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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Elan Microelectronics Corporation v. Apple, Inc. ATTACHMENT A-3 INFRINGEMENT CHART FOR U.S. PATENT NO. 6,933,929 Claim Language (6,933,929) 10. A touch pad apparatus, comprising: Elan Smart-Pad assembly1 The Elan Smart-Pad assembly is a touch pad apparatus. See, e.g., below screenshot of the Device Manager of, for example, a ASUS 1000HE computer and below picture of a ASUS 1000HE computer. See Exhibit 1 1 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 Doc. 155 Att. 5 Claim Language (6,933,929) Elan Smart-Pad assembly1 Elan touch pad See Exhibit 6 a housing, said housing having a wall and an opening extending entirely through said wall from an outer surface to an inner surface of said wall, The Elan Smart-Pad assembly includes a housing that has a wall and an opening extending entirely through said wall from an outer surface to an inner surface of said wall. See, e.g., below picture of housing with an opening extending through the wall of the housing. The housing supports the Elan touch pad in the ASUS 1000HE computer. 2 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 8 said housing further including a first recess extending partially within the outer surface of the wall about the periphery of the opening, The Elan Smart-Pad assembly includes housing with a first recess extending partially within the outer surface of the wall about the periphery of the opening. See, e.g., below picture of housing with a recess that supports the Elan touch pad in the ASUS 1000HE computer. 3 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 8 the first recess including a first recessed surface disposed below the outer surface; The Elan Smart-Pad assembly includes a first recess with a first recessed surface disposed below the outer surface. See, e.g., below picture of housing with a first recessed surface disposed below the outer surface. The recessed surface supports the Elan touch pad in the ASUS 1000HE computer. 4 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 8 and a track pad, said track pad being mounted in the first recess against the first recessed surface and over the opening. The Elan Smart-Pad assembly includes a track pad that is mounted in the first recess against the first recessed surface and over the opening. See, e.g., below picture of the Elan track pad that is mounted against the recessed surface of the housing in ASUS 1000HE computer. 5 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 9 11. A touch pad apparatus as recited in claim 10, wherein said touch pad apparatus is part of a portable computer. The Elan Smart-Pad assembly includes a touch pad apparatus that is part of a portable computer. See, e.g., below screenshot of the Device Manager of a ASUS 1000HE computer and below picture of a ASUS 1000HE computer. 6 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 1 7 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 6 12. A touch pad apparatus as recited in The Elan Smart-Pad assembly includes a track pad with a top surface and a bottom claim 10, wherein said track pad has a top surface, the bottom surface is adjacent the first recessed surface. See, e.g., below surface and a bottom surface, the bottom picture of the Elan touch pad in the housing from ASUS 1000HE computer. surface is adjacent the first recessed surface, and the top surface is substantially flush with the outer surface of said housing. 8 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 9 The Elan Smart-Pad assembly includes a track pad with a top surface that is substantially flush with the outer surface of said housing. See, e.g., below picture of the touch pad in the housing from the ASUS 1000HE computer. 9 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 7 13. A touch pad apparatus as recited in claim 12, wherein said touch pad apparatus further comprises: a track pad label that is provided over said track pad and said housing to secure or protect said track pad. The Elan Smart-Pad assembly includes a touch pad apparatus with a track pad label that is provided over said track pad and said housing to secure or protect said track pad. See, e.g., below picture of track pad apparatus from the ASUS 1000HE computer. 10 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 10 15. A touch pad system, comprising: The Elan Smart-Pad assembly is a touch pad apparatus. See, e.g., below screenshot of the Device Manager of, for example, a ASUS 1000HE computer and below picture of a ASUS 1000HE computer. 11 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 1 Elan touch pad 12 Claim Language (6,933,929) a track pad housing having a first recess; Elan Smart-Pad assembly1 See Exhibit 6 The Elan Smart-Pad assembly includes a track pad housing having a first recess. See, e.g., below picture of housing that holds the Elan touch pad in the ASUS 1000HE computer. See Exhibit 8 a track pad disposed in the first recess; and The Elan Smart-Pad assembly includes a track pad disposed in the first recess. See, e.g., below picture of Elan touch pad disposed in recess of a housing from the ASUS 1000HE. 13 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 9 a track pad label disposed over said track pad and said housing, the track pad label being substantially permanently attached to at least the track pad housing in order to secure the track pad within a cavity formed by the first recess and the track pad label. The Elan Smart-Pad assembly includes a track pad label disposed over said track pad and said housing, the track pad label being substantially permanently attached to at least the track pad housing in order to secure the track pad within a cavity formed by the first recess and the track pad label. See, e.g., below picture of housing from the ASUS 1000HE computer with track pad and track pad label. 14 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 10 16. The touch pad system as recited in claim 15 wherein the first recess is configured to coincide with the shape of the track pad and wherein the depth of the first recess is substantially the same as the thickness of the track pad. The Elan Smart-Pad assembly includes a first recess that is configured to coincide with the shape of the track pad. See, e.g., below picture of recess configured to correspond to the shape of the track pad from the ASUS 1000HE computer. 15 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 9 The Elan Smart-Pad assembly includes a first recess wherein the depth of the first recess is substantially the same as the thickness of the track pad. See, e.g., below picture a track pad and housing from the ASUS 1000HE computer. 16 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 7 17. The touch pad system as recited in claim 15 wherein the first recess surrounds an opening, the opening allowing wiring of the track pad to be provided internal to the track pad housing. The Elan Smart-Pad assembly includes a first recess that surrounds an opening, the opening allowing wiring of the track pad to be provided internal to the track pad housing. See, e.g., below picture of track pad and housing from the ASUS 1000HE computer. 17 Claim Language (6,933,929) Elan Smart-Pad assembly1 See Exhibit 11 18 Exhibit 1 APEL0006476 Exhibit 2 APEL0006477 Exhibit 3 APEL0006478 Exhibit 4 APEL0006479 Exhibit 5 APEL0006480 Exhibit 6 APEL0006481 Exhibit 7 APEL0006482 Exhibit 8 APEL0006483 Exhibit 9 APEL0006484 Exhibit 10 APEL0006485 Exhibit 11 APEL0006486

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