Oracle America, Inc. v. Google Inc.

Filing 1110

Statement Oracle's markup of the Court's Background Section by Oracle America, Inc.. (Jacobs, Michael) (Filed on 5/9/2012)

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MORRISON & FOERSTER LLP
MICHAEL A. JACOBS (Bar No. 111664)
[e-mail]
KENNETH A. KUWAYTI (Bar No. 145384)
[e-mail]
MARC DAVID PETERS (Bar No. 211725)
[e-mail]
DANIEL P. MUINO (Bar No. 209624)
[e-mail]
755 Page Mill Road, Palo Alto, CA 94304-1018
Telephone: [phone] / Facsimile: [phone]
BOIES, SCHILLER & FLEXNER LLP
DAVID BOIES (Admitted Pro Hac Vice)
[e-mail]
333 Main Street, Armonk, NY 10504
Telephone: [phone] / Facsimile: [phone]
STEVEN C. HOLTZMAN (Bar No. 144177)
[e-mail]
1999 Harrison St., Suite 900, Oakland, CA 94612
Telephone: [phone] / Facsimile: [phone]
ORACLE CORPORATION
DORIAN DALEY (Bar No. 129049)
[e-mail]
DEBORAH K. MILLER (Bar No. 95527)
[e-mail]
MATTHEW M. SARBORARIA (Bar No. 211600)
[e-mail]
500 Oracle Parkway, Redwood City, CA 94065
Telephone: [phone] / Facsimile: [phone]
Attorneys for Plaintiff
ORACLE AMERICA, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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ORACLE AMERICA, INC.

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Plaintiff,

ORACLE’S MARKUP OF COURT’S
BACKGROUND SECTION

Defendant.

Dept.: Courtroom 8, 19th Floor
Judge: Honorable William H. Alsup

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v.

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Case No. CV 10-03561 WHA

GOOGLE INC.

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ORACLE’S MARKUP OF COURT’S BACKGROUND SECTION
CASE NO. CV 10-03561 WHA
pa-1528046

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Oracle respectfully submits this markup of the Court’s proposed background section, after

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having consulted with its technical staff. Two versions are attached for the Court’s convenience:

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both redline and clear text.

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The Court asked about the difference between statements and expressions. This short
description explains the difference between the two:

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An expression is a (typically) small piece of program text that instructs the computer to
calculate a single value (e.g., 1 + 3, 2 * pi * r, Math.max(a, b)). A statement can be just an

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expression, or it can be a control structure that contains one or more expressions or other

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statements. For example, an “if” statement expresses a conditional action:

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if (x > y)
System.out.println("greater");

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This statement includes an expression (x > y) and another statement

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(System.out.println("greater")). It instructs the computer to compare the two variables x and y

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and then print the word “greater” if x is indeed greater than y. Statements are run in the sequence

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written. Statements are what tell the computer to do work.

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ORACLE’S MARKUP OF COURT’S BACKGROUND SECTION
CASE NO. CV 10-03561 WHA
pa-1528046

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Java syntax includes separators (e.g., {, }, ;), operators (e.g., +, -, *, /, <, >), literal values

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(e.g., 123, ‘x’, “Foo”), and keywords (e.g., if, then, else, while, return). These carry precise

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predefined meanings. Java syntax also includes identifiers (e.g., x, String, java.lang.Object),

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which are used by developers to name specific values, fields, methods, and classes as described

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below. These are used to form statements, each statement being a single command executed by

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the Java interpreterdirective to take some action. Statements are run in the sequence written.

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Statements are what tell the computer to do work.

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A declaration is a type of statement. It instructs the computer to recognize a name as a
variable or as a method or as a class and to reserve memory accordingly. The word “declare” is

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not used to precede a declaration. A declaration is a line (or more) of code that, for example,

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declares the variable pi to be 3.141592 or declares a class or method in its fully qualified form.

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The next higher level of syntax is the method. A method is a type of declaration. A

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method is a sequence of statements. Once defined, it can be invoked or “called” on” elsewhere in

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the program. A method is like a subroutine. When a method is called upon, arguments are

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usually passed over to the method. These are the inputs. The output(s) from the method are

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known as the return values(s). An example is a method that receives two numbers as inputs and

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returns the greater of the two as the output. Another example is a method that receives an angle

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expressed in degrees and returns the cosine of that angle. Methods can be much more

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complicated. A method, for example, could receive the month and day and return the Earth’s

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declination to the sun for that month and day.

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A method declaration consists of the method header and the method body. (At the trial,

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however, witnesses sometimes referred to the method header as the method declaration or the

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method signature, even though that was not technically correct, and so the Court will use the three

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synonymously to match the evidencesignature of the method (discussed below) as the

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declaration.) A method declaration defines the entire routine to be followed when the method is

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called. A method call is a line of other code somewhere else in the program that calls up (or

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invokes) the method and specifies the arguments to be passed to the method for crunching. The

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return is returned for use as the program marches on after the method call.
ORACLE’S MARKUP OF COURT’S BACKGROUND SECTION
CASE NO. CV 10-03561 WHA
pa-1528046

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A method header, also called a method signature, consists of the name of the method and

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the number and types of formal parameters to the method, if any. More specifically, the a method

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signature header will contain the name of the method; the number, order, type and name of the

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parameters used by the method; the type of value returned by the method; the checked exceptions

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that the method can throw; and various method modifiers that provide additional information

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about the method.

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A method body is a block of code that implements the method. If a method is declared to

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have a return type, then the method body must have a return statement and the statement must be

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followed by include the expression to be returned when that line of code is reached. During trial,

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many witnesses referred to the method body as the “implementation.” It is the method body that

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does the heavy lifting, namely the actual work of taking the inputs, crunching them, and returning

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an answer. (This part was not copied from Java by Google.)

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A class is another type of declaration After a method, the next higher level of syntax is the

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class. A class defines may include a collection of fields that hold data values and methods that

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operate on those values. Classes are a fundamental structural element in the Java programming

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language. All Java programs are written as aone or more classes. All Java statements appear

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within methods and all methods are implemented within classes. To write a Java program, it

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must be placed in a class.

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A class definition declaration includes the name of the class and other modifiers

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functional important information that define the class. The body of the class includes fields and

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methods, constructors and initializers. Classes can have subclasses that inherit the functionality

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of the class itself while adding specialized functionality for the subclass. When a new subclass is

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defined, the definition declaration uses the word “extends” to alert the computer compiler that the

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fields and methods of the patent parent class are inherited extended automatically into the new

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subclass so that only the additional fields or methods new and specialized codes for the subclass

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need be stateddeclared.

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An interface is a special type of class, which is used to relate similar classes more flexibly
than allowed by the strict subclass/superclass hierarchy. An interface contains method
ORACLE’S MARKUP OF COURT’S BACKGROUND SECTION
CASE NO. CV 10-03561 WHA
pa-1528046

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declarations, but the declarations do not have bodies. If a class is declared to “implement” an

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interface, then for each method in the interface the class must either declare that method or inherit

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it from a superclass; a class can implement more than one interface.

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Classes and interfaces can be grouped into packages in the same way we all group files
into folders on our computers.

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Here is a simple example that illustrates methods, classes and packages.

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Package java.lang;

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public class Math {

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public static int max (int x, int y) {

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if (x > y) return x ;

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else return y ;

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}

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{}

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A typical program would have more than one method in a class. All Java programs must

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have a at least one class. All programs, however, need not have packages, which are merely

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convenient ways to organize the classes.

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To invoke this method from a program, the following could be included in the program:

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int a= Math.max (2, 3);

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ORACLE’S MARKUP OF COURT’S BACKGROUND SECTION
CASE NO. CV 10-03561 WHA
pa-1528046

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Java syntax includes separators (e.g., {, }, ;), operators (e.g., +, -, *, /, <, >), literal values

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(e.g., 123, ‘x’, “Foo”), and keywords (e.g., if, then, else, while, return). These carry precise

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predefined meanings. Java syntax also includes identifiers (e.g., x, String, java.lang.Object),

4

which are used by developers to name specific values, fields, methods, and classes as described

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below. These are used to form statements, each statement being a single directive to take some

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action. Statements are run in the sequence written. Statements are what tell the computer to do

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work.

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A declaration instructs the computer to recognize a name as a variable or as a method or
as a class and to reserve memory accordingly. The word “declare” is not used to precede a

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declaration. A declaration is a line (or more) of code that, for example, declares the variable pi to

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be 3.141592 or declares a class or method.

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A method is a type of declaration. A method is a sequence of statements. Once defined, it

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can be invoked or “called on” elsewhere in the program. A method is like a subroutine. When a

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method is called upon, arguments are usually passed over to the method. These are the inputs.

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The output from the method are known as the return value. An example is a method that receives

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two numbers as inputs and returns the greater of the two as the output. Another example is a

17

method that receives an angle expressed in degrees and returns the cosine of that angle. Methods

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can be much more complicated. A method, for example, could receive the month and day and

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return the Earth’s declination to the sun for that month and day.

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A method declaration consists of the method header and the method body. (At the trial,

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however, witnesses sometimes referred to the method header as the method declaration or the

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method signature, even though that was not technically correct, and so the Court will use the three

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synonymously to match the evidence.) A method declaration defines the entire routine to be

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followed when the method is called. A method call is a line of other code somewhere else in the

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program that calls up (or invokes) the method and specifies the arguments to be passed to the

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method for crunching. The return is returned for use as the program marches on after the method

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call.

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ORACLE’S MARKUP OF COURT’S BACKGROUND SECTION
CASE NO. CV 10-03561 WHA
pa-1528046

5

1

A method signature consists of the name of the method and the number and types of

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formal parameters to the method, if any. More specifically, a method header will contain the

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name of the method; the number, order, type and name of the parameters used by the method; the

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type of value returned by the method; the checked exceptions that the method can throw; and

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various method modifiers that provide additional information about the method.

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A method body is a block of code that implements the method. If a method is declared to

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have a return type, then the method body must have a return statement and the statement must

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include the expression to be returned when that line of code is reached. During trial, many

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witnesses referred to the method body as the “implementation.” It is the method body that does

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the heavy lifting, namely the actual work of taking the inputs, crunching them, and returning an

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answer. (This part was not copied from Java by Google.)

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A class is another type of declaration . A class may include a collection of fields that hold

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data values and methods that operate on those values. Classes are a fundamental structural

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element in the Java programming language. All Java programs are written as one or more

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classes. Java statements appear within methods and all methods are implemented within classes.

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To write a Java program, it must be placed in a class.

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A class declaration includes the name of the class and other modifiers information that

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define the class. The body of the class includes fields and methods, constructors and initializers.

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Classes can have subclasses that inherit the functionality of the class itself while adding

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functionality for the subclass. When a new subclass is defined, the declaration uses the word

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“extends” to alert the compiler that the fields and methods of the parent class are inherited

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automatically into the new subclass so that only the additional fields or methods for the subclass

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need bedeclared.

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An interface is a special type of class, which is used to relate similar classes more flexibly

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than allowed by the strict subclass/superclass hierarchy. An interface contains method

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declarations, but the declarations do not have bodies. If a class is declared to “implement” an

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interface, then for each method in the interface the class must either declare that method or inherit

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ORACLE’S MARKUP OF COURT’S BACKGROUND SECTION
CASE NO. CV 10-03561 WHA
pa-1528046

6

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it from a superclass; a class can implement more than one interface.Classes and interfaces can be

2

grouped into packages in the same way we all group files into folders on our computers.

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Here is a simple example that illustrates methods, classes and packages.

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Package java.lang;

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public class Math {

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public static int max (int x, int y) {

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if (x > y) return x ;

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else return y ;

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}

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}

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A typical program would have more than one method in a class. All Java programs must

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have at least one class. All programs, however, need not have packages, which are merely

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convenient ways to organize the classes.

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To invoke this method from a program, the following could be included in the program:

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int a= Math.max (2, 3);

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Respectfully submitted,

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Dated: May 9, 2012

MORRISON & FOERSTER LLP
By: /s/ Michael A. Jacobs

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Attorneys for Plaintiff
ORACLE AMERICA, INC.

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ORACLE’S MARKUP OF COURT’S BACKGROUND SECTION
CASE NO. CV 10-03561 WHA
pa-1528046

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