Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 1020

Administrative Motion to File Under Seal Documents Under Seal Re Apples Opposition To Samsungs Motion For Summary Judgment filed by Apple Inc.. (Attachments: #1 Proposed Order, #2 Declaration Of Jason R. Bartlett In Support Of Apples Opposition To Samsungs Motion For Summary Judgment, #3 Bartlett Decl. Ex. 8, #4 Bartlett Decl. Ex. 9, #5 Bartlett Decl. Ex. 10, #6 Bartlett Decl. Ex. 11, #7 Bartlett Decl. Ex. 17, #8 Bartlett Decl. Ex. 18, #9 Bartlett Decl. Ex. 19, #10 Bartlett Decl. Ex. 23, #11 Bartlett Decl. Ex. 26, #12 Bartlett Decl. Ex. 30, #13 Bartlett Decl. Ex. 31, #14 Bartlett Decl. Ex. 32, #15 Bartlett Decl. Ex. 53, #16 Bartlett Decl. Ex. 54, #17 Bartlett Decl. Ex. 55, #18 Bartlett Decl. Ex. 57, #19 Bartlett Decl. Ex. 58, #20 Bartlett Decl. Ex. 59, #21 Bartlett Decl. Ex. 60, #22 Bartlett Decl. Ex. 61, #23 Bartlett Decl. Ex. 62, #24 Bartlett Decl. Ex. 64, #25 Bartlett Decl. Ex. 67, #26 Bartlett Decl. Ex. 80)(Jacobs, Michael) (Filed on 6/1/2012)

Exhibit 64

EXHIBIT G-7
SAMSUNG’S INVALIDITY CLAIM CHARTS FOR DTFLASH1 COMMERCIALLY SOLD, PUBLICLY KNOWN, OR
PUBLICLY USED BEFORE JANUARY 7, 2007 (“DTFLASH”)
U.S. Patent No. 7,469,381
[1A] A computer-implemented
method, comprising:

DTFlash
The DiamondTouch table running DTFlash discloses a computer-implemented method.
For example, MERL TR 2005-105 discloses that “DTFlash is the latest toolkit to emerge for
building applications on DiamondTouch.” MERL TR 2005-105 at Conclusion.

[1B] at a device with a touch
screen display

DTFlash runs on Diamond Touch table. The DiamondTouch table running DTFlash discloses a
device with a touch screen display.
For example, MERL TR 2005-105 discloses that “DTFlash is designed so that those familiar with
Macromedia Flash authoring tools can add multi-user multi-touch gestures and behaviors to webenabled games and other applications for the DiamondTouch table.” MERL TR 2005-105 at
Abstract. MERL TR 2002-48 discloses that “DiamondTouch is a multi-touch input technology.”
MERL TR 2002-48 at Abstract.

[1C] displaying a first portion
of an electronic document;

The DiamondTouch table running DTFlash discloses displaying a first portion of an electronic
document.

The electronic document is shown below, outlined in yellow.

1

DTFlash was disclosed in “Multi-User Multi-Touch Games on DiamondTouch with the DTFlash Toolkit,” Alan Esenther
and Kent Wittenburg, Mitsubishi Electric Research Laboratories, TR 2005-105 , Dec. 2005 (“MERL TR 2005-105”). DTFlash is an
authoring toolkit that runs on the DiamondTouch table. DiamondTouch was disclosed in “DiamondTouch SDK: Support for MultiUser, Multi-Touch Applications,” Alan Esenther, Cliff Forlines, Kathy Ryall, Sam Shipman, Mitsubishi Electric Research
Laboratories, TR 2002-48 , Nov. 2002 (“MERL TR 2002-48”).

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U.S. Patent No. 7,469,381

DTFlash

Electronic document

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U.S. Patent No. 7,469,381

DTFlash
Translating the electronic document slightly downward causes a first portion of the electronic
document to be displayed. The first portion is depicted in the picture below, outlined in yellow.

First portion

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U.S. Patent No. 7,469,381
[1D] detecting a movement of
an object on or near the touch
screen display; in response to
detecting the movement,
translating the electronic
document displayed on the
touch screen display in a first
direction to display a second
portion of the electronic
document, wherein the second
portion is different from the
first portion;

DTFlash
The DiamondTouch table can detect a movement of an object (e.g. a finger) on or near the touch
screen display. The DiamondTouch table running DTFlash discloses that in response to detecting
the movement, the electronic document is translated in a first direction to display a second portion
of the electronic document, wherein the second portion is different from the first portion.
DiamondTouch will detect movement of a finger on the touch screen and translate the electronic
document in the direction of the movement of the finger. Starting at the first portion referenced
above, obtained by having previously scrolled the electronic document slightly downward,
continuing from this position, if the user moves his finger upward, the electronic document will
move upward. A second portion of the electronic document is then displayed. This second portion
of the document is different from the first portion of the document. This is depicted in the figure
below:

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U.S. Patent No. 7,469,381

DTFlash

First direction
Second portion
[1E] in response to an edge of
the electronic document being
reached while translating the
electronic document in the first
direction while the object is still
detected on or near the touch
screen: displaying an area
beyond the edge of the
document, and displaying a
third portion of the electronic
document, wherein the third
portion is smaller than the first

The DiamondTouch table running DTFlash discloses that in response to an edge of the electronic
document being reached while translating the electronic document in the first direction while the
object (e.g. finger) is still detected on or near the touch screen, displaying an area beyond the edge
of the document, and displaying a third portion of the electronic document, wherein the third
portion is smaller than the first portion.
As the user reaches the bottom edge of the electronic document while scrolling upward in the
example discussed above, an area beyond the bottom edge of the electronic document will be
displayed. That area consists of a copy of the top portion of the electronic document, but is not part
of the electronic document. A third portion of the electronic document is displayed that is smaller
than the first portion of the electronic document because more of the electronic document has been
scrolled off the screen. The third portion (outlined in yellow) and the area beyond the edge
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U.S. Patent No. 7,469,381
portion; and

DTFlash
(outlined in red) of the electronic document are displayed in the picture below:

Third portion
First direction
Area beyond
the edge

[1F] in response to detecting
that the object is no longer on
or near the touch screen
display, translating the
electronic document in a second
direction until the area beyond
the edge of the electronic
document is no longer
displayed to display a fourth

The DiamondTouch table running DTFlash discloses that in response to detecting that the object is
no longer on or near the touch screen display, translating the electronic document in a second
direction until the area beyond the edge of the electronic document is no longer displayed to display
a fourth portion of the electronic document, wherein the fourth portion is different from the first
portion.
If the user lifts his finger while in the process of scrolling, the interface will automatically snap back
to realign the electronic document with the display. This snap-back feature will cause the electronic
document to be translated in a second direction, which will be opposite to the first direction, until

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U.S. Patent No. 7,469,381
portion of the electronic
document, wherein the fourth
portion is different from the
first portion.

DTFlash
the area beyond the edge of the electronic document can no longer be seen. As a result, a fourth
portion of the document is displayed. The fourth portion is different from the first portion.

Second direction
Fourth portion
[2] The computer-implemented
method of claim 1, wherein the
first portion of the electronic
document, the second portion
of the electronic document, the
third portion of the electronic
document, and the fourth
portion of the electronic
document are displayed at the

The DiamondTouch table running DTFlash discloses the first, second, third, and fourth portions are
all at the same magnification. For example, the four portions previously described are all displayed
at the same magnification.

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U.S. Patent No. 7,469,381
same magnification.
[3] The computer implemented
method of claim 1, wherein the
movement of the object is on
the touch screen display.
[4] The computer-implemented
method of claim 1, wherein the
object is a finger.

DTFlash
The DiamondTouch table running DTFlash can detect movement of an object on a touch screen
display. For example, the touch screen display can accept input based on a touch from a finger on
the display. See 1[B].
The DiamondTouch table running DTFlash discloses that the object used to interact with the touch
screen is a finger. For example, the touch screen display can accept input based on a touch from a
finger on the display. See 1[B].

[5] The computer-implemented The DiamondTouch table running DTFlash discloses the first direction is a vertical direction. For
method of claim 1, wherein the example, DTFlash permits the first direction to be vertical. The figure below depicts movement in a
first direction is a vertical
vertical direction:
direction, a horizontal direction,
or a diagonal direction.

First direction
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U.S. Patent No. 7,469,381

[6] The computer-implemented
method of claim 1, wherein the
electronic document is a web
page.

DTFlash

The DiamondTouch table running DTFlash discloses that the electronic document can be a web
page. For example, MERL TR 2005-105 discloses that “DTFlash applications can also work as
regular web pages.” MERL TR 2005-105 at DTFlash Authoring Environment.

To the extent that the DiamondTouch table running DTFlash does not disclose this claim element,
having a web page would have been a simple design choice representing a trivial and predictable
variation. It was well-known in the art to have a web page. For example, Lira, another graphical
user interface, discloses a web page. It would have been obvious to one of ordinary skill in the art
to combine the disclosures of the DiamondTouch table running DTFlash with Lira, because these
references describe graphical user interfaces involving scrolling on touch-screen display-based
electronic devices. Furthermore, these references describe the specific use of reversal of scrolling
direction to convey information to the user. See Exhibit G-1.
Samsung reserves the right to supplement this disclosure after claim construction. The term “web
page” has not been construed by the court. Samsung further reserves the right to supplement this
disclosure after Mitsubishi Electronics Research Laboratories responds to Samsung’s subpoena.
[7] The computer-implemented
method of claim 1, wherein the
electronic document is a digital
image.

It would have been obvious to one of ordinary skill in the art to apply DiamondTouch table running
DTFlash to an electronic document that is a digital image. A digital image provides input to the
user where to touch the touchscreen to manipulate the electronic document.
To the extent that the DiamondTouch table running DTFlash does not disclose this claim element,
having an electronic document that is a digital image would have been a simple design choice
representing a trivial and predictable variation. It was well-known in the art that an electronic
document could be a digital image. For example, Van Den Hoven discloses the use of digital
images. It would have been obvious to one of ordinary skill in the art to combine the disclosures of
the DiamondTouch table running DTFlash with Van Den Hoven, because these references describe
graphical user interfaces involving scrolling on touch-screen display-based electronic devices.
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U.S. Patent No. 7,469,381

DTFlash
Furthermore, these references describe the specific use of reversal of scrolling direction to convey
information to the user. See Exhibit G-2.

Samsung reserves the right to supplement this disclosure after Mitsubishi Electronics Research
Laboratories responds to Samsung’s subpoena.

[8] The computer-implemented
method of claim 1, wherein the
electronic document is a word
processing, spreadsheet, email
or presentation document.

It would have been obvious to one of ordinary skill in the art to apply DiamondTouch table running
DTFlash to an electronic document that is a word processing, spreadsheet, email or presentation
document. DTFlash is disclosed as a “toolkit … for building applications on DiamondTouch.”
MERL TR 2005-105 at Conclusion.
Samsung reserves the right to supplement this disclosure after Mitsubishi Electronics Research
Laboratories responds to Samsung’s subpoena.

[9] The computer-implemented
method of claim 1, wherein the
electronic document includes a
list of items.

It would have been obvious to one of ordinary skill in the art to apply DiamondTouch table running
DTFlash to an electronic document that includes a list of items. DTFlash is disclosed as a “toolkit
… for building applications on DiamondTouch.” MERL TR 2005-105 at Conclusion.
To the extent that the DiamondTouch table running DTFlash does not disclose this claim element,
having an electronic document that includes a list of items would have been a simple design choice
representing a trivial and predictable variation. It was well-known in the art that an electronic
document could be a digital image. For example, Van Den Hoven and Ording both disclose the use
of a list of items. It would have been obvious to one of ordinary skill in the art to combine the
disclosures of the DiamondTouch table running DTFlash with Van Den Hoven and Ording, because
these references describe graphical user interfaces involving scrolling on touch-screen display-based
electronic devices. Furthermore, these references describe the specific use of reversal of scrolling
direction to convey information to the user. See Exhibits G-2 and G-3.
Samsung reserves the right to supplement this disclosure after Mitsubishi Electronics Research
Laboratories responds to Samsung’s subpoena.
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U.S. Patent No. 7,469,381

DTFlash

[10] The computerimplemented method of claim
1, wherein the second direction
is opposite the first direction

The DiamondTouch table running DTFlash discloses that the second direction is opposite the first
direction. When the electronic document snaps back after the user lifts his finger, the direction of
the snap back is opposite the direction in which the user was scrolling. The figures below show that
the first direction is opposite the second direction.

First direction
11

DTFlash

[11] The computerimplemented method of claim
1, wherein translating in the
first direction prior to reaching
an edge of the document has an
associated speed of translation
that corresponds to a speed of
movement of the object.

The DiamondTouch table running DTFlash discloses that translating in the first direction prior to
reaching an edge of the document has an associated speed of translation that corresponds to a speed
of movement of the object.

Second direction

U.S. Patent No. 7,469,381

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U.S. Patent No. 7,469,381

DTFlash

First direction
To the extent that the DiamondTouch table running DTFlash does not disclose this claim element,
having an associated speed of translation that corresponds to a speed of movement of the object
would have been a simple design choice representing a trivial and predictable variation. It was
well-known in the art to have an associated speed of translation that corresponds to a speed of
movement. For example, both Ording and Van Den Hoven, which also involve graphical user
interfaces, disclose having an associated speed of translation that corresponds to a speed of
movement. It would have been obvious to one of ordinary skill in the art to combine the disclosures
of the DiamondTouch table running DTFlash with any one of Van Den Hoven or Ording, because
all of these references describe graphical user interfaces involving scrolling on touch-screen
display-based electronic devices. Furthermore, all of these references describe the specific use of
reversal of scrolling direction to convey information to the user. See Exhibits G-2 and G-3.

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U.S. Patent No. 7,469,381

DTFlash
Samsung reserves the right to supplement this disclosure after Mitsubishi Electronics Research
Laboratories responds to Samsung’s subpoena.

[12] The computerimplemented method of claim
1, wherein translating in the
first direction is in accordance
with a simulation of an
equation of motion having
friction.

The DiamondTouch table running DTFlash discloses that translating in the first direction is in
accordance with a simulation of an equation of motion having friction.

First direction
To the extent that the DiamondTouch table running DTFlash does not disclose this claim element, a
simulation of an equation of motion having friction would have been a simple design choice
representing a trivial and predictable variation. It was well-known in the art to use a simulation of
an equation of motion having friction. For example, both Ording and Van Den Hoven, which also
involve graphical user interfaces, disclose a simulation of an equation of motion having friction. It
would have been obvious to one of ordinary skill in the art to combine the disclosures of the

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U.S. Patent No. 7,469,381

DTFlash
DiamondTouch table running DTFlash with any one of Van Den Hoven or Ording, because all of
these references describe graphical user interfaces involving scrolling on touch-screen display-based
electronic devices. Furthermore, all of these references describe the specific use of reversal of
scrolling direction to convey information to the user. See Exhibits G-2 and G-3.
Samsung reserves the right to supplement this disclosure after Mitsubishi Electronics Research
Laboratories responds to Samsung’s subpoena.

[13] The computerimplemented method of claim
1, wherein the area beyond the
edge of the document is black,
gray, a solid color, or white.
[14] The computerimplemented method of claim
1, wherein the area beyond the
edge of the document is
visually distinct from the
document.
[15] The computerimplemented method of claim
1, wherein translating the
document in the second
direction is a damped motion.

The DiamondTouch table running DTFlash discloses the area beyond the edge of the document is
black, gray, a solid color, or white. The area beyond the edge appears the same as the opposite edge
of the document. If the opposite edge of the document is black, gray, a solid color, or white, then
the area beyond the edge will be black, gray, a solid color, or white.
The DiamondTouch table running DTFlash discloses the area beyond the edge of the document is
visually distinct from the document. The area beyond the edge appears the same as the opposite
edge of the document. If the opposite edge of the document is visually distinct, then the area
beyond the edge of the document will be visually distinct.

The DiamondTouch table running DTFlash discloses that translating the document in the second
direction is a damped motion.

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U.S. Patent No. 7,469,381

DTFlash

Second direction
To the extent that the DiamondTouch table running DTFlash does not disclose this claim element,
translating the document in the second direction with a damped motion would have been a simple
design choice representing a trivial and predictable variation. It was well-known in the art to use a
damped motion. For example, both Ording and Van Den Hoven, which also involve graphical user
interfaces, disclose using a damped motion. It would have been obvious to one of ordinary skill in
the art to combine the disclosures of the DiamondTouch table running DTFlash with any one of
Van Den Hoven or Ording, because all of these references describe graphical user interfaces
involving scrolling on touch-screen display-based electronic devices. Furthermore, all of these
references describe the specific use of reversal of scrolling direction to convey information to the
user. See Exhibits G-2 and G-3.

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U.S. Patent No. 7,469,381

DTFlash
Samsung reserves the right to supplement this disclosure after Mitsubishi Electronics Research
Laboratories responds to Samsung’s subpoena.

[16] The computerimplemented method of claim
1, wherein changing from
translating in the first direction
to translating in the second
direction until the area beyond
the edge of the document is no
longer displayed makes the
edge of the electronic document
appear to be elastically attached
to an edge of the touch screen
display or to an edge displayed
on the touch screen display.
[17] The computerimplemented method of claim
1, wherein translating in the
first direction prior to reaching
the edge of the electronic
document has a first associated
translating distance that
corresponds to a distance of
movement of the object prior to
reaching the edge of the
electronic document; and
wherein displaying an area
beyond the edge of the
electronic document comprises
translating the electronic
document in the first direction

See [1F].
Samsung reserves the right to supplement this disclosure after Mitsubishi Electronics Research
Laboratories responds to Samsung’s subpoena.

To the extent that the DiamondTouch table running DTFlash does not disclose this claim element,
having the second associated translating distance be less than a distance of movement of the object
after reaching the edge of the electronic document would have been a simple design choice
representing a trivial and predictable variation. It was well-known in the art to have a second
translating distance less than a distance of movement of the object. For example, both Ording and
Van Den Hoven, which also involve graphical user interfaces, disclose Claim 17. It would have
been obvious to one of ordinary skill in the art to combine the disclosures of the DiamondTouch
table running DTFlash with any one of Van Den Hoven or Ording, because all of these references
describe graphical user interfaces involving scrolling on touch-screen display-based electronic
devices. Furthermore, all of these references describe the specific use of reversal of scrolling
direction to convey information to the user. See Exhibits G-2 and G-3.
Samsung reserves the right to supplement this disclosure after Mitsubishi Electronics Research
Laboratories responds to Samsung’s subpoena.

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U.S. Patent No. 7,469,381

DTFlash

for a second associated
translating distance, wherein
the second associated
translating distance is less than
a distance of movement of the
object after reaching the edge
of the electronic document.
[18] The computerimplemented method of claim
1, wherein translating in the
first direction prior to reaching
the edge of the electronic
document has a first associated
translating speed that
corresponds to a speed of
movement of the object, and
wherein displaying an area
beyond the edge of the
electronic document comprises
translating the electronic
document in the first direction
at a second associated
translating speed, wherein the
second associated translating
speed is slower than the first
associated translating speed.
[19A] A device, comprising:
[19B] a touch screen display;
[19C] one or more processors;

See [1A].
See [1B].
See [1A].

[19D] memory; and

See [1A].

To the extent that the DiamondTouch table running DTFlash does not disclose this claim element,
Claim 18 would have been a simple design choice representing a trivial and predictable variation. It
was well-known in the art to have the second associated translating speed slower than the first
associated translating speed. For example, both Ording and Van Den Hoven, which also involve
graphical user interfaces, disclose Claim 18. It would have been obvious to one of ordinary skill in
the art to combine the disclosures of the DiamondTouch table running DTFlash with any one of
Van Den Hoven or Ording, because all of these references describe graphical user interfaces
involving scrolling on touch-screen display-based electronic devices. Furthermore, all of these
references describe the specific use of reversal of scrolling direction to convey information to the
user. See Exhibits G-2 and G-3.
Samsung reserves the right to supplement this disclosure after Mitsubishi Electronics Research
Laboratories responds to Samsung’s subpoena.

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U.S. Patent No. 7,469,381
[19E] one or more programs,
wherein the one or more
programs are stored in the
memory and configured to be
executed by the one or more
processors, the programs
including:

[19F] instructions for
displaying a first portion of an
electronic document;

[19G] instructions for detecting
a movement of an object on or
near the touch screen display;
instructions for translating the
electronic document displayed
on the touch screen display in a

DTFlash
See [1A].
Moreover, to the extent that the DiamondTouch table running DTFlash does not disclose this claim
element, the use of one or more programs, wherein the one or more programs are stored in the
memory and configured to be executed by the one or more processors, would have been a simple
design choice representing a trivial and predictable variation. It was well-known in the art to use
one or more programs. For example, Ording, which also involves graphical user interfaces,
discloses the use of one or more programs. It would have been obvious to one of ordinary skill in
the art to combine the disclosures of the DiamondTouch table running DTFlash with Ording,
because these references describe graphical user interfaces involving scrolling on touch-screen
display-based electronic devices. Furthermore, these references describe the specific use of reversal
of scrolling direction to convey information to the user. See Exhibit G-3.
See [1C].
Moreover, to the extent that the DiamondTouch table running DTFlash does not disclose this claim
element, the use of instructions for displaying a first portion of an electronic document would have
been a simple design choice representing a trivial and predictable variation. It was well-known in
the art to use instructions for displaying a first portion of an electronic document. For example,
Ording, which also involves graphical user interfaces, discloses the use of instructions for
displaying a first portion of an electronic document. It would have been obvious to one of ordinary
skill in the art to combine the disclosures of the DiamondTouch table running DTFlash with
Ording, because these references describe graphical user interfaces involving scrolling on touchscreen display-based electronic devices. Furthermore, these references describe the specific use of
reversal of scrolling direction to convey information to the user. See Exhibit G-3.
See [1D].
Moreover, to the extent that the DiamondTouch table running DTFlash does not disclose this claim
element, the use of instructions would have been a simple design choice representing a trivial and
predictable variation. It was well-known in the art to use instructions. For example, Ording, which
also involves graphical user interfaces, discloses the use of instructions. It would have been
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U.S. Patent No. 7,469,381

DTFlash

first direction to display a
second portion of the electronic
document, wherein the second
portion is different from the
first portion, in response to
detecting the movement;
[19H] instructions for
displaying an area beyond an
edge of the electronic document
and displaying a third portion
of the electronic document,
wherein the third portion is
smaller than the first portion, in
response to the edge of the
electronic document being
reached while translating the
electronic document in the first
direction while the object is still
detected on or near the touch
screen display; and
[19I] instructions for translating
the electronic document in a
second direction until the area
beyond the edge of the
electronic document is no
longer displayed to display a
fourth portion of the electronic
document, wherein the fourth
portion is different from the
first portion, in response to
detecting that the object is no
longer on or near the touch

obvious to one of ordinary skill in the art to combine the disclosures of the DiamondTouch table
running DTFlash with Ording, because these references describe graphical user interfaces
involving scrolling on touch-screen display-based electronic devices. Furthermore, these references
describe the specific use of reversal of scrolling direction to convey information to the user. See
Exhibit G-3.
See [1E].
Moreover, to the extent that the DiamondTouch table running DTFlash does not disclose this claim
element, the use of instructions would have been a simple design choice representing a trivial and
predictable variation. It was well-known in the art to use instructions. For example, Ording, which
also involves touch screen user interfaces, discloses the use of instructions. It would have been
obvious to one of ordinary skill in the art to combine the disclosures of the DiamondTouch table
running DTFlash with Ording, because these references describe graphical user interfaces
involving scrolling on touch-screen display-based electronic devices. Furthermore, these references
describe the specific use of reversal of scrolling direction to convey information to the user. See
Exhibit G-3.

See [1F].
Moreover, to the extent that the DiamondTouch table running DTFlash does not disclose this claim
element, the use of instructions would have been a simple design choice representing a trivial and
predictable variation. It was well-known in the art to use instructions. For example, Ording, which
also involves touch screen user interfaces, discloses the use of instructions. It would have been
obvious to one of ordinary skill in the art to combine the disclosures of the DiamondTouch table
running DTFlash with Ording, because these references describe graphical user interfaces
involving scrolling on touch-screen display-based electronic devices. Furthermore, these references
describe the specific use of reversal of scrolling direction to convey information to the user. See
Exhibit G-3.

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U.S. Patent No. 7,469,381
screen display.
[20A] A computer readable
storage medium having stored
therein instructions, which
when executed by a device with
a touch screen display, cause
the device to:

[20B] display a first portion of
an electronic document;
[20C] detect a movement of an
object on or near the touch
screen display; translate the
electronic document displayed
on the touch screen display in a
first direction to display a
second portion of the electronic
document, wherein the second
portion is different from the
first portion, in response to
detecting the movement;
[20D] display an area beyond
an edge of the electronic
document and display a third
portion of the electronic
document, wherein the third

DTFlash
See [1A]-[1B].
Moreover, to the extent that the DiamondTouch table running DTFlash does not disclose this claim
element, a computer readable storage medium having instructions would have been a simple design
choice representing a trivial and predictable variation. It was well-known in the art to use a
computer readable storage medium having instructions. For example, Ording, which also involves
touch screen user interfaces, discloses a computer readable storage medium having instructions. It
would have been obvious to one of ordinary skill in the art to combine the disclosures of the
DiamondTouch table running DTFlash with Ording, because these references describe graphical
user interfaces involving scrolling on touch-screen display-based electronic devices. Furthermore,
these references describe the specific use of reversal of scrolling direction to convey information to
the user. See Exhibit G-3.
See [1C]
See [1D].

See [1E].

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U.S. Patent No. 7,469,381

DTFlash

portion is smaller than the first
portion, if the edge of the
electronic document is reached
while translating the electronic
document in the first direction
while the object is still detected
on or near the touch screen
display; and
[20E] translate the electronic
See [1F].
document in a second direction
until the area beyond the edge
of the electronic document is no
longer displayed to display a
fourth portion of the electronic
document, wherein the fourth
portion is different from the
first portion, in response to
detecting that the object is no
longer on or near the touch
screen display.

22