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)

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Claim Language (5,764,218) h) supplying positional data relating to the second contact interval to said computer system to cause the cursor to move across said display screen if said second contact interval lasts longer than said third predetermined maximum time interval; Elan Smart-Pad1 The Smart-Pad supplies positional data relating to the second contact interval to said computer system to cause the cursor to move across said display screen if said second contact interval lasts longer than said third predetermined maximum time interval. For example, the drag and drop gesture is a tap followed by a contact exceeding a predetermined interval. Once it is determined that the contact exceeds the predetermined interval, the object subjected to the drag and drop gesture can be dragged across the display. See Exhibit 3 See above Description. 18 Dockets.Justia.com Claim Language (5,764,218) i) detecting whether a third contact interval follows said second contact interval in less than a fourth predetermined maximum time interval; Elan Smart-Pad1 The Smart-Pad detects whether a third contact interval follows said second contact interval in less than a fourth predetermined maximum time interval as part of the process of determining whether to terminate the drag and drop function. For example, in the case of the drag and drop function, the Smart-Pad will not terminate the function if the third contact occurs before a predetermined time. See Exhibit 3 See above Description ("Release after time delay"). 19 Claim Language (5,764,218) j) setting the value of the ButtonState variable to the second button value if said third contact interval does not follow said second contact interval in less than said fourth predetermined maximum time interval; Elan Smart-Pad1 The Smart-Pad sets the value of the ButtonState variable to the second button value if said third contact interval does not follow said second contact interval in less than said fourth predetermined maximum time interval. For example, in the case of the drag and drop gesture, if a third contact interval follows the second contact interval in a time more than a fourth predetermined maximum time interval, the button variable will be set to the value of the second button value. See Exhibit 3 See above Description ("Release after time delay"). 20 Claim Language (5,764,218) k) determining if said third contact interval lasts longer than a fifth predetermined maximum time interval if said third contact interval does follow the second contact interval in less than said fourth predetermined maximum time interval; and Elan Smart-Pad1 The Smart-Pad determines if said third contact interval lasts longer than a fifth predetermined maximum time interval if said third contact interval does follow the second contact interval in less than said fourth predetermined maximum time interval as part of the process of determining whether to terminate the drag and drop function. For example, in the case of the drag and drop operation, when the third contact interval is less that the Delay Time, the drag and drop operation is not ended. See Exhibit 3 See above Description. 21 Claim Language (5,764,218) l) supplying positional data relating to the third contact interval to said computer system in order to maintain the cursor movements initiated by supplying positional data relating to the second contact interval to the computer system if said third contact interval lasts longer than said fifth predetermined maximum time interval. Elan Smart-Pad1 The Smart-Pad supplies positional data relating to the third contact interval to said computer system in order to maintain the cursor movements initiated by supplying positional data relating to the second contact interval to the computer system if said third contact interval lasts longer than said fifth predetermined maximum time interval. For example, in the case of the drag and drop operation, the cursor can be used to drag an icon around the screen when the third contact interval lasts longer than a fifth predetermined maximum time interval. See Exhibit 3 See above Description. 22 Claim Language (5,764,218) 3. The method of claim 2 further comprising the step of setting the value of the ButtonState variable to the second button value if said third contact interval does not last longer than said fifth predetermined maximum time interval. Elan Smart-Pad1 The Smart-Pad sets the value of the ButtonState variable to the second button value if said third contact interval does not last longer than said fifth predetermined maximum time interval. For example, in the case of the drag and drop gesture, the button state variable is set to the second button value when the Smart-Pad registers a tap. See, e.g., the "Tap again to release" setting. See Exhibit 3 23 Claim Language (5,764,218) 5. An apparatus for operating a touch-sensitive input device of a computer system comprising: Elan Smart-Pad1 Elan's Smart-Pad, specifically the controller of the Smart-Pad, is an apparatus for operating a touch-sensitive input device of a computer system. 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 24 Claim Language (5,764,218) a) means for detecting contact intervals when a user contacts the touch-sensitive input device; Elan Smart-Pad1 This element is governed by 35 U.S.C. § 112(6). The corresponding structure is the Smart-Pad controller and associated circuitry. See, e.g., below picture of the Smart-Pad's controller. See Exhibit 4 25 Claim Language (5,764,218) Elan Smart-Pad1 The Smart-Pad controller and associated circuitry 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). See Exhibit 2 26 Claim Language (5,764,218) Elan Smart-Pad1 http://www.emc.com.tw/eng/ap02_01_04_01_tps.asp (Smart-Pad gestures). 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 "Description" in the Figure above ("tapping the pad twice"). 27 Claim Language (5,764,218) b) means for detecting gap intervals between subsequent contact intervals; and Elan Smart-Pad1 This element is governed by 35 U.S.C. § 112(6). The corresponding structure is the Smart-Pad controller and associated circuitry. See, e.g., below picture of the Smart-Pad's controller. See Exhibit 4 28 Claim Language (5,764,218) Elan Smart-Pad1 The Smart-Pad controller and associated circuitry detects gap intervals between subsequent contact intervals to determine whether the user is invoking a gesture (and to determine the type of gesture). See Exhibit 2 29 Claim Language (5,764,218) Elan Smart-Pad1 http://www.emc.com.tw/eng/ap02_01_04_01_tps.asp (Smart-Pad gestures). 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 above Description ("tapping the pad twice"). Further, a gap interval is detected to determine whether to release the drag. See above description of ("Release after time delay"). 30 Claim Language (5,764,218) c) means for distinguishing between a first 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 for reporting one of said first second or third cursor control operations in accordance therewith. Elan Smart-Pad1 This element is governed by 35 U.S.C. § 112(6). The corresponding structure is the Smart-Pad controller and associated circuitry. See, e.g., below picture of the Smart-Pad's controller. See Exhibit 4 The Smart-Pad controller and associated circuitry distinguishes between a first cursor control operation, a second cursor control operation and a third cursor control operation based on the duration of said contact and gap intervals. 31 Claim Language (5,764,218) Elan Smart-Pad1 The Smart-Pad supports a number of gestures. For example: See Exhibit 2 http://www.emc.com.tw/eng/ap02_01_04_01_tps.asp (Smart-Pad gestures). 32 Claim Language (5,764,218) Elan Smart-Pad1 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. See Exhibit 3 33 Claim Language (5,764,218) Elan Smart-Pad1 The Smart-Pad controller and associated circuitry, after the Smart-Pad recognizes the gesture, reports one of said first second or third cursor control operations in accordance therewith. 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: See Exhibit 3 34

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