Undeterred by challenges to the sufficiency of its pleading in May 2023 complaints filed separately against Alphabet (Google) and Deutsche Telekom (T-Mobile), SmartWatch Mobileconcepts LLC (SWM) has accused Verizon (Verizon Wireless) (6:23-cv-00731) of infringing the same patent by attaching to the new complaint a claim chart with the same level of detail. Both prior defendants accuse SWM of failing to identify several claim elements in its initial infringement allegations, including the recited “secured electronic system” to which the accused smartwatches “achiev[e] secured, short-range RF communication”. In opposition to these motions to dismiss, SWM states plainly that this “secured electronic system” is the smartphone to which the accused watches connect via Bluetooth.