1-4 Filed 02/13/24 Page 87 of 87 PageID #: 190