Exhibit 4 to the Complaint.

1

U.S. Patent No. 9,300,723 v. Roche Accu-Chek.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 1 of 434 PageID #:

1270
Exhibit 4 to the Complaint.

2

1. Claim Chart

Claim Analysis

[1.P] A media 

system, 

comprising:

Roche 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 provides Accu-Chek Guide Meter, a blood glucose meter designed to measure blood sugar levels. 

This device transmits the measured blood sugar levels to the mySugr app, installed on the user's smartphone, using a 

Bluetooth network.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 2 of 434 PageID #:

1271
Exhibit 4 to the Complaint.

3

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 3 of 434 PageID #:

1272
Exhibit 4 to the Complaint.

4

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 4 of 434 PageID #:

1273
Exhibit 4 to the Complaint.

5

Source: https://www.mysugr.com/en-us/

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 5 of 434 PageID #:

1274
Exhibit 4 to the Complaint.

6

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 6 of 434 PageID #:

1275
Exhibit 4 to the Complaint.

7

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 7 of 434 PageID #:

1276
Exhibit 4 to the Complaint.

8

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 8 of 434 PageID #:

1277
Exhibit 4 to the Complaint.

9

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 9 of 434 PageID #:

1278
Exhibit 4 to the Complaint.

10

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

ann

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 10 of 434 PageID #:

1279
Exhibit 4 to the Complaint.

11

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 11 of 434 PageID #:

1280
Exhibit 4 to the Complaint.

12

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 12 of 434 PageID #:

1281
Exhibit 4 to the Complaint.

13

[1.1] at least 

one media 

terminal 

disposed in 

an accessible 

relation to at 

least one 

interactive 

computer 

network, 

Company makes, uses, sells and/or offers to sell 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 Accu-Chek Guide transmits the blood sugar levels to the mySugr app, installed on the user's smartphone 

("media terminal"), using Bluetooth network ("interactive computer network"). Since, the smartphone communicates 

and sends data to the Accu-Chek Guide using Bluetooth, it is apparent for a person having ordinary skills in the art that, 

at least one media terminal disposed in an accessible relation to at least one interactive computer network.

media 

terminal

interactive 

computer 

network

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 13 of 434 PageID #:

1282
Exhibit 4 to the Complaint.

14

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2 (annotated)

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09 (annotated)

interactive 

computer 

network

media 

terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 14 of 434 PageID #:

1283
Exhibit 4 to the Complaint.

15

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17 (annotated)

media 

terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 15 of 434 PageID #:

1284
Exhibit 4 to the Complaint.

16

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 16 of 434 PageID #:

1285
Exhibit 4 to the Complaint.

17

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:17 (annotated)

media

terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 17 of 434 PageID #:

1286
Exhibit 4 to the Complaint.

18

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 18 of 434 PageID #:

1287
Exhibit 4 to the Complaint.

19

Source: https://play.google.com/store/apps/details?id=com.mysugr.android.companion

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] a

wireless 

range 

structured to 

permit 

authorized 

access to

said at least 

one 

interactive 

computer 

network,

Company makes, uses, sells and/or offers to sell 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, the Accu-Chek Guide and the smartphone, on which the mySugr app is installed, are paired with each other 

using the Bluetooth network (“interactive computer network”). This network facilitates the pairing of the smartphone 

and the Accu-Chek Guide when they are within Bluetooth range of each other. To complete the Bluetooth pairing, the 

user is required to input the PIN (“permit authorized access”) of the Accu-Chek Guide into the mySugr app. It would be 

apparent to a person of ordinary skill in the art that wireless range structured to permit authorized access to at least one 

interactive computer network.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 19 of 434 PageID #:

1288
Exhibit 4 to the Complaint.

20

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 20 of 434 PageID #:

1289
Exhibit 4 to the Complaint.

21

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 21 of 434 PageID #:

1290
Exhibit 4 to the Complaint.

22

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 22 of 434 PageID #:

1291
Exhibit 4 to the Complaint.

23

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 23 of 434 PageID #:

1292
Exhibit 4 to the Complaint.

24

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 24 of 434 PageID #:

1293
Exhibit 4 to the Complaint.

25

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29 (annotated)

authorized 

access

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 25 of 434 PageID #:

1294
Exhibit 4 to the Complaint.

26

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 26 of 434 PageID #:

1295
Exhibit 4 to the Complaint.

27

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 27 of 434 PageID #:

1296
Exhibit 4 to the Complaint.

28

[1.3] 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,

Company makes, uses, sells and/or offers to sell 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.

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

For example, the Accu-Chek Guide ("media node") employs the Bluetooth network ("interactive computer network") to 

pair with the mySugr app which is installed on the user's smartphone. The Accu-Chek Guide is within the Bluetooth 

range of the smartphone where the mySugr app is installed. The mySugr detects the Accu-Chek Guide which is within 

its Bluetooth range (“disposable within the wireless range”). 

Source: https://www.accu-chek.com/products/mysugr (annotated)

media node

media terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 28 of 434 PageID #:

1297
Exhibit 4 to the Complaint.

29

Source: https://www.accu-chek.com/products/meters/guide

media 

node

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 29 of 434 PageID #:

1298
Exhibit 4 to the Complaint.

30

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70 

(annotated)

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 30 of 434 PageID #:

1299
Exhibit 4 to the Complaint.

31

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12 (annotated)

media 

terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 31 of 434 PageID #:

1300
Exhibit 4 to the Complaint.

32

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:17 (annotated)

media 

terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 32 of 434 PageID #:

1301
Exhibit 4 to the Complaint.

33

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19 (annotated)

media 

terminal

media node is 

detectable

by the media 

terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 33 of 434 PageID #:

1302
Exhibit 4 to the Complaint.

34

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:25 (annotated)

media 

terminal

media node is 

detectable

by the media 

terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 34 of 434 PageID #:

1303
Exhibit 4 to the Complaint.

35

Source: https://www.accu-chek.com/support/products/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 Defendant.

[1.4] at least 

one digital 

media file

initially 

Company makes, uses, sells and/or offers to sell 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.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 35 of 434 PageID #:

1304
Exhibit 4 to the Complaint.

36

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, the Accu-Chek Guide meter measures the blood sugar levels (“digital media file”). These measured blood 

sugar levels are saved in the Accu-Chek Guide meter (“digital media file initially disposed on at least one of said media 

terminal or said at least one media node”). The mySugr app installed in the user’s smartphone detects (“at least one media 

terminal structured to detect said at least one media node”) the Accu-Chek Guide meter through Bluetooth and establishes 

a connection (gets paired).

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 2 of 70 

(annotated)

media node

digital 

media file

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 36 of 434 PageID #:

1305
Exhibit 4 to the Complaint.

37

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70 

(annotated)

Source: https://www.accu-chek.com/products/meters/guide

media 

node

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 37 of 434 PageID #:

1306
Exhibit 4 to the Complaint.

38

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 38 of 434 PageID #:

1307
Exhibit 4 to the Complaint.

39

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19 (annotated)

media 

terminal

media terminal 

structured to detect 

said at least

one media node

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 39 of 434 PageID #:

1308
Exhibit 4 to the Complaint.

40

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:25 (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] a 

communicati

on link 

structured to 

dispose said 

at least one

Company makes, uses, sells and/or offers to sell 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.

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

media 

terminal

media terminal 

structured to detect 

said at least

one media node

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 40 of 434 PageID #:

1309
Exhibit 4 to the Complaint.

41

media 

terminal and 

said at least 

one media 

node in a

communicati

ve relation 

with one 

another via 

said at least

one 

interactive 

computer 

network,

For example, mySugr app installed on the user’s smartphone and Accu-Chek Guide establishes a connection through 

Bluetooth pairing. This process creates a Bluetooth channel (“communication link structured to dispose”) between AccuChek Guide meter and mySugr app for the transfer of the measured blood sugar levels (“a communicative relation with 

one another via said interactive computer network”).

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 41 of 434 PageID #:

1310
Exhibit 4 to the Complaint.

42

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 42 of 434 PageID #:

1311
Exhibit 4 to the Complaint.

43

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 43 of 434 PageID #:

1312
Exhibit 4 to the Complaint.

44

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 44 of 434 PageID #:

1313
Exhibit 4 to the Complaint.

45

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17 (annotated)

media 

terminal

media node

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 45 of 434 PageID #:

1314
Exhibit 4 to the Complaint.

46

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 46 of 434 PageID #:

1315
Exhibit 4 to the Complaint.

47

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 47 of 434 PageID #:

1316
Exhibit 4 to the Complaint.

48

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 48 of 434 PageID #:

1317
Exhibit 4 to the Complaint.

49

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[1.6] said 

communicati

on link being 

initiated by 

said at least 

one

Company makes, uses, sells and/or offers to sell 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, the mySugr app, installed on the smartphone, initiates Bluetooth pairing to establish the communication 

channel with the Accu-Chek Guide.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 49 of 434 PageID #:

1318
Exhibit 4 to the Complaint.

50

media 

terminal,

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 50 of 434 PageID #:

1319
Exhibit 4 to the Complaint.

51

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09 (annotated)

media 

terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 51 of 434 PageID #:

1320
Exhibit 4 to the Complaint.

52

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 52 of 434 PageID #:

1321
Exhibit 4 to the Complaint.

53

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 53 of 434 PageID #:

1322
Exhibit 4 to the Complaint.

54

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 54 of 434 PageID #:

1323
Exhibit 4 to the Complaint.

55

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 55 of 434 PageID #:

1324
Exhibit 4 to the Complaint.

56

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[1.7] said at 

least one 

media node 

and said at 

least one 

media

Company makes, uses, sells and/or offers to sell 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 communication link.

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

For example, after establishing a Bluetooth channel (“communication link”) between the mySugr app installed on the 

user’s smartphone and the Accu-Chek Guide, the Accu-Chek Guide (“media node") sends (“structured to transmit”) the 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 56 of 434 PageID #:

1325
Exhibit 4 to the Complaint.

57

terminal 

being 

structured to 

transmit said 

at least one

digital media 

file 

therebetween 

via said 

communicati

on

link, and 

measured blood sugar levels (“at least one digital media file”) to the mySugr app installed on the user’s smartphone 

(“media terminal”).

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 57 of 434 PageID #:

1326
Exhibit 4 to the Complaint.

58

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 58 of 434 PageID #:

1327
Exhibit 4 to the Complaint.

59

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40 (annotated)

media node 

transmits digital 

media file to 

media terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 59 of 434 PageID #:

1328
Exhibit 4 to the Complaint.

60

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43 (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.

[1.8] said 

communicati

on link is 

structured to 

bypass at 

least one

Company makes, uses, sells and/or offers to sell 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.

media node 

transmits 

digital media 

file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 60 of 434 PageID #:

1329
Exhibit 4 to the Complaint.

61

media 

terminal 

security 

measure for a 

limited 

permissible 

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.

For example, the Accu-Chek Guide meter and the mySugr app do not require users to input a PIN (“security 

measure”) every time they communicate. Instead, the PIN input is necessary during the initial pairing process, and 

thereafter, the devices automatically exchange data without requiring users to re-enter the PIN (“at least one

media terminal security measure”). The Accu-Chek Guide meter uses that communication channel only for 

transmitting the measured blood sugar levels to the mySugr app (“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”). The mySugr app displays the received the measured blood sugar levels. Therefore, upon information 

and belief, the Bluetooth channel created between Accu-Chek Guide meter and mySugr app bypass at least one

media terminal security measure.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 61 of 434 PageID #:

1330
Exhibit 4 to the Complaint.

62

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 62 of 434 PageID #:

1331
Exhibit 4 to the Complaint.

63

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 63 of 434 PageID #:

1332
Exhibit 4 to the Complaint.

64

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 64 of 434 PageID #:

1333
Exhibit 4 to the Complaint.

65

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 65 of 434 PageID #:

1334
Exhibit 4 to the Complaint.

66

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 66 of 434 PageID #:

1335
Exhibit 4 to the Complaint.

67

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 67 of 434 PageID #:

1336
Exhibit 4 to the Complaint.

68

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 68 of 434 PageID #:

1337
Exhibit 4 to the Complaint.

69

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

display 

digital 

media file 

media 

terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 69 of 434 PageID #:

1338
Exhibit 4 to the Complaint.

70

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 the production of such source code by Company.

[3] The 

method of 

claim 1, 

wherein the 

transmission 

of the media 

file from the 

at least one 

media node to 

the at least 

one media 

terminal 

completely 

bypasses the 

security 

measure.

Company makes, uses, sells and/or offers to sell the transmission of the media file from the at least one media node to 

the at least one media terminal completely bypasses the security measure.

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

For example, the Accu-Chek Guide meter and the mySugr app do not require users to input a PIN (“security 

measure”) every time they communicate. Instead, the PIN input is necessary during the initial pairing process, and 

thereafter, the devices automatically exchange data without requiring users to re-enter the PIN (bypasses the security 

measure). Therefore, upon information and belief, the Bluetooth channel created between Accu-Chek Guide meter 

and mySugr app bypass the security measure.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 70 of 434 PageID #:

1339
Exhibit 4 to the Complaint.

71

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 71 of 434 PageID #:

1340
Exhibit 4 to the Complaint.

72

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 72 of 434 PageID #:

1341
Exhibit 4 to the Complaint.

73

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 73 of 434 PageID #:

1342
Exhibit 4 to the Complaint.

74

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 74 of 434 PageID #:

1343
Exhibit 4 to the Complaint.

75

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 75 of 434 PageID #:

1344
Exhibit 4 to the Complaint.

76

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 76 of 434 PageID #:

1345
Exhibit 4 to the Complaint.

77

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 77 of 434 PageID #:

1346
Exhibit 4 to the Complaint.

78

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

digital 

media file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 78 of 434 PageID #:

1347
Exhibit 4 to the Complaint.

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 the production of such source code by Company.

[6] The 

system of 

claim 1, 

wherein the 

communicati

on link

is at least one 

of a peer-topeer 

connection, 

bluetooth 

connec

tion, and a 

WiFi 

connection.

Company makes, uses, sells and/or offers to sell 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, mySugr app installed in the user’s smartphone detects the Accu-Chek Guide meter through Bluetooth and 

establishes a connection (“communication link”).

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 79 of 434 PageID #:

1348
Exhibit 4 to the Complaint.

80

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 80 of 434 PageID #:

1349
Exhibit 4 to the Complaint.

81

Source: https://www.accu-chek.com/support/products/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 Defendant.

[8] The 

system of 

claim 1, 

further 

comprising 

Company makes, uses, sells and/or offers to sell 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 mySugr app installed on the user’s smartphone displays the measured blood sugar levels.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 81 of 434 PageID #:

1350
Exhibit 4 to the Complaint.

82

presenting 

the

at least one 

digital media 

file on a 

display.

Source: https://www.accu-chek.com/products/meters/guide

 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 82 of 434 PageID #:

1351
Exhibit 4 to the Complaint.

83

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

display 

digital 

media file 

media 

terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 83 of 434 PageID #:

1352
Exhibit 4 to the Complaint.

84

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.

[9] The 

system of 

claim 1, 

wherein the at 

least one 

digital media 

file is 

provided by 

the at least 

one media 

node.

Company makes, uses, sells and/or offers to sell 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 Accu-Chek Guide (“media node") sends the measured blood sugar levels (“at least one digital media 

file”) to the mySugr app installed on the user’s smartphone.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 84 of 434 PageID #:

1353
Exhibit 4 to the Complaint.

85

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 85 of 434 PageID #:

1354
Exhibit 4 to the Complaint.

86

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 86 of 434 PageID #:

1355
Exhibit 4 to the Complaint.

87

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40 (annotated)

media node

transmits digital 

media file to 

media terminal

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 87 of 434 PageID #:

1356
Exhibit 4 to the Complaint.

88

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43 (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.

[12.P] A 

media system 

configured to 

receive a 

media file 

from

Roche Diagnostics Corporation (“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.

media node

transmits digital 

media file

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 88 of 434 PageID #:

1357
Exhibit 4 to the Complaint.

89

a wireless 

mobile 

device over 

communicati

on network, 

com

prising:

For example, Company provides mySugr app (“media system”) to receive measured blood sugar levels from a AccuChek Guide meter (“wireless mobile device”). The mySugr app, installed on the user's smartphone, receive the measured 

blood sugar levels from the Accu-Chek Guide, using a Bluetooth network.

Source: https://www.mysugr.com/en-us/

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 89 of 434 PageID #:

1358
Exhibit 4 to the Complaint.

90

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 90 of 434 PageID #:

1359
Exhibit 4 to the Complaint.

91

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 91 of 434 PageID #:

1360
Exhibit 4 to the Complaint.

92

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 92 of 434 PageID #:

1361
Exhibit 4 to the Complaint.

93

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 93 of 434 PageID #:

1362
Exhibit 4 to the Complaint.

94

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 94 of 434 PageID #:

1363
Exhibit 4 to the Complaint.

95

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 95 of 434 PageID #:

1364
Exhibit 4 to the Complaint.

96

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 96 of 434 PageID #:

1365
Exhibit 4 to the Complaint.

97

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 97 of 434 PageID #:

1366
Exhibit 4 to the Complaint.

98

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 98 of 434 PageID #:

1367
Exhibit 4 to the Complaint.

99

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[12.1] a 

wireless 

receiver;

Company makes, uses, sells and/or offers to sell a wireless receiver.

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

For example, the mySugr app, installed on the user's smartphone, includes a Bluetooth receiver (“wireless receiver”) for 

receiving data from the Accu-Chek Guide.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 99 of 434 PageID #:

1368
Exhibit 4 to the Complaint.

100

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 100 of 434 PageID #:

1369
Exhibit 4 to the Complaint.

101

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 101 of 434 PageID #:

1370
Exhibit 4 to the Complaint.

102

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07

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.

[12.2] a 

security 

measure; and

Company makes, uses, sells and/or offers to sell a security measure.

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

For example, the mySugr app, installed on the user’s smartphone, initially require users to input a PIN (“security 

measure”) which is necessary during the initial pairing process with the Accu-Chek Guide.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 102 of 434 PageID #:

1371
Exhibit 4 to the Complaint.

103

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 103 of 434 PageID #:

1372
Exhibit 4 to the Complaint.

104

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 104 of 434 PageID #:

1373
Exhibit 4 to the Complaint.

105

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 105 of 434 PageID #:

1374
Exhibit 4 to the Complaint.

106

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 106 of 434 PageID #:

1375
Exhibit 4 to the Complaint.

107

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 107 of 434 PageID #:

1376
Exhibit 4 to the Complaint.

108

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

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.

[12.3] the 

media system 

disposed in 

an accessible 

relation to at

least one 

interactive 

computer 

Company makes, uses, sells and/or offers to sell 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, the mySugr app, installed on the user's smartphone ("media system") receives the blood sugar levels from 

the Accu-Chek Guide using Bluetooth network ("interactive computer network"). Since, the smartphone communicates 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 108 of 434 PageID #:

1377
Exhibit 4 to the Complaint.

109

network that 

has a wire

less range 

structured to 

permit 

authorized 

access to said

at least one 

interactive 

computer 

network,

and receives data from the Accu-Chek Guide using Bluetooth, it is apparent for a person having ordinary skills in the art 

that, 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 at least one interactive computer network.

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2 (annotated)

interactive 

computer 

network

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 109 of 434 PageID #:

1378
Exhibit 4 to the Complaint.

110

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09 (annotated)

interactive 

computer 

network

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 110 of 434 PageID #:

1379
Exhibit 4 to the Complaint.

111

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 111 of 434 PageID #:

1380
Exhibit 4 to the Complaint.

112

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 112 of 434 PageID #:

1381
Exhibit 4 to the Complaint.

113

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:17 (annotated)

media

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 113 of 434 PageID #:

1382
Exhibit 4 to the Complaint.

114

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 114 of 434 PageID #:

1383
Exhibit 4 to the Complaint.

115

Source: https://play.google.com/store/apps/details?id=com.mysugr.android.companion

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.

[12.4] the 

wireless 

mobile 

device within 

said wireless 

range,

wherein said 

wireless 

mobile 

device is 

detectable by 

said

media 

system, 

Company makes, uses, sells and/or offers to sell 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, the Accu-Chek Guide (“wireless mobile device”) and the smartphone (“media system”), on which the 

mySugr app is installed, are paired with each other using the Bluetooth network (“interactive computer network”). This 

network facilitates the pairing of the smartphone and the Accu-Chek Guide when they are within Bluetooth range of 

each other. The mySugr app detects the list of Accu-Chek Guides which are in the Bluetooth range (“wireless mobile 

device is detectable by said media system”).

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 115 of 434 PageID #:

1384
Exhibit 4 to the Complaint.

116

Source: https://www.accu-chek.com/products/mysugr (annotated)

Source: https://www.accu-chek.com/products/meters/guide

wireless mobile device

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 116 of 434 PageID #:

1385
Exhibit 4 to the Complaint.

117

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 117 of 434 PageID #:

1386
Exhibit 4 to the Complaint.

118

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 118 of 434 PageID #:

1387
Exhibit 4 to the Complaint.

119

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 119 of 434 PageID #:

1388
Exhibit 4 to the Complaint.

120

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 120 of 434 PageID #:

1389
Exhibit 4 to the Complaint.

121

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 121 of 434 PageID #:

1390
Exhibit 4 to the Complaint.

122

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 122 of 434 PageID #:

1391
Exhibit 4 to the Complaint.

123

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 123 of 434 PageID #:

1392
Exhibit 4 to the Complaint.

124

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[12.5] at least 

one digital 

media file 

initially 

disposed on 

the

Company makes, uses, sells and/or offers to sell 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 Accu-Chek Guide ("wireless mobile device") employs the Bluetooth network to pair with the mySugr 

app which is installed on the user's smartphone. The mySugr app detects the Accu-Chek Guides which are within its 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 124 of 434 PageID #:

1393
Exhibit 4 to the Complaint.

125

wireless 

mobile 

device, said 

media system 

being 

structured to 

detect said 

wireless 

mobile 

device 

disposed 

within said 

wireless 

range,

Bluetooth range (“media system being structured to detect said wireless mobile device disposed within said wireless 

range”).

Source: https://www.accu-chek.com/products/mysugr (annotated)

wireless mobile 

device

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 125 of 434 PageID #:

1394
Exhibit 4 to the Complaint.

126

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70 

(annotated)

wireless 

mobile 

device

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 126 of 434 PageID #:

1395
Exhibit 4 to the Complaint.

127

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 127 of 434 PageID #:

1396
Exhibit 4 to the Complaint.

128

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 128 of 434 PageID #:

1397
Exhibit 4 to the Complaint.

129

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:17 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 129 of 434 PageID #:

1398
Exhibit 4 to the Complaint.

130

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19 (annotated)

media 

system

wireless mobile 

device is detectable

by the media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 130 of 434 PageID #:

1399
Exhibit 4 to the Complaint.

131

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:25 (annotated)

media 

system

wireless mobile 

device is detectable

by the media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 131 of 434 PageID #:

1400
Exhibit 4 to the Complaint.

132

Source: https://www.accu-chek.com/support/products/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 Defendant.

[12.6] a 

communicati

on link 

structured to 

Company makes, uses, sells and/or offers to sell 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.

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

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 132 of 434 PageID #:

1401
Exhibit 4 to the Complaint.

133

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,

For example, mySugr app installed on the user’s smartphone and Accu-Chek Guide establishes a connection through 

Bluetooth pairing. This process creates a Bluetooth channel (“communication link structured to dispose”) between AccuChek Guide meter and mySugr app for the transfer of the measured blood sugar levels (“a communicative relation with 

one another via said at least interactive computer network”).

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 133 of 434 PageID #:

1402
Exhibit 4 to the Complaint.

134

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 134 of 434 PageID #:

1403
Exhibit 4 to the Complaint.

135

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 135 of 434 PageID #:

1404
Exhibit 4 to the Complaint.

136

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 136 of 434 PageID #:

1405
Exhibit 4 to the Complaint.

137

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17 (annotated)

media 

system

wireless 

mobile 

device

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 137 of 434 PageID #:

1406
Exhibit 4 to the Complaint.

138

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 138 of 434 PageID #:

1407
Exhibit 4 to the Complaint.

139

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 139 of 434 PageID #:

1408
Exhibit 4 to the Complaint.

140

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 140 of 434 PageID #:

1409
Exhibit 4 to the Complaint.

141

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[12.7] said 

communicati

on link being 

initiated by 

said media

system,

Company makes, uses, sells and/or offers to sell 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, the mySugr app, installed on the smartphone, initiates Bluetooth pairing to establish the communication 

channel with the Accu-Chek Guide.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 141 of 434 PageID #:

1410
Exhibit 4 to the Complaint.

142

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 142 of 434 PageID #:

1411
Exhibit 4 to the Complaint.

143

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 143 of 434 PageID #:

1412
Exhibit 4 to the Complaint.

144

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 144 of 434 PageID #:

1413
Exhibit 4 to the Complaint.

145

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 145 of 434 PageID #:

1414
Exhibit 4 to the Complaint.

146

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 146 of 434 PageID #:

1415
Exhibit 4 to the Complaint.

147

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 147 of 434 PageID #:

1416
Exhibit 4 to the Complaint.

148

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[12.8] said 

wireless 

mobile 

device and 

media system 

being 

structured to 

Company makes, uses, sells and/or offers to sell 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 establishing a Bluetooth channel (“communication link”) between the mySugr app installed on the 

user’s smartphone and the Accu-Chek Guide, the Accu-Chek Guide (“wireless mobile device") sends (“structured to 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 148 of 434 PageID #:

1417
Exhibit 4 to the Complaint.

149

transmit said 

at least one 

digital media 

file

therebetween 

via said 

communicati

on link, and

transmit”) the measured blood sugar levels (“at least one digital media file”) to the mySugr app installed on the user’s 

smartphone (“media system”).

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 149 of 434 PageID #:

1418
Exhibit 4 to the Complaint.

150

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 150 of 434 PageID #:

1419
Exhibit 4 to the Complaint.

151

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40 (annotated)

wireless mobile 

device transmits 

digital media file 

to media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 151 of 434 PageID #:

1420
Exhibit 4 to the Complaint.

152

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43 (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.

[12.9] said 

communicati

on link is 

structured to 

bypass the 

security 

measure of 

Company makes, uses, sells and/or offers to sell 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.

wireless mobile 

device transmits 

digital media file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 152 of 434 PageID #:

1421
Exhibit 4 to the Complaint.

153

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.

For example, the Accu-Chek Guide meter and the mySugr app do not require users to input a PIN (“security 

measure”) every time they communicate. Instead, the PIN input is necessary during the initial pairing process, and 

thereafter, the devices automatically exchange data without requiring users to re-enter the PIN (“security measure of 

the media system”). The Accu-Chek Guide meter utilizes that communication channel exclusively for transmitting 

the measured blood sugar levels to the mySugr app (“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”). The mySugr app displays the received the measured blood sugar levels. Therefore, upon information 

and belief, the Bluetooth channel created between Accu-Chek Guide meter and mySugr app bypass the security 

measure of the media system.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 153 of 434 PageID #:

1422
Exhibit 4 to the Complaint.

154

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 154 of 434 PageID #:

1423
Exhibit 4 to the Complaint.

155

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 155 of 434 PageID #:

1424
Exhibit 4 to the Complaint.

156

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 156 of 434 PageID #:

1425
Exhibit 4 to the Complaint.

157

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 157 of 434 PageID #:

1426
Exhibit 4 to the Complaint.

158

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 158 of 434 PageID #:

1427
Exhibit 4 to the Complaint.

159

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 159 of 434 PageID #:

1428
Exhibit 4 to the Complaint.

160

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 160 of 434 PageID #:

1429
Exhibit 4 to the Complaint.

161

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

display 

digital 

media file 

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 161 of 434 PageID #:

1430
Exhibit 4 to the Complaint.

162

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 the production of such source code by Company.

[14] The 

media system 

of claim 12, 

wherein the 

transmission 

of the at least 

one digital 

media file 

from the 

wireless

mobile 

device to the 

media system 

completely 

bypasses the

security 

measure.

Company makes, uses, sells and/or offers to sell the transmission of the at least one digital media file from the wireless

mobile device to the media system completely bypasses the security measure.

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

For example, the Accu-Chek Guide meter and the mySugr app do not require users to input a PIN (“security 

measure”) every time they communicate. Instead, the PIN input is necessary during the initial pairing process, and 

thereafter, the devices automatically exchange data without requiring users to re-enter the PIN (“bypasses the security 

measure”). Therefore, upon information and belief, the Bluetooth channel created between Accu-Chek Guide meter 

and mySugr app completely bypasses the security measure.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 162 of 434 PageID #:

1431
Exhibit 4 to the Complaint.

163

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 163 of 434 PageID #:

1432
Exhibit 4 to the Complaint.

164

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 164 of 434 PageID #:

1433
Exhibit 4 to the Complaint.

165

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 165 of 434 PageID #:

1434
Exhibit 4 to the Complaint.

166

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 166 of 434 PageID #:

1435
Exhibit 4 to the Complaint.

167

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 167 of 434 PageID #:

1436
Exhibit 4 to the Complaint.

168

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 168 of 434 PageID #:

1437
Exhibit 4 to the Complaint.

169

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 169 of 434 PageID #:

1438
Exhibit 4 to the Complaint.

170

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

digital 

media file 

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 170 of 434 PageID #:

1439
Exhibit 4 to the Complaint.

171

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 the production of such source code by Company.

[17] The 

media system 

of claim 12, 

wherein the 

communicati

on link is at 

least one of a 

peer-to-peer 

connection, 

blue

tooth 

connection, 

and a WiFi 

connection. 

Company makes, uses, sells and/or offers to sell 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 mySugr app installed in the user’s smartphone detects the Accu-Chek Guide meter through Bluetooth 

and establishes a connection (“communication link”) for receiving the measured blood sugar level.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 171 of 434 PageID #:

1440
Exhibit 4 to the Complaint.

172

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 172 of 434 PageID #:

1441
Exhibit 4 to the Complaint.

173

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2 (annotated)

bluetooth 

connection

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 173 of 434 PageID #:

1442
Exhibit 4 to the Complaint.

174

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07

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.

[19] The 

media system 

of claim 12, 

wherein the 

further

media system 

is configured 

Company makes, uses, sells and/or offers to sell media system is configured to present 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 mySugr app installed on the user’s smartphone (“media system”), displays (“present”) the measured 

blood sugar levels (“digital media file”).

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 174 of 434 PageID #:

1443
Exhibit 4 to the Complaint.

175

to present the 

at least one 

digital

media file on 

a display.

Source: https://www.accu-chek.com/products/meters/guide

 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 175 of 434 PageID #:

1444
Exhibit 4 to the Complaint.

176

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

display 

digital 

media file 

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 176 of 434 PageID #:

1445
Exhibit 4 to the Complaint.

177

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.

[20] The 

media system 

of claim 12, 

wherein the at 

least one

media file is 

provided by 

the wireless 

mobile 

device.

Company makes, uses, sells and/or offers to sell at least one 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 Accu-Chek Guide (“wireless mobile device") sends the measured blood sugar levels (“at least one 

media file”) to the mySugr app installed on the user’s smartphone.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 177 of 434 PageID #:

1446
Exhibit 4 to the Complaint.

178

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 178 of 434 PageID #:

1447
Exhibit 4 to the Complaint.

179

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 179 of 434 PageID #:

1448
Exhibit 4 to the Complaint.

180

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40 (annotated)

wireless mobile 

device transmits 

media file to 

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 180 of 434 PageID #:

1449
Exhibit 4 to the Complaint.

181

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43 (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.

[22.P] A 

method of 

transferring a 

media file 

from a 

wireless

Roche Diagnostics Corporation (“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.

wireless mobile 

device transmits 

media file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 181 of 434 PageID #:

1450
Exhibit 4 to the Complaint.

182

mobile 

device to a 

media system 

over a 

communicati

on network, 

the media 

system 

including a 

security 

measure, 

comprising:

For example, Company provides mySugr app (“media system”) to receive measured blood sugar levels from a AccuChek Guide meter (“wireless mobile device”). The mySugr app, installed on the user's smartphone, receive the measured 

blood sugar levels from the Accu-Chek Guide, using a Bluetooth network (“communication network”). The mySugr app, 

initially require users to input a PIN (“security measure”) which is necessary during the initial pairing process with the 

Accu-Chek Guide, and thereafter, the devices automatically exchange data without requiring users to re-enter the PIN.

Source: https://www.mysugr.com/en-us/

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 182 of 434 PageID #:

1451
Exhibit 4 to the Complaint.

183

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 183 of 434 PageID #:

1452
Exhibit 4 to the Complaint.

184

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 184 of 434 PageID #:

1453
Exhibit 4 to the Complaint.

185

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 185 of 434 PageID #:

1454
Exhibit 4 to the Complaint.

186

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 186 of 434 PageID #:

1455
Exhibit 4 to the Complaint.

187

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 187 of 434 PageID #:

1456
Exhibit 4 to the Complaint.

188

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 188 of 434 PageID #:

1457
Exhibit 4 to the Complaint.

189

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 189 of 434 PageID #:

1458
Exhibit 4 to the Complaint.

190

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 190 of 434 PageID #:

1459
Exhibit 4 to the Complaint.

191

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 191 of 434 PageID #:

1460
Exhibit 4 to the Complaint.

192

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[22.1] 

disposing the 

media system 

in an 

accessible 

relation to at

Company performs and/or induces others to perform the 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.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 192 of 434 PageID #:

1461
Exhibit 4 to the Complaint.

193

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,

For example, the mySugr app, installed on the user's smartphone ("media system") receives the blood sugar levels from 

the Accu-Chek Guide (“wireless mobile device”) using Bluetooth network ("interactive computer network"). The AccuChek Guide and the smartphone, on which the mySugr app is installed, are paired with each other using the Bluetooth 

network. The pairing process requires the user to input PIN and enables (“permit authorized access”) the Accu-Chek 

Guide to send the measured blood sugar levels to the mySugr app. The mySugr app detects the Accu-Chek Guide which 

is in the Bluetooth range (“detectable by said media system”). Since, the smartphone communicates and receives data 

from the Accu-Chek Guide using Bluetooth, it is apparent for a person having ordinary skills in the art that, 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 at least one interactive computer network.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 193 of 434 PageID #:

1462
Exhibit 4 to the Complaint.

194

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2 (annotated)

media 

system

interactive 

computer 

network

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 194 of 434 PageID #:

1463
Exhibit 4 to the Complaint.

195

Source: https://www.accu-chek.com/products/mysugr (annotated)

wireless mobile device

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 195 of 434 PageID #:

1464
Exhibit 4 to the Complaint.

196

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09 (annotated)

interactive 

computer 

network

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 196 of 434 PageID #:

1465
Exhibit 4 to the Complaint.

197

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 197 of 434 PageID #:

1466
Exhibit 4 to the Complaint.

198

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 198 of 434 PageID #:

1467
Exhibit 4 to the Complaint.

199

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:17 (annotated)

media

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 199 of 434 PageID #:

1468
Exhibit 4 to the Complaint.

200

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 200 of 434 PageID #:

1469
Exhibit 4 to the Complaint.

201

Source: https://play.google.com/store/apps/details?id=com.mysugr.android.companion

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.

[22.2] 

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

Company performs and/or induces others to perform the 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.

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

For example, the Accu-Chek Guide meter measures the blood sugar levels (“digital media file”). These measured blood 

sugar levels are saved in the Accu-Chek Guide meter (“initially disposing at least one digital media file on the wireless 

mobile device”). The mySugr app installed in the user’s smartphone detects (“media system being structured to detect 

said wireless mobile device”) the Accu-Chek Guide meter which are in its Bluetooth range and establishes a connection 

(gets paired).

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 201 of 434 PageID #:

1470
Exhibit 4 to the Complaint.

202

within said 

wireless 

range, 

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 2 of 70 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 202 of 434 PageID #:

1471
Exhibit 4 to the Complaint.

203

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70 

(annotated)

Source: https://www.accu-chek.com/products/meters/guide

wireless mobile 

device

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 203 of 434 PageID #:

1472
Exhibit 4 to the Complaint.

204

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 204 of 434 PageID #:

1473
Exhibit 4 to the Complaint.

205

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19 (annotated)

media 

system

media system 

structured to detect

wireless mobile 

device

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 205 of 434 PageID #:

1474
Exhibit 4 to the Complaint.

206

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:25 (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.

[22.3] 

structuring a 

communicati

on link to 

dispose said 

media

Company performs and/or induces others to perform the 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,

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

media 

system

media system 

structured to detect 

wireless mobile 

device

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 206 of 434 PageID #:

1475
Exhibit 4 to the Complaint.

207

system and 

said wireless 

mobile 

device in a 

communicative relation 

with one 

another via 

said at least 

one

interactive 

computer 

network,

For example, mySugr app installed on the user’s smartphone and Accu-Chek Guide establishes a connection through 

Bluetooth pairing. This process creates a Bluetooth channel (“structuring a communication link to dispose”) between 

Accu-Chek Guide meter and mySugr app for the transfer of the measured blood sugar levels (“communicative relation 

with one another via said at least one interactive computer network”).

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 207 of 434 PageID #:

1476
Exhibit 4 to the Complaint.

208

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 208 of 434 PageID #:

1477
Exhibit 4 to the Complaint.

209

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 209 of 434 PageID #:

1478
Exhibit 4 to the Complaint.

210

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 210 of 434 PageID #:

1479
Exhibit 4 to the Complaint.

211

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17 (annotated)

media 

system

wireless 

mobile 

device

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 211 of 434 PageID #:

1480
Exhibit 4 to the Complaint.

212

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 212 of 434 PageID #:

1481
Exhibit 4 to the Complaint.

213

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 213 of 434 PageID #:

1482
Exhibit 4 to the Complaint.

214

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 214 of 434 PageID #:

1483
Exhibit 4 to the Complaint.

215

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[22.4] 

initiating said 

communicati

on link by 

said media 

system,

Company performs and/or induces others to perform the step of initiating said communication link by said media system.

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

For example, the mySugr app, installed on the smartphone, initiates Bluetooth pairing to establish the communication 

channel with the Accu-Chek Guide.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 215 of 434 PageID #:

1484
Exhibit 4 to the Complaint.

216

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 216 of 434 PageID #:

1485
Exhibit 4 to the Complaint.

217

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 217 of 434 PageID #:

1486
Exhibit 4 to the Complaint.

218

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 218 of 434 PageID #:

1487
Exhibit 4 to the Complaint.

219

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 219 of 434 PageID #:

1488
Exhibit 4 to the Complaint.

220

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 220 of 434 PageID #:

1489
Exhibit 4 to the Complaint.

221

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 221 of 434 PageID #:

1490
Exhibit 4 to the Complaint.

222

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[22.5] 

transmitting 

by said 

wireless 

mobile 

device to the 

media

Company performs and/or induces others to perform the 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 establishing a Bluetooth channel (“communication link”) between the mySugr app installed on the 

user’s smartphone and the Accu-Chek Guide, the Accu-Chek Guide (“wireless mobile device") sends (“transmitting”) 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 222 of 434 PageID #:

1491
Exhibit 4 to the Complaint.

223

system said at 

least one 

digital media 

file 

therebetween

via said 

communicati

on link, and

the measured blood sugar levels (“at least one digital media file”) to the mySugr app installed on the user’s smartphone 

(“media system”).

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 223 of 434 PageID #:

1492
Exhibit 4 to the Complaint.

224

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 224 of 434 PageID #:

1493
Exhibit 4 to the Complaint.

225

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40 (annotated)

wireless mobile 

device transmits 

digital media file 

to media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 225 of 434 PageID #:

1494
Exhibit 4 to the Complaint.

226

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43 (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.

[22.6] 

wherein said 

communicati

on link is 

structured to 

bypass

Company performs and/or induces others to perform the step of 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.

wireless mobile 

device transmits 

digital media file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 226 of 434 PageID #:

1495
Exhibit 4 to the Complaint.

227

the security 

measure of 

the media 

system for a 

limited

permissible 

use of the 

communicati

on link by the 

wire

less 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.

For example, the Accu-Chek Guide meter and the mySugr app do not require users to input a PIN (“security 

measure”) every time they communicate. Instead, the PIN input is necessary during the initial pairing process, and 

thereafter, the devices automatically exchange data without requiring users to re-enter the PIN (“security measure of 

the media system”). The Accu-Chek Guide meter utilizes that communication channel exclusively for transmitting 

the measured blood sugar levels to the mySugr app (“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”). The mySugr app displays the received the measured blood sugar levels. Therefore, upon information 

and belief, the Bluetooth channel created between Accu-Chek Guide meter and mySugr app bypass the security 

measure of the media system.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 227 of 434 PageID #:

1496
Exhibit 4 to the Complaint.

228

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 228 of 434 PageID #:

1497
Exhibit 4 to the Complaint.

229

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 229 of 434 PageID #:

1498
Exhibit 4 to the Complaint.

230

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 230 of 434 PageID #:

1499
Exhibit 4 to the Complaint.

231

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 231 of 434 PageID #:

1500
Exhibit 4 to the Complaint.

232

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 232 of 434 PageID #:

1501
Exhibit 4 to the Complaint.

233

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 233 of 434 PageID #:

1502
Exhibit 4 to the Complaint.

234

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 234 of 434 PageID #:

1503
Exhibit 4 to the Complaint.

235

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

display 

digital 

media file 

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 235 of 434 PageID #:

1504
Exhibit 4 to the Complaint.

236

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 the production of such source code by Company.

[24] The 

method of 

claim 22, 

wherein the 

transmission 

of the at least 

one digital 

media file 

from the 

wireless 

mobile

device to the 

media system 

completely 

bypasses the 

security 

measure.

Company performs and/or induces others to perform the step of transmission of the at least one digital media file from 

the wireless mobile device to the media system completely bypasses the security measure.

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

For example, the Accu-Chek Guide meter and the mySugr app do not require users to input a PIN (“security measure”) 

every time they communicate. Instead, the PIN input is necessary during the initial pairing process, and thereafter, the 

devices automatically exchange data without requiring users to re-enter the PIN (“bypasses the security measure”). 

Therefore, upon information and belief, the Bluetooth channel created between Accu-Chek Guide meter and mySugr app 

bypass the security measure.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 236 of 434 PageID #:

1505
Exhibit 4 to the Complaint.

237

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 237 of 434 PageID #:

1506
Exhibit 4 to the Complaint.

238

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 238 of 434 PageID #:

1507
Exhibit 4 to the Complaint.

239

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 239 of 434 PageID #:

1508
Exhibit 4 to the Complaint.

240

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 240 of 434 PageID #:

1509
Exhibit 4 to the Complaint.

241

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 241 of 434 PageID #:

1510
Exhibit 4 to the Complaint.

242

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 242 of 434 PageID #:

1511
Exhibit 4 to the Complaint.

243

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 243 of 434 PageID #:

1512
Exhibit 4 to the Complaint.

244

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

digital 

media file 

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 244 of 434 PageID #:

1513
Exhibit 4 to the Complaint.

245

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.

[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/or induces others to perform the step of 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 mySugr app installed in the user’s smartphone detects the Accu-Chek Guide meter through Bluetooth 

and establishes a connection (“communication link”) for receiving the measured blood sugar level.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 245 of 434 PageID #:

1514
Exhibit 4 to the Complaint.

246

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 246 of 434 PageID #:

1515
Exhibit 4 to the Complaint.

247

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2 (annotated)

bluetooth 

connection

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 247 of 434 PageID #:

1516
Exhibit 4 to the Complaint.

248

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07

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.

[29] The 

method of 

claim 22, 

further 

comprising 

presenting

the at least 

one digital 

Company performs and/or induces others to perform the step of 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 mySugr app installed on the user’s smartphone displays (“presenting”) the measured blood sugar levels 

(“digital media file”).

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 248 of 434 PageID #:

1517
Exhibit 4 to the Complaint.

249

media file on 

a display.

Source: https://www.accu-chek.com/products/meters/guide

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 249 of 434 PageID #:

1518
Exhibit 4 to the Complaint.

250

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

display 

digital 

media file 

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 250 of 434 PageID #:

1519
Exhibit 4 to the Complaint.

251

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.

[30] The 

method of 

claim 22, 

wherein the at 

least one 

digital media 

file is 

provided by 

the wireless 

mobile 

device.

Company performs and/or induces others to perform the step of 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 Accu-Chek Guide (“wireless mobile device") transmits the measured blood sugar levels (“at least one 

digital media file”) to the mySugr app installed on the user’s smartphone.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 251 of 434 PageID #:

1520
Exhibit 4 to the Complaint.

252

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 252 of 434 PageID #:

1521
Exhibit 4 to the Complaint.

253

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 253 of 434 PageID #:

1522
Exhibit 4 to the Complaint.

254

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40 (annotated)

wireless mobile 

device transmits 

digital media 

file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 254 of 434 PageID #:

1523
Exhibit 4 to the Complaint.

255

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43 (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.

[32.P] A 

wireless 

mobile 

device 

configured to 

transmit a

Roche Diagnostics Corporation (“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 provides Accu-Chek Guide (“wireless mobile device”), a blood glucose meter designed to 

measure blood sugar levels. This device transmits the measured blood sugar levels to the mySugr app, installed on the 

wireless mobile 

device transmits 

digital media 

file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 255 of 434 PageID #:

1524
Exhibit 4 to the Complaint.

256

media file to a 

media system 

over a 

communicati

on network

having a 

security 

measure 

comprising:

user's smartphone (“media system”), using a Bluetooth network (“communication network”). The mySugr app, initially 

require users to input a PIN (“security measure”) which is necessary during the initial pairing process with the AccuChek Guide, and thereafter, the devices automatically exchange data without requiring users to re-enter the PIN.

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 256 of 434 PageID #:

1525
Exhibit 4 to the Complaint.

257

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 257 of 434 PageID #:

1526
Exhibit 4 to the Complaint.

258

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 258 of 434 PageID #:

1527
Exhibit 4 to the Complaint.

259

Source: https://www.mysugr.com/en-us/

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 259 of 434 PageID #:

1528
Exhibit 4 to the Complaint.

260

Source: https://www.accu-chek.com/products/mysugr (annotated)

wireless mobile device

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 260 of 434 PageID #:

1529
Exhibit 4 to the Complaint.

261

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 261 of 434 PageID #:

1530
Exhibit 4 to the Complaint.

262

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 262 of 434 PageID #:

1531
Exhibit 4 to the Complaint.

263

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 263 of 434 PageID #:

1532
Exhibit 4 to the Complaint.

264

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 264 of 434 PageID #:

1533
Exhibit 4 to the Complaint.

265

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 265 of 434 PageID #:

1534
Exhibit 4 to the Complaint.

266

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[32.1] the 

media system 

disposed in 

an accessible 

relation to at

least one 

interactive 

Company makes, uses, sells and/or offers to sell 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.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 266 of 434 PageID #:

1535
Exhibit 4 to the Complaint.

267

computer 

network that 

has a wireless 

range 

structured to 

permit 

authorized 

access to said

at least one 

interactive 

computer 

network,

For example, the mySugr app, installed on the user's smartphone ("media system") receives the blood sugar levels to, 

from the Accu-Chek Guide using Bluetooth network ("interactive computer network"). The Accu-Chek Guide and the 

smartphone, on which the mySugr app is installed, are paired with each other using the Bluetooth network. Since, the 

smartphone communicates and receives data from the Accu-Chek Guide using Bluetooth, it is apparent for a person 

having ordinary skills in the art that, 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 at least one interactive computer 

network.

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2 (annotated)

media 

system

interactive 

computer 

network

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 267 of 434 PageID #:

1536
Exhibit 4 to the Complaint.

268

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09 (annotated)

interactive 

computer 

network

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 268 of 434 PageID #:

1537
Exhibit 4 to the Complaint.

269

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 269 of 434 PageID #:

1538
Exhibit 4 to the Complaint.

270

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 270 of 434 PageID #:

1539
Exhibit 4 to the Complaint.

271

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:17 (annotated)

media

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 271 of 434 PageID #:

1540
Exhibit 4 to the Complaint.

272

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 272 of 434 PageID #:

1541
Exhibit 4 to the Complaint.

273

Source: https://play.google.com/store/apps/details?id=com.mysugr.android.companion

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.

[32.2] the 

wireless 

mobile 

device within 

said wireless 

range,

wherein said 

wireless 

mobile 

device is 

detectable by 

said

media 

system,

Company makes, uses, sells and/or offers to sell 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, the Accu-Chek Guide (“wireless mobile device”) and the smartphone (“media system”), on which the 

mySugr app is installed, are paired with each other using the Bluetooth network (“interactive computer network”). This 

network facilitates the pairing of the smartphone and the Accu-Chek Guide when they are within Bluetooth range of 

each other. The mySugr app detects the list of Accu-Chek Guides which are in the Bluetooth range (“wireless mobile 

device is detectable by said media system”).

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 273 of 434 PageID #:

1542
Exhibit 4 to the Complaint.

274

Source: https://www.accu-chek.com/products/mysugr (annotated)

Source: https://www.accu-chek.com/products/meters/guide

wireless mobile device

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 274 of 434 PageID #:

1543
Exhibit 4 to the Complaint.

275

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 275 of 434 PageID #:

1544
Exhibit 4 to the Complaint.

276

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 276 of 434 PageID #:

1545
Exhibit 4 to the Complaint.

277

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 277 of 434 PageID #:

1546
Exhibit 4 to the Complaint.

278

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 278 of 434 PageID #:

1547
Exhibit 4 to the Complaint.

279

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 279 of 434 PageID #:

1548
Exhibit 4 to the Complaint.

280

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29 (annotated)

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 280 of 434 PageID #:

1549
Exhibit 4 to the Complaint.

281

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 281 of 434 PageID #:

1550
Exhibit 4 to the Complaint.

282

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[32.3] at least 

one digital 

media file 

initially 

disposed on 

the

Company makes, uses, sells and/or offers to sell 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 Accu-Chek Guide ("wireless mobile device") employs the Bluetooth network to pair with the mySugr 

app which is installed on the user's smartphone. The Accu-Chek Guide is within the Bluetooth range of the smartphone 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 282 of 434 PageID #:

1551
Exhibit 4 to the Complaint.

283

wireless 

mobile 

device, said 

media system 

being 

structured to 

detect said 

wireless 

mobile 

device 

disposed

within said 

wireless 

range,

where the mySugr app is installed. The smartphone, on which the mySugr app is installed, detects the Accu-Chek Guides 

which are within its Bluetooth range (“media system being structured to detect said wireless mobile device disposed 

within said wireless range”).

Source: https://www.accu-chek.com/products/mysugr (annotated)

wireless mobile 

device

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 283 of 434 PageID #:

1552
Exhibit 4 to the Complaint.

284

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 2 of 70 

(annotated)

Source: https://www.accu-chek.com/products/meters/guide

digital 

media file

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 284 of 434 PageID #:

1553
Exhibit 4 to the Complaint.

285

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70 

(annotated)

wireless 

mobile 

device

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 285 of 434 PageID #:

1554
Exhibit 4 to the Complaint.

286

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 286 of 434 PageID #:

1555
Exhibit 4 to the Complaint.

287

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:17 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 287 of 434 PageID #:

1556
Exhibit 4 to the Complaint.

288

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19 (annotated)

media 

system

wireless mobile 

device is detectable

by the media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 288 of 434 PageID #:

1557
Exhibit 4 to the Complaint.

289

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:25 (annotated)

media 

system

wireless mobile 

device is detectable

by the media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 289 of 434 PageID #:

1558
Exhibit 4 to the Complaint.

290

Source: https://www.accu-chek.com/support/products/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 Defendant.

[32.4] a 

communicati

on link 

structured to 

Company makes, uses, sells and/or offers to sell 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.

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

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 290 of 434 PageID #:

1559
Exhibit 4 to the Complaint.

291

dispose said 

media

system and 

said wireless 

mobile 

device in a 

communicative relation 

with one 

another via 

said at least 

one

interactive 

computer 

network,

For example, mySugr app installed on the user’s smartphone and Accu-Chek Guide establishes a connection through 

Bluetooth pairing. This process creates a Bluetooth channel (“communication link structured to dispose”) between AccuChek Guide meter and mySugr app for the transfer of the measured blood sugar levels (“a communicative relation with 

one another via said at least interactive computer network”).

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 291 of 434 PageID #:

1560
Exhibit 4 to the Complaint.

292

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 292 of 434 PageID #:

1561
Exhibit 4 to the Complaint.

293

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 293 of 434 PageID #:

1562
Exhibit 4 to the Complaint.

294

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 294 of 434 PageID #:

1563
Exhibit 4 to the Complaint.

295

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17 (annotated)

media 

system

wireless 

mobile 

device

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 295 of 434 PageID #:

1564
Exhibit 4 to the Complaint.

296

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 296 of 434 PageID #:

1565
Exhibit 4 to the Complaint.

297

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 297 of 434 PageID #:

1566
Exhibit 4 to the Complaint.

298

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 298 of 434 PageID #:

1567
Exhibit 4 to the Complaint.

299

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[32.5] said 

communicati

on link being 

initiated by 

said media

system,

Company makes, uses, sells and/or offers to sell 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, the mySugr app, installed on the smartphone, initiates Bluetooth pairing to establish the communication 

channel with the Accu-Chek Guide.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 299 of 434 PageID #:

1568
Exhibit 4 to the Complaint.

300

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 300 of 434 PageID #:

1569
Exhibit 4 to the Complaint.

301

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 301 of 434 PageID #:

1570
Exhibit 4 to the Complaint.

302

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 302 of 434 PageID #:

1571
Exhibit 4 to the Complaint.

303

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 303 of 434 PageID #:

1572
Exhibit 4 to the Complaint.

304

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 304 of 434 PageID #:

1573
Exhibit 4 to the Complaint.

305

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 305 of 434 PageID #:

1574
Exhibit 4 to the Complaint.

306

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[32.6] said 

wireless 

mobile 

device and 

media system 

being 

structured to 

Company makes, uses, sells and/or offers to sell 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 establishing a Bluetooth channel (“communication link”) between the mySugr app installed on the 

user’s smartphone and the Accu-Chek Guide, the Accu-Chek Guide (“wireless mobile device") sends (“structured to 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 306 of 434 PageID #:

1575
Exhibit 4 to the Complaint.

307

transmit said 

at least one 

digital media 

file

therebetween 

via said 

communicati

on link, and

transmit”) the measured blood sugar levels (“at least one digital media file”) to the mySugr app installed on the user’s 

smartphone (“media system”).

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 307 of 434 PageID #:

1576
Exhibit 4 to the Complaint.

308

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 308 of 434 PageID #:

1577
Exhibit 4 to the Complaint.

309

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40 (annotated)

wireless mobile 

device transmits 

digital media file 

to media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 309 of 434 PageID #:

1578
Exhibit 4 to the Complaint.

310

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43 (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.

[32.7] said 

communicati

on link is 

structured to 

bypass the 

security 

measure of 

Company makes, uses, sells and/or offers to sell 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.

wireless mobile 

device transmits 

digital media file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 310 of 434 PageID #:

1579
Exhibit 4 to the Complaint.

311

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. 

For example, the Accu-Chek Guide meter and the mySugr app do not require users to input a PIN (“security 

measure”) every time they communicate. Instead, the PIN input is necessary during the initial pairing process, and 

thereafter, the devices automatically exchange data without requiring users to re-enter the PIN (“security measure of 

the media system”). The Accu-Chek Guide meter utilizes that communication channel exclusively for transmitting 

the measured blood sugar levels to the mySugr app (“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”). The mySugr app displays the received the measured blood sugar levels. Therefore, upon information 

and belief, the Bluetooth channel created between Accu-Chek Guide meter and mySugr app bypass the security 

measure of the media system.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 311 of 434 PageID #:

1580
Exhibit 4 to the Complaint.

312

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 312 of 434 PageID #:

1581
Exhibit 4 to the Complaint.

313

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 313 of 434 PageID #:

1582
Exhibit 4 to the Complaint.

314

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 314 of 434 PageID #:

1583
Exhibit 4 to the Complaint.

315

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 315 of 434 PageID #:

1584
Exhibit 4 to the Complaint.

316

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 316 of 434 PageID #:

1585
Exhibit 4 to the Complaint.

317

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 317 of 434 PageID #:

1586
Exhibit 4 to the Complaint.

318

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 318 of 434 PageID #:

1587
Exhibit 4 to the Complaint.

319

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

display 

digital 

media file 

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 319 of 434 PageID #:

1588
Exhibit 4 to the Complaint.

320

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 the production of such source code by Company.

[34] The 

wireless 

mobile 

device of 

claim 32, 

wherein the 

transmission 

of the at least 

one digital 

media file 

from the 

wireless 

mobile 

device to the 

media system 

completely 

bypasses the 

security 

measure.

Company makes, uses, sells and/or offers to sell the transmission of the at least one digital media file from the wireless 

mobile device to the media system completely bypasses the security measure.

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

For example, the Accu-Chek Guide meter and the mySugr app do not require users to input a PIN (“security measure”) 

every time they communicate. Instead, the PIN input is necessary during the initial pairing process, and thereafter, the 

devices automatically exchange data without requiring users to re-enter the PIN (“bypasses the security measure”). 

Therefore, upon information and belief, the Bluetooth channel created between Accu-Chek Guide meter and mySugr app 

completely bypass the security measure.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 320 of 434 PageID #:

1589
Exhibit 4 to the Complaint.

321

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 321 of 434 PageID #:

1590
Exhibit 4 to the Complaint.

322

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 322 of 434 PageID #:

1591
Exhibit 4 to the Complaint.

323

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 323 of 434 PageID #:

1592
Exhibit 4 to the Complaint.

324

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 324 of 434 PageID #:

1593
Exhibit 4 to the Complaint.

325

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 325 of 434 PageID #:

1594
Exhibit 4 to the Complaint.

326

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 326 of 434 PageID #:

1595
Exhibit 4 to the Complaint.

327

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 327 of 434 PageID #:

1596
Exhibit 4 to the Complaint.

328

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

digital 

media file 

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 328 of 434 PageID #:

1597
Exhibit 4 to the Complaint.

329

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.

[37] The 

device of 

claim 32, 

wherein the 

communicati

on

link is at least 

one of a peerto-peer 

connection, 

bluetooth

connection, 

and a WiFi 

connection.

Company makes, uses, sells and/or offers to sell 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 mySugr app installed in the user’s smartphone detects the Accu-Chek Guide meter through Bluetooth 

and establishes a connection (“communication link”).

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 329 of 434 PageID #:

1598
Exhibit 4 to the Complaint.

330

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 330 of 434 PageID #:

1599
Exhibit 4 to the Complaint.

331

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2 (annotated)

bluetooth 

connection

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 331 of 434 PageID #:

1600
Exhibit 4 to the Complaint.

332

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07

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.

[39] The 

device of 

claim 32, 

wherein the 

device is 

configured to 

present the at 

least one 

Company makes, uses, sells and/or offers to sell the device is configured to present 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 Accu-Chek Guide meter displays (“present”) the measured blood sugar levels (“digital-media file”).

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 332 of 434 PageID #:

1601
Exhibit 4 to the Complaint.

333

digital-media 

file on a 

display.

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

Source: https://www.accu-chek.com/products/meters/guide

show digitalmedia file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 333 of 434 PageID #:

1602
Exhibit 4 to the Complaint.

334

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 2 of 70

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.

[40] The 

device of 

claim 32, 

wherein the at 

least one 

digital media 

file is 

provided by 

the wireless 

mobile 

device.

Company makes, uses, sells and/or offers to sell 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 Accu-Chek Guide (“wireless mobile device") transmits the measured blood sugar levels (“at least one 

digital media file”) to the mySugr app installed on the user’s smartphone.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 334 of 434 PageID #:

1603
Exhibit 4 to the Complaint.

335

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 335 of 434 PageID #:

1604
Exhibit 4 to the Complaint.

336

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 336 of 434 PageID #:

1605
Exhibit 4 to the Complaint.

337

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40 (annotated)

wireless mobile 

device transmits 

digital media 

file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 337 of 434 PageID #:

1606
Exhibit 4 to the Complaint.

338

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43 (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.

[42.P] A 

transfer 

system from 

transferring a 

media file 

over a

Roche Diagnostics Corporation (“Company”) makes, uses, sells, and/or offers to sell a transfer system from transferring 

a media file over a communication network, comprising a media system; and a wireless mobile device.

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

wireless mobile 

device transmits 

digital media 

file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 338 of 434 PageID #:

1607
Exhibit 4 to the Complaint.

339

communicati

on network, 

comprising a 

media 

system; and a

wireless 

mobile 

device, 

wherein the 

media system 

includes:

For example, Company provides mySugr app (“media system”) to receive measured blood sugar levels from a AccuChek Guide meter (“wireless mobile device”). The mySugr app, installed on the user's smartphone, receive the measured 

blood sugar levels from the Accu-Chek Guide, using a Bluetooth network (“communication network”).

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 339 of 434 PageID #:

1608
Exhibit 4 to the Complaint.

340

Source: https://www.accu-chek.com/products/mysugr (annotated)

Source: https://www.mysugr.com/en-us/

wireless mobile device

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 340 of 434 PageID #:

1609
Exhibit 4 to the Complaint.

341

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 341 of 434 PageID #:

1610
Exhibit 4 to the Complaint.

342

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 342 of 434 PageID #:

1611
Exhibit 4 to the Complaint.

343

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 343 of 434 PageID #:

1612
Exhibit 4 to the Complaint.

344

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 344 of 434 PageID #:

1613
Exhibit 4 to the Complaint.

345

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 345 of 434 PageID #:

1614
Exhibit 4 to the Complaint.

346

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 346 of 434 PageID #:

1615
Exhibit 4 to the Complaint.

347

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 347 of 434 PageID #:

1616
Exhibit 4 to the Complaint.

348

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 348 of 434 PageID #:

1617
Exhibit 4 to the Complaint.

349

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[42.1] a 

wireless 

receiver,

Company makes, uses, sells and/or offers to sell a wireless receiver.

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

For example, the mySugr app, installed on the user's smartphone, includes a Bluetooth receiver (“wireless receiver”) for 

receiving data from the Accu-Chek Guide.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 349 of 434 PageID #:

1618
Exhibit 4 to the Complaint.

350

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 350 of 434 PageID #:

1619
Exhibit 4 to the Complaint.

351

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 351 of 434 PageID #:

1620
Exhibit 4 to the Complaint.

352

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07

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.

[42.2] a 

security 

measure, and

Company makes, uses, sells and/or offers to sell a security measure.

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

For example, the mySugr app, installed on the user’s smartphone, initially require users to input a PIN (“security 

measure”) which is necessary during the initial pairing process with the Accu-Chek Guide.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 352 of 434 PageID #:

1621
Exhibit 4 to the Complaint.

353

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 353 of 434 PageID #:

1622
Exhibit 4 to the Complaint.

354

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 354 of 434 PageID #:

1623
Exhibit 4 to the Complaint.

355

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 355 of 434 PageID #:

1624
Exhibit 4 to the Complaint.

356

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 356 of 434 PageID #:

1625
Exhibit 4 to the Complaint.

357

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 357 of 434 PageID #:

1626
Exhibit 4 to the Complaint.

358

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

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.

[42.3] a 

processor 

configured to

Company makes, uses, sells and/or offers a processor configured.

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

For example, the mySugr app, installed on the user's smartphone, includes a processor for receiving data from the AccuChek Guide.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 358 of 434 PageID #:

1627
Exhibit 4 to the Complaint.

359

Source: https://www.accu-chek.com/products/meters/guide

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 359 of 434 PageID #:

1628
Exhibit 4 to the Complaint.

360

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.

[42.4] 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 makes, uses, sells and/or offers to sell the 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, the mySugr app, installed on the user's smartphone ("media system") receives the blood sugar levels to, 

from the Accu-Chek Guide using Bluetooth network ("interactive computer network"). The Accu-Chek Guide and the 

smartphone, on which the mySugr app is installed, are paired with each other using the Bluetooth network. Since, the 

smartphone communicates and receives data from the Accu-Chek Guide using Bluetooth, it is apparent for a person 

having ordinary skills in the art that, 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 at least one interactive computer 

network

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 360 of 434 PageID #:

1629
Exhibit 4 to the Complaint.

361

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2 (annotated)

media 

system

interactive 

computer 

network

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 361 of 434 PageID #:

1630
Exhibit 4 to the Complaint.

362

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09 (annotated)

interactive 

computer 

network

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 362 of 434 PageID #:

1631
Exhibit 4 to the Complaint.

363

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 363 of 434 PageID #:

1632
Exhibit 4 to the Complaint.

364

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 364 of 434 PageID #:

1633
Exhibit 4 to the Complaint.

365

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:17 (annotated)

media

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 365 of 434 PageID #:

1634
Exhibit 4 to the Complaint.

366

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 366 of 434 PageID #:

1635
Exhibit 4 to the Complaint.

367

Source: https://play.google.com/store/apps/details?id=com.mysugr.android.companion

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.

[42.5] the 

wireless 

mobile 

device within 

said wireless 

range, 

wherein said 

wireless 

mobile 

device is 

detectable by 

said

media 

system,

Company makes, uses, sells and/or offers to sell 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, the Accu-Chek Guide (“wireless mobile device”) and the smartphone (“media system”), on which the 

mySugr app is installed, are paired with each other using the Bluetooth network (“interactive computer network”). This 

network facilitates the pairing of the smartphone and the Accu-Chek Guide when they are within Bluetooth range of 

each other. The mySugr app detects the Accu-Chek Guide which is in the Bluetooth range (“wireless mobile device is 

detectable by said media system”).

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 367 of 434 PageID #:

1636
Exhibit 4 to the Complaint.

368

Source: https://www.accu-chek.com/products/mysugr (annotated)

Source: https://www.accu-chek.com/products/meters/guide

wireless mobile device

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 368 of 434 PageID #:

1637
Exhibit 4 to the Complaint.

369

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 369 of 434 PageID #:

1638
Exhibit 4 to the Complaint.

370

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 370 of 434 PageID #:

1639
Exhibit 4 to the Complaint.

371

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 371 of 434 PageID #:

1640
Exhibit 4 to the Complaint.

372

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 372 of 434 PageID #:

1641
Exhibit 4 to the Complaint.

373

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 373 of 434 PageID #:

1642
Exhibit 4 to the Complaint.

374

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 374 of 434 PageID #:

1643
Exhibit 4 to the Complaint.

375

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 375 of 434 PageID #:

1644
Exhibit 4 to the Complaint.

376

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[42.6] at least 

one digital 

media file 

initially 

disposed on 

the wireless 

mobile 

Company makes, uses, sells and/or offers to sell 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 Accu-Chek Guide ("wireless mobile device") employs the Bluetooth network to pair with the mySugr 

app which is installed on the user's smartphone. The Accu-Chek Guide is within the Bluetooth range of the smartphone 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 376 of 434 PageID #:

1645
Exhibit 4 to the Complaint.

377

device, said 

media system 

being 

structured to 

detect said 

wireless 

mobile 

device 

disposed 

within said 

wireless 

range,

where the mySugr app is installed. The smartphone, on which the mySugr app is installed, detects the Accu-Chek Guides 

which are within its Bluetooth range (“media system being structured to detect said wireless mobile device disposed 

within said wireless range”).

Source: https://www.accu-chek.com/products/mysugr (annotated)

wireless mobile 

device

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 377 of 434 PageID #:

1646
Exhibit 4 to the Complaint.

378

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70 

(annotated)

wireless 

mobile 

device

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 378 of 434 PageID #:

1647
Exhibit 4 to the Complaint.

379

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 379 of 434 PageID #:

1648
Exhibit 4 to the Complaint.

380

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 380 of 434 PageID #:

1649
Exhibit 4 to the Complaint.

381

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:17 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 381 of 434 PageID #:

1650
Exhibit 4 to the Complaint.

382

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19 (annotated)

media 

system

wireless mobile 

device is detectable

by the media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 382 of 434 PageID #:

1651
Exhibit 4 to the Complaint.

383

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:25 (annotated)

media 

system

wireless mobile 

device is detectable

by the media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 383 of 434 PageID #:

1652
Exhibit 4 to the Complaint.

384

Source: https://www.accu-chek.com/support/products/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 Defendant.

[42.7] a 

communicati

on link 

structured to 

Company makes, uses, sells and/or offers to sell 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.

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

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 384 of 434 PageID #:

1653
Exhibit 4 to the Complaint.

385

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,

For example, mySugr app installed on the user’s smartphone and Accu-Chek Guide establishes a connection through 

Bluetooth pairing. This process creates a Bluetooth channel (“communication link structured to dispose”) between AccuChek Guide meter and mySugr app for the transfer of the measured blood sugar levels (“a communicative relation with 

one another via said at least interactive computer network”).

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 385 of 434 PageID #:

1654
Exhibit 4 to the Complaint.

386

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 386 of 434 PageID #:

1655
Exhibit 4 to the Complaint.

387

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 387 of 434 PageID #:

1656
Exhibit 4 to the Complaint.

388

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 388 of 434 PageID #:

1657
Exhibit 4 to the Complaint.

389

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17 (annotated)

media 

system

wireless 

mobile 

device

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 389 of 434 PageID #:

1658
Exhibit 4 to the Complaint.

390

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 390 of 434 PageID #:

1659
Exhibit 4 to the Complaint.

391

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 391 of 434 PageID #:

1660
Exhibit 4 to the Complaint.

392

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 392 of 434 PageID #:

1661
Exhibit 4 to the Complaint.

393

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[42.8] said 

communicati

on link being 

initiated by 

said media

system,

Company makes, uses, sells and/or offers to sell 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, the mySugr app, installed on the smartphone, initiates Bluetooth pairing to establish the communication 

channel with the Accu-Chek Guide.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 393 of 434 PageID #:

1662
Exhibit 4 to the Complaint.

394

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 394 of 434 PageID #:

1663
Exhibit 4 to the Complaint.

395

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09 (annotated)

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 395 of 434 PageID #:

1664
Exhibit 4 to the Complaint.

396

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 396 of 434 PageID #:

1665
Exhibit 4 to the Complaint.

397

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 397 of 434 PageID #:

1666
Exhibit 4 to the Complaint.

398

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 398 of 434 PageID #:

1667
Exhibit 4 to the Complaint.

399

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 399 of 434 PageID #:

1668
Exhibit 4 to the Complaint.

400

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43

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 Defendant.

[42.9] said 

wireless 

mobile 

device and 

media system 

being 

structured to 

Company makes, uses, sells and/or offers to sell 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 establishing a Bluetooth channel (“communication link”) between the mySugr app installed on the 

user’s smartphone and the Accu-Chek Guide, the Accu-Chek Guide (“wireless mobile device") sends (“structured to 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 400 of 434 PageID #:

1669
Exhibit 4 to the Complaint.

401

transmit said 

at least one 

digital media 

file 

therebetween 

via said 

communicati

on link, and

transmit”) the measured blood sugar levels (“at least one digital media file”) to the mySugr app installed on the user’s 

smartphone (“media system”).

Source: https://www.accu-chek.com/products/meters/guide

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 401 of 434 PageID #:

1670
Exhibit 4 to the Complaint.

402

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 402 of 434 PageID #:

1671
Exhibit 4 to the Complaint.

403

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40 (annotated)

wireless mobile 

device transmits 

digital media file 

to media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 403 of 434 PageID #:

1672
Exhibit 4 to the Complaint.

404

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43 (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.

[42.10] said 

communicati

on link is 

structured to 

bypass the 

security 

measure of 

Company makes, uses, sells and/or offers to sell 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.

wireless mobile 

device transmits 

digital media file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 404 of 434 PageID #:

1673
Exhibit 4 to the Complaint.

405

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.

For example, the Accu-Chek Guide meter and the mySugr app do not require users to input a PIN (“security measure”) 

every time they communicate. Instead, the PIN input is necessary during the initial pairing process, and thereafter, the 

devices automatically exchange data without requiring users to re-enter the PIN (“security measure of the media 

system”). The Accu-Chek Guide meter uses that communication channel only for transmitting the measured blood sugar 

levels to the mySugr app (“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”). The mySugr 

app displays the received the measured blood sugar levels. Therefore, upon information and belief, the Bluetooth channel 

created between Accu-Chek Guide meter and mySugr app bypass the security measure of the media system.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 405 of 434 PageID #:

1674
Exhibit 4 to the Complaint.

406

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 406 of 434 PageID #:

1675
Exhibit 4 to the Complaint.

407

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 407 of 434 PageID #:

1676
Exhibit 4 to the Complaint.

408

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 408 of 434 PageID #:

1677
Exhibit 4 to the Complaint.

409

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 409 of 434 PageID #:

1678
Exhibit 4 to the Complaint.

410

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 410 of 434 PageID #:

1679
Exhibit 4 to the Complaint.

411

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 411 of 434 PageID #:

1680
Exhibit 4 to the Complaint.

412

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 412 of 434 PageID #:

1681
Exhibit 4 to the Complaint.

413

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

display 

digital 

media file 

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 413 of 434 PageID #:

1682
Exhibit 4 to the Complaint.

414

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 the production of such source code by Company.

[44] The 

transfer 

system of 

claim 42, 

wherein the 

transmission 

of the at least 

one digital 

media file 

from the 

wireless

mobile 

device to the 

media system 

completely 

bypasses the

security 

measure. 

Company makes, uses, sells and/or offers to sell the transmission of the at least one digital media file from the wireless

mobile device to the media system completely bypasses the security measure.

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

For example, the Accu-Chek Guide meter and the mySugr app do not require users to input a PIN (“security 

measure”) every time they communicate. Instead, the PIN input is necessary during the initial pairing process, and 

thereafter, the devices automatically exchange data without requiring users to re-enter the PIN (“bypasses the security 

measure”). Therefore, upon information and belief, the Bluetooth channel created between Accu-Chek Guide meter 

and mySugr app completely bypasses the security measure.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 414 of 434 PageID #:

1683
Exhibit 4 to the Complaint.

415

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 415 of 434 PageID #:

1684
Exhibit 4 to the Complaint.

416

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 416 of 434 PageID #:

1685
Exhibit 4 to the Complaint.

417

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07, 0:09

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 417 of 434 PageID #:

1686
Exhibit 4 to the Complaint.

418

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:12, 0:17

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 418 of 434 PageID #:

1687
Exhibit 4 to the Complaint.

419

 

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:19, 0:25

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 419 of 434 PageID #:

1688
Exhibit 4 to the Complaint.

420

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:26, 0:29

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 420 of 434 PageID #:

1689
Exhibit 4 to the Complaint.

421

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 421 of 434 PageID #:

1690
Exhibit 4 to the Complaint.

422

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

digital 

media file 

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 422 of 434 PageID #:

1691
Exhibit 4 to the Complaint.

423

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.

[47] The 

system of 

claim 42, 

wherein the 

communicati

on

link is at least 

one of a peerto-peer 

connection, 

bluetooth

connection, 

and a WiFi 

connection.

Company makes, uses, sells and/or offers to sell 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 mySugr app installed in the user’s smartphone detects the Accu-Chek Guide meter through Bluetooth 

and establishes a connection (“communication link”) for receiving the measured blood sugar level.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 423 of 434 PageID #:

1692
Exhibit 4 to the Complaint.

424

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 424 of 434 PageID #:

1693
Exhibit 4 to the Complaint.

425

Source: https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download, Page 1 of 2 (annotated)

bluetooth 

connection

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 425 of 434 PageID #:

1694
Exhibit 4 to the Complaint.

426

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:07

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.

[49] The 

system of 

claim 42, 

wherein the 

system is 

configured to 

present the at 

Company makes, uses, sells and/or offers to sell the system is configured to present 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 mySugr app installed on the user’s smartphone (“media system”), the smartphone includes a display to 

show (“present”) the measured blood sugar levels (“digital media file”).

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 426 of 434 PageID #:

1695
Exhibit 4 to the Complaint.

427

least one 

digital media 

file on a 

display.

Source: https://www.accu-chek.com/products/meters/guide

 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 427 of 434 PageID #:

1696
Exhibit 4 to the Complaint.

428

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40

Source: https://www.mysugr.com/en-us/diabetes-app/

Source: https://www.mysugr.com/en-us/diabetes-app/ (annotated)

display 

digital 

media file 

media 

system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 428 of 434 PageID #:

1697
Exhibit 4 to the Complaint.

429

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.

[50] The 

system of 

claim 42, 

wherein the at 

least one 

digital media 

file is 

provided by 

the wireless 

mobile 

device.

Company makes, uses, sells and/or offers to sell 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 Accu-Chek Guide (“wireless mobile device") sends the measured blood sugar levels (“at least one 

digital media file”) to the mySugr app installed on the user’s smartphone.

Source: https://www.accu-chek.com/products/meters/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 429 of 434 PageID #:

1698
Exhibit 4 to the Complaint.

430

Source: https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, Page 63 of 70

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 430 of 434 PageID #:

1699
Exhibit 4 to the Complaint.

431

Source: https://www.accu-chek.com/support/products/guide

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 431 of 434 PageID #:

1700
Exhibit 4 to the Complaint.

432

 Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:38, 0:40 (annotated)

wireless mobile 

device transmits 

media file to 

media system

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 432 of 434 PageID #:

1701
Exhibit 4 to the Complaint.

433

Source: https://www.youtube-nocookie.com/embed/EByD_P5-j0g, at 0:43 (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.

wireless mobile 

device transmits 

media file 

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 433 of 434 PageID #:

1702
Exhibit 4 to the Complaint.

434

2. List of References

1. https://www.accu-chek.com/products/meters/guide, last accessed on November 16, 2023. 

2. https://www.youtube-nocookie.com/embed/EByD_P5-j0g, last accessed on November 16, 2023.

3. https://www.accu-chek.com/products/mysugr, last accessed on November 16, 2023.

4. https://www.accu-chek.com/support/products/guide, last accessed on November 16, 2023.

5. https://www.accu-chek.com/document/accu-chek-guide-quick-start-guide-2/download , last accessed on November 16, 2023.

6. https://www.accu-chek.com/document/accu-chek-guide-meter-manual-english/download, last accessed on November 16, 2023.

7. https://www.mysugr.com/en-us/diabetes-app/, last accessed on November 16, 2023.

Case 2:23-cv-00585-JRG-RSP Document 38-4 Filed 07/12/24 Page 434 of 434 PageID #:

1703