Elan Microelectronics Corporation v. Apple, Inc.

Filing 104

Declaration of Nathan Greenblatt in Support of Apple's Responsive Claim Construction Brief re 103 filed by Apple, Inc. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J) (Powers, Matthew) (Filed on 6/2/2010) Modified on 6/4/2010 (bw, COURT STAFF).

EXHIBIT A

Case 5:06-cv-01839-PVT

Document 63-2

Filed 12/18/2006

Page 1 of 3

Case 5:06-cv-01839-PVT

Document 63-2

Filed 12/18/2006

Page 2 of 3

JOINT CLAIM CONSTRUCTION CHART
Claim Terms
1. "tap gesture" ('931/'591) 2. "X and Y position information" ('931/'591) 3. "initiating a first signal to the host indicating the occurrence of said gesture" ('591) 4. "terminating said first signal" ('591) 5. "sending a second signal to said host indicating said second gesture" ('591)

Synaptics Claim Construction Disclosure

Elantech Claim Construction Disclosure

"a quick tap of the finger on the pad, of short duration and involving little or no X or Y finger motion, that is presented to the host as a brief click of the mouse button" "information about the horizontal and vertical "two-dimensional location on a touch-sensor pad" positioning of an object on a touch sensor"

"initiating transmission of a first set of data to a computer, or other device that can take as input the output of a touch-sensor pad, that indicates that a tap gesture has occurred on the touchsensor pad" "terminating the previous signal" "sending a second set of data to a computer, or other device that can take as input the output of a touch-sensor pad, that indicates that a second tap gesture has occurred on the touch-sensor pad"

"outputting to the host a high state of a signal that has a low and a high state, and the high signal state represents that a double tap gesture will potentially occur on the touch-sensor pad" "changing the state of the signal from the high signal state to the low signal state" "changing the state of the signal from a low signal state to a high signal state for a predetermined period of time, and sending the high signal state to the host which interprets the termination of the first signal and the existence of a second high signal state as being a double tap gesture" This claim construction presumes that "said second gesture" should have read "said gesture" or "said double tap gesture." Absent such a presumption, no claim construction can be made because there is no antecedent basis for "said second gesture." "outputting to a host a high state of a signal that has a low and high state, and the high signal state represents that a drag gesture will potentially occur on the touch-sensor pad" "continuously outputting the high signal state"

6. "initiating a drag gesture signal to the host indicating the occurrence of a gesture" ('591) 7. "maintaining said drag gesture signal" ('591) 8. "repeatedly sending X and Y position information to said host for the duration of said second presence" ('591) 9. "initiating a signal to the host indicating the occurrence of said tap gesture" ('931) 10. "maintaining said signal for a predetermined period of time" ('931) 11. "detecting in which of at least one corner of the touch-sensor pad said tap gesture occurred" ('931)

"initiating transmission of a first set of data to a computer or other device that can take as input the output of a touch-sensor pad, that indicates that a gesture has occurred on the touch-sensor pad" "to continue, retain, or repeat the drag gesture signal" "after the second presence is detected, repeatedly sending information about the horizontal and vertical positioning of an object on a touch sensor to a computer, or other device that can take as input the output of a touch-sensor pad while the second presence continues" "initiating the transmission of a set of data to a computer, or other device that can take as input the output of a touch-sensor pad, that indicates that a tap gesture has occurred on the touchsensor pad" "to continue, retain, or repeat the signal for a period of time that was determined before"

"continuously sending the current two-dimensional location of the object on the touch-sensor pad to the host as long as the object continues to be in proximity to the touch-sensor pad"

"outputting to the host a high state of a signal that has a low and a high state, where the high signal state represents that a tap gesture occurred on the touch-sensor pad" "continuously outputting the high state of the signal only for a predetermined time period (i.e., changing the signal state from high to low at the end of the predetermined time period)" "after detecting the occurrence of the tap gesture, separately detecting in which of at least one corner of the touch-sensor pad the tap gesture occurred"

"detecting that a tap gesture has occurred in at least one corner, the identity of which is distinguished in some way from other corners of the touch-sensor pad"

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Case 5:06-cv-01839-PVT

Document 63-2

Filed 12/18/2006

Page 3 of 3

JOINT CLAIM CONSTRUCTION CHART
12. "data packet processor" ('052) 13. "incrementally move" ('411) 14. "operative coupling" ('352) 15(a) "scanning the touch sensor" 15(b) "means for scanning the touch sensor . . ." ('352) "hardware and/or program code, for example, software executed on a central processing unit, that examines data packets" "to move in increments" "software for processing data packets and sending messages"

movement defined by the second component of Equations 12 and 13 in the '411 patent, namely, S(Xcur ­Xcenter) and S(Ycur - Ycenter) "finger-induced electrical effect"

16. "scanning the touch sensor to . . . identify a first maxima in a signal corresponding to a first finger" ('352) 17. "scanning the touch sensor to . . . identify a minima following the first maxima" ('352t) 18. "scanning the touch sensor to . . . identify a second maxima in a signal corresponding to a second finger following said minima" ('352) 19(a) "providing an indication of the simultaneous presence of two fingers in response to identification of said first and second maxima" ('352) 19(b) "means for providing an indication of the simultaneous presence of two fingers in response to identification of said first and second maxima" ('352) pa-1117140

"sequentially measuring the traces in the touch "examining information associated with the touch sensor" sensor" 112 ¶6 Claimed Function "scanning the touch sensor to (a) identify a first maxima in a signal corresponding to a first finger, (b) identify a minima following the first maxima, and (c) identify a second maxima in a signal corresponding to a second finger following said minima," as those terms are defined below 112 ¶6 Corresponding Structures analog multiplexor 45, capacitance measuring circuit 70, analog to digital converter 80, microcontroller 60 "measuring the trace values of the touch sensor "identify a first peak value in a finger profile corresponding to a first finger and determining the obtained from scanning the touch sensor" point at which the measured values cease to increase and begin to decrease"

"measuring the trace values of the touch sensor following, in scan order, after the first maxima and determining the point at which the measured values cease to decrease and begin to increase" "measuring the trace values corresponding to a second finger following, in scan order, said minima and determining the point at which the measured values cease to decrease and begin to increase"

"identify the lowest value in the finger profile that occurs after the first peak value, and before another peak value is identified"

"after identifying the lowest value in the finger profile, identify a second peak value in the finger profile"

No further construction necessary since ordinary meaning is sufficient.

112 ¶6 Claimed Function "providing an indication of the simultaneous presence of two fingers in response to identification of said first and second maxima" 112 ¶6 Corresponding Structure 112 ¶6 Corresponding Structure None microcontroller 60

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