Elan Microelectronics Corporation v. Apple, Inc.

Filing 155

Declaration of Sonal N. Mehta in Support of 152 Memorandum in Opposition to Elan's Motion to Exclude Documents or, in the Alternative, for Costs filed byApple, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit A-1, Part 1 of 2, # 3 Exhibit A-1, Part 2 of 2, # 4 Exhibit A-2, # 5 Exhibit A-3, # 6 Exhibit B)(Related document(s) 152 ) (Lumish, Douglas) (Filed on 8/3/2010)

ATTACHMENT A-1

INFRINGEMENT CHART FOR U.S. PATENT NO. 5,764,218
Claim Language (5,764,218) 1. A method of operating a touchsensitive input device of a computer system comprising the steps of: Elan Smart-Pad1 Elan's Smart-Pad is a touch-sensitive input device. See, e.g., http://www.emc.com.tw/eng/ap02_01_04_01_tps.asp. Elan provides its Smart-Pad as part of at least the ASUS line of Eee computer systems, see, e.g., below screen shot of the Device Manager of a ASUS 1000HE computer.

See Exhibit 1
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The Elan Smart-Pad is incorporated into laptops sold into the United States, including for example, the ASUS Eee 1000x line of computers, which includes the ASUS Eee 1000, ASUS Eee 1000H, ASUS Eee 1000HD, ASUS Eee 1000HA, and ASUS Eee 1000HE computers. References herein are to the Elan Smart-Pad as included in the ASUS Eee 1000HE computer, which is believed to be exemplary of the ASUS Eee 1000x line.

Dockets.Justia.com

Claim Language (5,764,218) a) detecting contact intervals when a user contacts the touch-sensitive input device;

Elan Smart-Pad1 The Smart-Pad detects contact intervals when a user contacts the touch-sensitive input device to determine whether the user is invoking a gesture (and to determine the type of gesture).

http://www.emc.com.tw/eng/ap02_01_04_01_tps.asp (Smart-Pad gestures). See Exhibit 2

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Claim Language (5,764,218)

Elan Smart-Pad1 Gestures can be found in the control settings for the Smart-Pad:

See Exhibit 3 The drag and drop gesture, for example, is invoked by detecting contact intervals. See, e.g., "Description" in the Figure above ("tapping the pad twice"). b) detecting gap intervals between subsequent contact intervals; and The Smart-Pad detects gap intervals between subsequent contact intervals to determine whether the user is invoking a gesture (and to determine the type of gesture).

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Claim Language (5,764,218)

Elan Smart-Pad1

http://www.emc.com.tw/eng/ap02 01 04 01 tps.asp (Smart-Pad gestures). See Exhibit 2

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Claim Language (5,764,218)

Elan Smart-Pad1 Gestures can be found in the control settings for the Smart-Pad:

See Exhibit 3 The drag and drop gesture, for example, is invoked by, among other things, detecting a short gap interval between two contacts. See, e.g., above Description ("tapping the pad twice"). Further, a gap interval is detected to determine whether to release the drag. See, e.g., above description of ("Release after time delay"). c) distinguishing between a first The Smart-Pad supports a number of gestures. For example: cursor control operation, a second cursor control operation and a third cursor control operation based on the duration of said contact and gap intervals; and

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Claim Language (5,764,218)

Elan Smart-Pad1

http://www.emc.com.tw/eng/ap02 01 04 01 tps.asp (Smart-Pad gestures). See Exhibit 2 The Smart-Pad distinguishes these gestures based on the duration of the contact and gap intervals. For example, the Smart-Pad distinguishes between selecting an object (such as an icon), opening an object, dragging the object, and performing a drag and drop based on contact and gap intervals.

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Claim Language (5,764,218)

Elan Smart-Pad1

See Exhibit 3 d) reporting one of said first, second or third cursor control operations in accordance with said step of distinguishing. Once the Smart-Pad recognizes the gesture, it reports the operation to the application. Gestures, such as drag and drop, can be found in the control settings for the Smart-Pad, which are similarly reported to the relevant application:

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Claim Language (5,764,218)

Elan Smart-Pad1

See Exhibit 3 2. A method of using a touchsensitive input device coupled to a computer system to move a cursor on a display screen of the computer system and to change the value of a ButtonState variable to one of a first button value and a second button value, said ButtonState variable simulating a button state of a mechanical button switch, said method comprising the steps of: Elan provides its Smart-Pad as part of at least the ASUS line of Eee computer systems, see, e.g., below screen shot of the Device Manager of a ASUS 1000HE computer.

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Claim Language (5,764,218)

Elan Smart-Pad1

See Exhibit 1

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Claim Language (5,764,218)

Elan Smart-Pad1 The Smart-Pad includes, for example, the drag and drop function:

See Exhibit 3 The Smart-Pad "drag and drop" function, for example, performs the method of using a touch-sensitive input device to move a cursor on a display screen of a computer system and to change the value of a ButtonState variable to one of a first button value and a second button value, said ButtonState variable simulating a button state of a mechanical button switch.

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Claim Language (5,764,218) a) detecting a first contact interval when a user first contacts said touch-sensitive input device;

Elan Smart-Pad1 The Smart-Pad detects a first contact interval. For example, the Smart Pad detects a first contact interval as part of the process for determining whether the user is invoking the drag and drop function, opening an icon/file, selecting an icon/file, or simply moving the cursor on the screen.

See Exhibit 3

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Claim Language (5,764,218) b) determining if said first contact interval lasts longer than a first predetermined maximum time interval;

Elan Smart-Pad1 The Smart-Pad determines if the first contact interval lasts longer than a first predetermined maximum time interval as part of the process for determining which gesture is being invoked. For example, in the case of a first tap, the Smart Pad determines whether the user is invoking the drag and drop function, opening an icon/file, selecting an icon/file, or simply moving the cursor on the screen.

See Exhibit 3

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Claim Language (5,764,218) c) supplying positional data relating to the first contact interval to said computer system to cause the cursor to move across said display screen if said first contact interval lasts longer than said first predetermined maximum time interval;

Elan Smart-Pad1 The Smart-Pad supplies positional data relating to the first contact interval to said computer system to cause the cursor to move across said display screen if said first contact interval lasts longer than said first predetermined maximum time interval. For example, in the case of a single tap, if the contact interval lasts longer than a predetermined interval, the Smart Pad interprets this to mean that the user is intending to move the cursor.

See Exhibit 3

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Claim Language (5,764,218) d) setting the value of the ButtonState variable to the first button value if said first contact interval does not last longer than said first predetermined maximum time interval;

Elan Smart-Pad1 The Smart-Pad sets the value of the ButtonState variable to the first button value if said first contact interval does not last longer than said first predetermined maximum time interval. For example, the Smart-Pad registers a button value condition when the user taps the SmartPad.

See Exhibit 3

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Claim Language (5,764,218) e) detecting whether a second contact interval follows said first contact interval in less than a second predetermined maximum time interval;

Elan Smart-Pad1 The Smart-Pad detects whether a second contact interval follows the first contact interval in less than a second predetermined maximum time interval as part of the process of determining whether the user invoked the drag and drop function. For example, the drag and drop gesture requires the Smart-Pad to detect that a second contact interval follows a first contact interval within a predetermined maximum time interval. If the second contact interval follows a first contact interval in more than a second predetermined maximum, the gesture is not a drag and drop gesture.

See Exhibit 3 See above Description ("tapping the pad twice").

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Claim Language (5,764,218) f) setting the value of the ButtonState variable to the second button value if said second contact interval does not follow said first contact interval in less than said second predetermined maximum time interval;

Elan Smart-Pad1 The Smart-Pad sets the value of the ButtonState variable to the second button value if said second contact interval does not follow said first contact interval in less than said second predetermined maximum time interval. For example, if the Smart-Pad detects a tap followed by a long interval before another contact, the Smart-Pad sets the button value to a second value.

See Exhibit 3

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Claim Language (5,764,218) g) determining if said second contact interval lasts longer than a third redetermined maximum time interval if said second contact interval does follow said first contact interval in less than said second predetermined maximum time interval;

Elan Smart-Pad1 The Smart-Pad determines if said second contact interval lasts longer than a third predetermined maximum time interval if said second contact interval does follow said first contact interval in less than said second predetermined maximum time interval. For instance, the Smart-Pad registers a particular command if a second contact interval is less than a predetermined maximum, which is different from the command registered by the Smart-Pad if the second command is more than a predetermined maximum. See, e.g., for instance, the gesture required for drag and drop.

See Exhibit 3 See above Description ("tapping the pad twice").

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