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

Filing 1056

Administrative Motion to File Under Seal Reply Declaration of Marc J. Pernick in Support of Apple's Motion to Strike Portions of Samsung's Expert Reports filed by Apple Inc.. (Attachments: #1 Declaration of Marc J. Pernick in Support of Reply re Apple's Motion to Strike Portions of Samsung's Expert Reports, #2 Exhibit 1, #3 Exhibit 2, #4 Exhibit 3, #5 Exhibit 4, #6 Exhibit 5, #7 Exhibit 6, #8 Exhibit 7, #9 Exhibit 8, #10 Exhibit 9, #11 Exhibit 10, #12 Exhibit 11)(Jacobs, Michael) (Filed on 6/7/2012)

Exhibit 8

EXHIBIT A

1
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,812,828
Claim Term
“mathematically fitting
an ellipse to at least one
of the pixel groups”
(claims 1 and 10)

Proposed Construction
for at least one of the pixel groups,
applying a unitary transformation of
the group covariance matrix of
second moments of proximity data
for all pixels in that pixel group to
fit an ellipse

Identified by Samsung.

Supporting Evidence
Intrinsic Evidence
See Amendment dated 2/24/2010 (application no. 11/677,958) at
10-12.
See also Interview Summary dated 2/2/2010 (application no.
11/677,958).
See also U.S. Patent No. 7,812,828 (‘828 Patent) at 26:17-46.
Additional Evidence
Documents from In the Matter of Certain Mobile Devices and
Related Software, 337-TA-750, including but not limited to
deposition testimony and exhibits, parties' claim construction
disclosures, parties' expert reports, parties' prehearing briefs, trial
testimony and exhibits, parties' posthearing briefs, and initial and
final determinations.

“segmenting each
Plain and ordinary meaning.
proximity image into one
or more pixel groups that
indicate significant
proximity”
(claim 1)
“segment the proximity
2
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,812,828
Claim Term
image into one or more
pixel groups”
(claim 24)

Proposed Construction

Supporting Evidence

Identified by Apple.
“pixel”

Plain and ordinary meaning.

(claims 1, 6, 9, 10, 16,
24, and 31)
Identified by Apple.
“means for producing a
proximity image
representing a scan of a
plurality of electrodes of
a touch-sensitive surface,
the proximity image
having a plurality of
pixels corresponding to
the touch-sensing
electrodes”
Identified by Samsung
and Apple.

Function: producing a proximity
image representing a scan of a
plurality of electrodes of a touchsensitive surface, the proximity
image having a plurality of pixels
corresponding to the touch-sensing
electrodes

Intrinsic Evidence
See ‘828 Patent at 16:4-32.
See also Figures 2-6, 7A and 7B.

Structure: circuitry that constructs
and outputs a proximity image
including: (1) a proximity sensing
device that measures selfcapacitance of one or more
pixilated sensing electrodes, as in
figs. 2-6; and (2) circuitry that
3
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,812,828
Claim Term

“means for segmenting
the proximity image into
one or more pixel
groups, each pixel group
representing a touch
object on or near the
touchsensitive surface”
Identified by Samsung
and Apple.
“means for fitting an
ellipse to at least one of
the pixel groups”

Proposed Construction
converts each signal from the
proximity sensing device to a
digital code appropriate for
processing by computer by using
digital-to-analog converter to
convert a digital stored background
signal value to a voltage, using a
differential amplifier to subtract that
background signal from the
proximity sensing device signal,
and then converting this difference
signal to digital code using an
analog to digital converter, as in
figs. 7A and 7B; and equivalents
thereof.
Function: segmenting the
proximity image into one or more
pixel groups, each pixel group
representing a touch object on or
near the touch-sensitive surface

Supporting Evidence

Intrinsic Evidence
See ‘828 Patent at 23:8-23, 25:54-56.
See also Figure 8.

Structure: a host computer
programmed to perform the steps
diagrammed in figure 18 and
equivalents thereof.
Function: fitting an ellipse to at
least one of the pixel groups

See ‘828 Patent at 14:6-8, 25:61-26:34.

4
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,812,828
Claim Term

Proposed Construction

Identified by Samsung
and Apple.

Structure: using a programmed
host computer as described in 14:68, parameterizing the grouped pixel
data in at least one of the pixel
groups by (1) computing a
proximity-weighted centroid from
positions and proximities of each
pixel in a pixel group using
equations 12-14 in the
specification; (2) computing a
group covariance matrix of x-y
second moments using equations
15-18 of the specification; (3) after
calculating the eigenvalues of the
covariance matrix in equation 15,
using these eigenvalues to
determine axis lengths and
orientation of an ellipse using
equations 19-21 of the
specification; and equivalents
thereof.

“means for transmitting
one or more ellipse
parameters as a control
signal to an electronic or
electromechanical
device”

Supporting Evidence

Function: transmitting one or more
ellipse parameters as a control
signal to an electronic or
electromechanical device
Structure: Indefinite. There is no
5
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,812,828
Claim Term
Identified by Samsung
and Apple.
“means for tracking a
path of one or more pixel
groups through a
plurality of timesequenced proximity
images”
Identified by Samsung
and Apple.
“means for fitting an
ellipse to at least one of
the pixel groups in a
plurality successive
proximity images”
Identified by Samsung
and Apple.

Proposed Construction
structure that performs the claimed
function.

Supporting Evidence

Function: tracking a path of one or
more pixel groups through a
plurality of time-sequenced
proximity images
Structure: Indefinite. There is no
structure that performs the claimed
function.

Function: fitting an ellipse to at
least one of the pixel groups in a
plurality successive proximity
images

Intrinsic Evidence
See ‘828 Patent at 14:6-8, 25:61-26:34.

Structure: using a programmed
host computer as described in 14:68, parameterizing the grouped pixel
data in at least one of the pixel
groups by (1) computing a
proximity-weighted centroid from
positions and proximities of each
pixel in a pixel group using
equations 12-14 in the
6
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,812,828
Claim Term

“means for tracking a
change in one or more
ellipse parameters
through a plurality of
time-sequenced
proximity images”
Identified by Samsung
and Apple.

Proposed Construction
specification; (2) computing a
group covariance matrix of x-y
second moments using equations
15-18 of the specification; (3) after
calculating the eigenvalues of the
covariance matrix in equation 15,
using these eigenvalues to
determine axis lengths and
orientation of an ellipse using
equations 19-21 of the
specification; and equivalents
thereof
Function: tracking a change in one
or more ellipse parameters through
a plurality of time-sequenced
proximity images

Supporting Evidence

Structure: Indefinite. There is no
structure that performs the claimed
function.

7
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 6,493,002
Claim Term
“cursor”

Proposed Construction
A movable indicator on a computer
screen identifying the point that will
be affected by input from the user.

Supporting Evidence
Intrinsic Evidence
Figs. 2A, 2C, 2D, 2E; 8:55-62; 12:44-52; 12:67-13:-8; 16:3-14;
17:23-30; 17:46-50; 20:14-17:
Extrinsic Evidence
Deposition of Steven Christensen 10/26/11 at 116:20-119:22.

"cursor control device"

A trackpad, trackball, or mouse that
causes a cursor to move and select
objects on the display.

“programming module”

Plain and ordinary meaning.

“independently displayed
and independently active”

Indefinite under 35 U.S.C. § 112 ¶2.

“at least one of the
plurality of display areas
and its associated
programming module is
sensitive to user input”

At least one of the plurality of display
areas and its associated programming
module responds when the cursor is
placed over the area and is clicked on
using the cursor control device.

Intrinsic Evidence
Fig. 9; 5:2-4; 7:2-3; 7:20-23; 10:1-12; 12:40-13:13; 15:60-61;
15:65-67: 16:2-6; 20:30-31.
Extrinsic Evidence
Deposition of Steven Christensen 10/26/11 at 116:25-117:8;
118:6-119:12; 130:18-131:1

Intrinsic Evidence
Figs. 2C, 2D, 2E, 9, 10; 6:11-34: 10:1-12; 12:64-13:24
Extrinsic Evidence
Deposition of Steven Christensen 10/26/11 at 54:25-56:23;
130:5-131:1; 178:18-24, Exhibit 978 (APLNDC-X0000002323)

8
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 6,493,002
Claim Term
“the first window region
implemented in a window
layer that appears on top
of application
programming windows
that may be generated”

Proposed Construction
The first window and the plurality of
independent display areas are never
obscured by any portion of any
application windows that are
generated or capable of being
generated.

"means for positioning a
cursor on a data display
screen" (Claim 26)

Function: positioning a cursor on a
data display screen

Supporting Evidence
Intrinsic Evidence
Fig. 2A; 6:41-52; June 28, 2000 Response to Final Office
Action, at 3 (APLNDC00028084); June 6, 2001 Appeal Brief,
passim.
Extrinsic Evidence
Deposition of Steven Christensen 10/26/11 at 23:7-24:2, 42:943:18, 75:8-19, 126:11-127:22; Exhibit 978 (APLNDCX0000002323)
Intrinsic Evidence
Fig. 9; 5:2-4; 7:2-3; 7:20-23; 10:1-12; 12:40-13:13; 15:60-61;
15:65-67: 16:2-6; 20:30-31.

Structure: trackpad, trackball, mouse
Extrinsic Evidence
(7:2-3). The means plus function
"means for positioning a
claims are indefinite as to any
Deposition of Steven Christensen 10/26/11 at 116:25-117:8;
cursor on said data display remaining structures (e.g. “stylus”
118:6-119:12; 130:18-131:1
screen" (Claim 39)
and “cursor function keys”) for
failing to disclose these structures in
Identified by Samsung and sufficient detail.
Apple
"means for creating an
operating environment for
a plurality of individual
programming modules
associated with different
application programs that
provide status and/or

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: creating an operating
9
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 6,493,002
Claim Term
control functions" (Claims
26, 39)

Proposed Construction
environment for a plurality of
individual programming modules
associated with different application
programs that provide status and/or
Identified by Samsung and control functions
Apple
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

Supporting Evidence

"means for executing at
least one of the plurality of
individual programming
modules to generate
information for display in
one of the plurality of
display areas in the first
window region" (Claim
26)

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: executing at least one of
the plurality of individual
programming modules to generate
information for display in one of the
plurality of display areas in the first
Identified by Samsung and window region
Apple
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

10
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 6,493,002
Claim Term
"means for generating user
sensitive graphics for
display in at least one data
display area" (Claim 39)
Identified by Apple

Proposed Construction
Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: generating user sensitive
graphics for display in at least one
data display area
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

Supporting Evidence

"means for determining
when said at least one data
display area has been
selected by the user"
(Claim 39)

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: determining when said at
Identified by Samsung and least one data display area has been
Apple
selected by the user
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.
11
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 6,493,002
Claim Term
"means for initiating a
response from said at least
one of the plurality of
programming modules"
(Claim 39)

Proposed Construction
Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: initiating a response from
Identified by Samsung and said at least one of the plurality of
Apple
programming modules
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.
"means for window
generation and control"
(Claim 50)
Identified by Samsung
"means for indicia
generation coupled to the
data display screen to
execute at least one of the
plurality of individual
programming modules to
generate information for

Supporting Evidence

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: window generation and
control to create an operating
environment for a plurality of
individual programming modules
associated with different application
programs that provide status and/or
control functions
Structure: none disclosed.

12
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 6,493,002
Claim Term
display in one of the
plurality of display areas
in the first window region"
(Claim 50)
Identified by Apple
"means for indicia
generation" (Claim 50)
Identified by Samsung
“means for indicia
generation coupled to the
data display screen to
execute at least one of the
plurality of individual
programming modules to
generate information for
display in one of the
plurality of display areas
in the first window
region” (claim 50)
Identified by Apple

Proposed Construction
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

Supporting Evidence

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: indicia generation coupled
to the data display screen to execute
at least one of the plurality of
individual programming modules to
generate information for display in
one of the plurality of display areas in
the first window region
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

13
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,469,381
Claim Term
“electronic document”
(all claims)
Identified by Samsung.

Proposed Construction
Information that is visually
represented on a screen that has a
defined set of boundaries.

Supporting Evidence
Intrinsic Evidence
’381 Patent at 23:7-13; 26:56-62; 27:7-12; 30:11-17; 30:18-26;
31:9-16; 32:20-23; 32:42-44; 33:26-32; Figures 8A-D; Figure 9;
Figures 10A-C; Figure 11; Figures 12A-C; Figures 13A-C;
Figures 15A-E.
Extrinsic Evidence
Deposition of Bas Ording, 8/9/11, Transcript at 20:18-21:3.
Deposition of Ravin Balakrishnan, 8/16/11, Transcript at 27:1328:18; 161:13-163:2; 147:16-158:22; Exhibit 104.
Deposition of Andries Van Dam, 9/14/11, Transcript at 38:7 39:3; 118:10-17; 126:2-15.
Declaration of Andries Van Dam in Support of Samsung’s
Opposition to Apple’s Motion for Preliminary Injunction,
8/22/11, ¶¶ 45, 47, 49, 52, 53.

“an edge of the electronic
document” (claims 1, 19,
20)

A boundary of the electronic
document that distinguishes it from
another electronic document, other
content, or a background area.

Intrinsic Evidence
’381 Patent at 3:4-18; 21:23-34; 27:25-39; 28:34-47; 30:48-59;
Figures 8A-8D; Figure 10B.

“the edge of the electronic
14
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,469,381
Claim Term
document” (claims 1, 16,
17, 18, 19, 20)

Proposed Construction

Supporting Evidence
Extrinsic Evidence
Deposition of Bas Ording, 8/9/11, Transcript at 20:18-21:3;
27:13- 28:18; 161:13-163:2.

“the edge of the
document” (claims 1, 13,
14, 16)

Deposition of Ravin Balakrishnan, 8/16/11, Transcript at 147:16158:22; Exhibit 104.

“an edge of the document”
(claim 11)

Deposition of Andries Van Dam, 9/14/11, Transcript at 38:7 39:3; 118:10-17; 126:2-15.

Identified by Samsung.

Declaration of Andries Van Dam in Support of Samsung’s
Opposition to Apple’s Motion for Preliminary Injunction,
8/22/11, ¶¶ 45, 47, 49, 52, 53.

“first direction” (claims 1,
5, 10, 11, 12, 16, 17, 18,
19, 20)

A specific angle of translation.

Identified by Samsung.

“displaying an area
beyond the edge of the
document” (claim 1)

Intrinsic Evidence
’381 Patent at 15:16-19; 20:60-67; 21:1-11; 24:10-12; 24:33-36;
26:37-45; 27:12-17; 29:21-40; Figures 8A-8C.
Extrinsic Evidence
Declaration of Jeffrey Johnson in Support of Samsung’s
Opposition to Apple’s Motion for Preliminary Injunction,
8/22/11, ¶ 24.

Visually showing the area beyond the
boundary of the document by
emitting light or illuminating the area
beyond the boundary of the

Intrinsic Evidence
’381 Patent at 3:4-8; 3:41-46; 4:17-20; 8:3-14; 9:39-41; 10:1-4;
10:8-22; 12:20-26; 15:29-36; 18:29-31; 22:36-57; 31:4-6.

15
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,469,381
Claim Term
“displaying an area
beyond the edge of the
electronic document”
(claim 17, 18)

Proposed Construction
document.

Supporting Evidence
Extrinsic Evidence
Definition of “display.” American Heritage Dictionary, Third
Edition, 1996.

“displaying an area
beyond an edge of the
electronic document”
(claims 19, 20)

Definition of “display.” Mc-Graw-Hill Electronics Dictionary,
Sixth Edition, Neil Sclater and John Markus, 1997.

Identified by Samsung.

Tex. Digital Sys. v. Telegenix, Inc., 308 F.3d 1193, 1210 (Fed.
Cir. 2002); Honeywell Int’l., Inc. v. United States, 609 F.3d
1292, 1299 (Fed. Cir. 2010).
Declaration of Jeffrey Johnson in Support of Samsung’s
Opposition to Apple’s Motion for Preliminary Injunction,
8/22/11, ¶¶ 48-50, 55.
Deposition of Ravin Balakrishnan, 8/16/11, Transcript at 112:1115; 124:7-125:12.

“beyond the edge of the
document” (claim 1)
“beyond the edge of the
electronic document”
(claims 17, 18)

Next to (and not behind or
underneath) the boundary of the
document.

Intrinsic Evidence
’381 Patent at 26:25-31.
Extrinsic Evidence
Definition of “beyond.” Webster’s Third New International
Dictionary of the English Language Unabridged, 2002.

16
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,469,381
Claim Term
“beyond an edge of the
electronic document”
(claims 19, 20)

Proposed Construction

Supporting Evidence

Identified by Samsung.
instructions for displaying
a first portion of an
electronic document
(claim 19)

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: displaying a first portion
of an electronic document.
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

instructions for detecting a
movement of an object on
or near the touch screen
display (claim 19)

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: detecting a movement of
an object on or near the touch screen
display

17
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

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

Proposed Construction
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

instructions for 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, in
response to detecting the
movement (claim 19)

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: translating the electronic
document displayed on the touch
screen display in a first direction to
display a second portion of the
electronic document.
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

instructions for displaying
an area beyond an edge of
the electronic document
and displaying a third
portion of the electronic

Supporting Evidence

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
18
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,469,381
Claim Term
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 (claim 19)

Proposed Construction
Function: displaying an area beyond
an edge of the electronic document
and displaying a third portion of the
electronic document.
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

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 screen display
(claim 19)

Supporting Evidence

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: 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.
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

19
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,469,381
Claim Term
display a first portion of
an electronic document
(claim 20)

Proposed Construction
Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: displaying a first portion
of an electronic document.
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

detect a movement of an
object on or near the touch
screen display (claim 20)

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: detecting a movement of
an object on or near the touch screen
display.
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

translate the electronic

Supporting Evidence

Subject to § 112 ¶ 6.
20
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,469,381
Claim Term
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 (claim 20)

Proposed Construction
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: translating the electronic
document displayed on the touch
screen display in a first direction to
display a second portion of the
electronic document.
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

display an area beyond an
edge of the electronic
document and display a
third portion of the
electronic document,
wherein the third 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

Supporting Evidence

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: displaying an area beyond
an edge of the electronic document
and displaying a third portion of the
electronic document.
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
21
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,469,381
Claim Term
display (claim 20)

Proposed Construction
description.

translate 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 screen display
(claim 20)

Supporting Evidence

Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: 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.
Structure: none disclosed.
Alternatively, if this term is not
subject to § 112 ¶ 6, the claim is
invalid for lack of written
description.

22
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,844,915
Claim Term
“scrolling a window
having a view associated
with the event object”
(all claims)

Proposed Construction
sliding a window in a direction
corresponding to the direction of the
user input over a view that is
stationary relative to the window

means for receiving,
through a hardware
device, a user input on a
touch-sensitive display of
the apparatus, the user
input is one or more input
points applied to the
touch-sensitive display
that is integrated with the
apparatus (claim 15 and all
dependent claims from it)
means for creating an
event object in response to
the user input (claim 15
and all dependent claims
from it)

Subject to § 112 ¶ 6.

Supporting Evidence
Intrinsic Evidence
‘915 Patent at 1:39-47, 2:1-10, 5:25-47.

Intrinsic Evidence
‘915 Patent at 19:23-34.

Function: receiving, through a
hardware device, a user input on a
touch-sensitive display of the
apparatus.
Corresponding structure: input
device 2954 as described in col.
19:23-34.
Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: creating an event object in
response to the user input.
Corresponding structure: none
23
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,844,915
Claim Term

Proposed Construction
disclosed.
Subject to § 112 ¶ 6.

Supporting Evidence

means for determining
whether the event object
invokes a scroll or gesture This limitation is indefinite. The
operation (claim 15 and all specification does not disclose an
dependent claims from it) algorithm to perform the recited
function.
Function: determining whether the
event object invokes a scroll or
gesture operation.

means for issuing at least
one scroll or gesture call
based on invoking the
scroll or gesture operation
(claim 15 and all
dependent claims from it)

Corresponding structure: none
disclosed.
Subject to § 112 ¶ 6.

This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: issuing at least one scroll
or gesture call.
Corresponding structure: none
disclosed.

24
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,844,915
Claim Term
means for responding to at
least one scroll call, if
issued, by scrolling a
window having a view
associated with the event
object (claim 15 and all
dependent claims from it)

Proposed Construction
Subject to § 112 ¶ 6.

Supporting Evidence

This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: responding to at least one
scroll call, if issued, by scrolling a
window having a view associated
with the event object.

means for responding to at
least one gesture call, if
issued, by scaling the view
associated with the event
object based on receiving
the two or more input
points in the form of the
user input (claim 15 and
all dependent claims from
it)

Corresponding structure: none
disclosed.
Subject to § 112 ¶ 6.

This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: responding to at least one
gesture call, if issued, by scaling the
view associated with the event object
based on receiving the two or more
input points in the form of the user
input
25
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,844,915
Claim Term

Proposed Construction

Supporting Evidence

Corresponding structure: none
disclosed.
means for rubberbanding a Subject to § 112 ¶ 6.
scrolling region (claim
16)
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: rubberbanding a scrolling
region displayed within the window
by a predetermined maximum
displacement.

means for attaching scroll
indicators to a content
edge of the window (claim
17)

Corresponding structure: none
disclosed.
Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: attaching scroll indicators
to a content edge of the window
Corresponding structure: none
26
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,844,915
Claim Term
means for attaching scroll
indicators to the window
edge (claim 18)

Proposed Construction
disclosed.
Subject to § 112 ¶ 6.

Supporting Evidence

This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: attaching scroll indicators
to the window edge.

means for responding to at
least one gesture call…by
rotating a view associated
with the event object
(claim 20)

Corresponding structure: none
disclosed.
Subject to § 112 ¶ 6.
This limitation is indefinite. The
specification does not disclose an
algorithm to perform the recited
function.
Function: responding to at least one
gesture call by rotating a view
associated with the event object
Corresponding structure: none
disclosed.

27
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,853,891
Claim Term
"the first window has been
displayed independently
from a position of a cursor
on the screen"
Identified by Samsung.

Proposed Construction
there is a mouse pointer or a similar
icon that is controlled by a mouse,
track ball, or touch pad visible on the
screen and the user’s movement of
the mouse pointer or similar icon
does not affect the location of the
first window

Supporting Evidence
Intrinsic Evidence
See, e.g., U.S. Patent No. 7,853,891 at 1:41-46; 1:55-62; 2:1320; 3:8-12; 7:26-31; 9:9-13.
See also, e.g., Amendment dated June 15, 2006 (application no.
10/193,573) at 23; Amendment dated March 4, 2010 (application
no. 12/012,384) at 22; US 2003/0016253 (Aoki), Abstract.
Extrinsic Evidence
Deposition testimony of Imran Chaudhri, 10/14/2011, 81:8-84:4.
Deposition testimony of Christensen, 10/26/2011, 118:13119:12.

"starting a timer"
Identified by Samsung

initiation of a timekeeping process
that begins at a predetermined value
and counts down until zero

Intrinsic Evidence
See, e.g., U.S. Patent No. 7,853,891 at Abstract; Figures 12, 13,
and 14; 2:22-24; 2:28-31; 2:30-37; 2:49-50 5:65-6:1; 6:21-25;
7:11-20; 8:6-15; 8:23-25; 9:47-49.
Extrinsic Evidence
Deposition testimony of Imran Chaudhri, 10/14/2011, 70:10-16,
71:3-17.

"closing the first window"

Plain and ordinary meaning.

Identified by Samsung.
"in response to a

in response to the timer reaching a

See "starting a timer."

28
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,853,891
Claim Term
determination that the
timer expired"

Proposed Construction
zero value

Supporting Evidence

Identified by Samsung.
"any input from a user
input device"

Indefinite under 35 U.S.C. § 112 ¶ 2.

Extrinsic Evidence
Deposition testimony of Imran Chaudhri, 10/14/2011, 71:1878:19.

neither opaque nor transparent and
allows for the underlying window to
be visible

Intrinsic Evidence
See, e.g., U.S. Patent No. 7,853,891 at Abstract; Figure 12, 14
and 15; 2:31-41; 2:52-56; 3:15-21; 3:37-43; 6:3-5; 8:6-15; 9:1315.

Identified by Samsung.
“translucent”
Identified by Samsung.

Extrinsic Evidence
Deposition testimony of Imran Chaudhri, 10/14/2011, 86:12100:19.
“closing the first window
without user input”

Plain and ordinary meaning.

Identified by Samsung.
“means for displaying a
first window” (Claim 51)

Function: displaying a first window
Structure: Indefinite. There is no
structure that performs the claimed

Identified by Samsung.
29
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,853,891
Claim Term

Proposed Construction
function.

Supporting Evidence

“means for displaying a
first window” (Claim 70)
Identified by Samsung and
Apple.
"means for displaying a
first window in response
to receiving a first input
from a user input device of
the digital processing
system" (Claim 51)
Identified by Apple
"means for starting a
timer" (Claims 51, 71)

Function: starting a timer

Structure: Indefinite. There is no
structure that performs the claimed
Identified by Samsung and function.
Apple.
Function: closing a first window
"means for closing the
first window" (Claim 51)
Structure: Indefinite. There is no
structure that performs the claimed
Identified by Samsung.
function.

30
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,853,891
Claim Term
"means for closing the
first window in response
to a determination that the
timer expired" (Claim 51)

Proposed Construction

Supporting Evidence

Identified by Apple
Function: fading out an image of a
"means for fading out an
image of the first window" first window
(Claims 55, 74)
Structure: Indefinite. There is no
structure that performs the claimed
Identified by Samsung and function.
Apple.
"means for determining a
position on a display of
the digital processing
system independent of a
position of a cursor on the
display" (Claim 64)
Identified by Samsung and
Apple.
"means for restarting the
timer" (Claim 66)

Function: determining a position on
a display of the digital processing
system independent of a position of a
cursor on the display
Structure: Indefinite. There is no
structure that performs the claimed
function.
Function: restarting a timer
Structure: Indefinite. There is no
structure that performs the claimed
31
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,853,891
Claim Term
Identified by Samsung.

Proposed Construction
function.

Supporting Evidence

"means for restarting the
timer in response to
receiving a second input
for the first window
(Claim 66)
Identified by Apple
"means for determining
whether or not a condition
is met" (Claim 73)

Function: determining whether or
not a condition is met

Structure: Indefinite. There is no
structure that performs the claimed
Identified by Samsung and function.
Apple
Function: determining whether or
"means for closing the
first window without user not a condition is met
input"
Structure: Indefinite. There is no
structure that performs the claimed
Identified by Apple
function.

32
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,663,607
Claim Term
Proposed Construction
“glass member” (claim 10) Plain and ordinary meaning.

Supporting Evidence

Identified by Apple.
“capacitive monitoring
circuitry” (claim 1)
Identified by Samsung.

Function: detect changes in charge
coupling between a plurality of first
conductive lines and a plurality of
second conductive lines

Intrinsic Evidence
See, e.g., U.S. Patent No. 7,663,607 at 17:12-35; 17:66–18:39;
13:38-49.

Structure: capacitive sensing circuit
230 including a multiplexer with a
plurality of independent input
channels for receiving signals from
each of a plurality of sensing points
at the same time, the capacitive
sensing circuit sequentially driving
one driving line at a time until all the
driving lines have been driven and
capactively sensing all intersecting
sensing lines in parallel

33
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,864,163
Claim Term
“substantially centered”
(Claims 2, 49, 50, 51, and
52 and all dependent
claims from them)
“instructions for
displaying at least a
portion of a structured
electronic document on
the touch screen display”
(claim 50 and all
dependent claims from it)

Proposed Construction
Indefinite.

Supporting Evidence

This term is indefinite under 35
U.S.C. § 112 ¶ 2 because there is
insufficient structure disclosed in the
specification that corresponds to this
means-plus-function clause under 35
U.S.C. § 112 ¶ 6.
Function: displaying at least a
portion of a structured electronic
document on the touch screen display
Corresponding Structure: None
disclosed.

“means for displaying at
least a portion of a
structured electronic
document on the touch
screen display” (claim 52
and all dependent claims
from it)

Function: displaying at least a
Intrinsic Evidence
portion of a structured electronic
’163 Patent at Figure 1A, Figure 1B, 2:30-35, 7:13-18, 7:40-49,
document on the touch screen display 10:62-2, 14:20-21.

“instructions for detecting
a first gesture at a location

This term is indefinite under 35
U.S.C. § 112 ¶ 2 because there is

Corresponding Structure: Figs. 1A
and 1B, boxes 112, 103, 102, and
132.

34
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,864,163
Claim Term
on the displayed portion of
the structured electronic
document” (claim 50 and
all dependent claims from
it)

Proposed Construction
insufficient structure disclosed in the
specification that corresponds to this
means-plus-function clause under 35
U.S.C. § 112 ¶ 6.

Supporting Evidence

Function: detecting a first gesture at
a location on the displayed portion of
the structured electronic document
Corresponding Structure: None
disclosed.
“means for detecting a
first gesture at a location
on the displayed portion of
the structured electronic
document” (claim 52 and
all dependent claims from
it)

Function: detecting a first gesture at
a location on the displayed portion of
the structured electronic document

“instructions for
determining a first box in
the plurality of boxes at
the location of the first
gesture” (claim 50 and all
dependent claims from it)

Function: determining a first box in
the plurality of boxes at the location
of the first gesture.

Intrinsic Evidence
’163 patent at Figures 1A, 1B, 7:13-18, 7:40-49, 7:61-8:4, 10:3161.

Corresponding Structure: Figs. 1A
and 1B, boxes 112, 103, 102, and
130.
Intrinsic Evidence
’163 Patent at Figure 6A, 15-29.

Corresponding Structure: Steps
6014-6018 in Fig. 6A.

“means for determining a
Function: determining a first box in
first box in the plurality of the plurality of boxes at the location
boxes at the location of the

See “instructions for determining a first box in the plurality of
boxes at the location of the first gesture” (claim 50 and all

35
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,864,163
Claim Term
first gesture” (claim 52
and all dependent claims
from it)

Proposed Construction
of the first gesture

“instructions for enlarging
and translating the
structured electronic
document so that the first
box is substantially
centered on the touch
screen display” (claim 50
and all dependent claims
from it)

This term is indefinite under 35
U.S.C. § 112 ¶ 2 because there is
insufficient structure disclosed in the
specification that corresponds to this
means-plus-function clause under 35
U.S.C. § 112 ¶ 6.

“means for enlarging and
translating the structured
electronic document so
that the first box is
substantially centered on
the touch screen display”
(claim 50 and all
dependent claims from it)

Supporting Evidence
dependent claims from it).

This term is indefinite under 35
U.S.C. § 112 ¶ 2 because there is
insufficient structure disclosed in the
specification that corresponds to this
means-plus-function clause under 35
U.S.C. § 112 ¶ 6.

Corresponding Structure: Steps
6014-6018 in Fig. 6A.

Function: Indefinite.
Corresponding Structure: None
disclosed.

Function: Indefinite.
Corresponding Structure: None
disclosed.

“instructions for, while the

This term is indefinite under 35
36
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,864,163
Claim Term
first box is enlarged,
detecting a second gesture
on a second box other than
the first box” (claim 50
and all dependent claims
from it)

Proposed Construction
U.S.C. § 112 ¶ 2 because there is
insufficient structure disclosed in the
specification that corresponds to this
means-plus-function clause under 35
U.S.C. § 112 ¶ 6.

Supporting Evidence

Function: While the first box is
enlarged, detecting a second gesture
on a second box other than the first
box
Corresponding Structure: None
disclosed
“means for, while the first
box is enlarged, detecting
a second gesture on a
second box other than the
first box” (claim 52 and all
dependent claims from it)

Function: While the first box is
enlarged, detecting a second gesture
on a second box other than the first
box

“instructions for, in
response to detecting the
second gesture, translating
the structured electronic
document so that the
second box is substantially
centered on the touch
screen display” (claim 50

This term is indefinite under 35
U.S.C. § 112 ¶ 2 because there is
insufficient structure disclosed in the
specification that corresponds to this
means-plus-function clause under 35
U.S.C. § 112 ¶ 6.

See “means for detecting a first gesture at a location on the
displayed portion of the structured electronic document” (claim
52)

Structure: Fig. 1A and 1B, boxes
112, 103, 102, and 130.

37
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,864,163
Claim Term
and all dependent claims
from it)

Proposed Construction
Function: Indefinite

Supporting Evidence

Corresponding Structure: None
disclosed.
“means for, in response to
detecting the second
gesture, translating the
structured electronic
document so that the
second box is substantially
centered on the touch
screen display” (claim 52
and all dependent claims
from it)

This term is indefinite under 35
U.S.C. § 112 ¶ 2 because there is
insufficient structure disclosed in the
specification that corresponds to this
means-plus-function clause under 35
U.S.C. § 112 ¶ 6.
Function: Indefinite
Corresponding Structure: None
disclosed.

38
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,920,129
Claim Term
“substantially electrically
isolate” (claims 3, 12, 19,
22, 24-26)

Proposed Construction
Indefinite under 35 U.S.C. § 112 ¶ 2.

Supporting Evidence

Identified by Samsung.

39
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 6,928,604
Claim Term
“input data frame” (claims
1,6,10, 17-18, 20-22, 24)

Proposed Construction
Plain and ordinary meaning.

Supporting Evidence

Identified by Apple.

40
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,050,410
Claim Term
“bit reverse method”
(claim 4)

Proposed Construction
A method of reversing a binary bit
sequence.

Supporting Evidence
Intrinsic Evidence
5:42-53

Identified by Apple.
“means for receiving an
information bit stream
and for outputting an
output stream including
an information bit
stream, a first parity
stream, and a second
parity stream, by
encoding the information
bit stream”
(claim 55)

Function: receiving an information
bit stream; outputting an output
stream including an information bit
stream, a first parity stream, and a
second parity stream, by encoding
the information bit stream

Intrinsic Evidence
Abstract; 3:14-19; Figs. 2 and 3

Structure: an encoder as shown in
figures 2 and 3

Identified by Apple.
“means for performing
an interleaving operation
in response to the output
stream and outputting an
interleaved stream”
(claim 55)

Intrinsic Evidence
Function: performing an
interleaving operation in response to Abstract; 1:64-65; Figure 2
the output stream and outputting an
interleaved stream
Structure: an interleaver as shown
in figure 2

41
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,050,410
Claim Term
Identified by Apple.
“means for creating at
least one radio frame in
response to the
interleaved stream”
(claim 55)

Proposed Construction

Supporting Evidence

Function: creating at least one radio Intrinsic Evidence
frame in response to the interleaved 1:65-67; 7:9-10; Figs. 1 and 2
stream
Structure: a radio frame segmenter
as shown in figure 2

Identified by Apple.
“means for separating the
at least one radio frame
into a separate
information bit stream, a
first separate parity
stream, and a second
separate parity stream”
(claim 55)

Function: separating the at least
one radio frame into a separate
information bit stream, a first
separate parity stream, and a second
separate parity stream

Intrinsic Evidence
Abstract; 4:36-49; 4:54-57; Fig. 2

Structure: a demultiplexer as
shown in figure 2

Identified by Apple.
“means for bypassing the
separate information bit
stream and for
puncturing a part of the
first and second separate
parity streams according
to a given rate matching
rule”

Function: bypassing the separate
information bit stream and
puncturing a part of the first and
second separate parity streams
according to a given rate matching
rule

Intrinsic Evidence
Abstract; 3:32-35; 16:42-54; Fig. 2

Structure: a rate matcher as shown

42
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,050,410
Claim Term
(claim 55)

Proposed Construction
in figure 2

Supporting Evidence

Identified by Apple.

43
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,069,055
Claim Term
“means for storing
Greenwich mean time
(GMT) information for
each of a plurality of
cities” (claim 1)

Proposed Construction
Supporting Evidence
Function: Storing Greenwich mean Intrinsic Evidence
time (GMT) information for each of a Figure 1, items 111-113; Col. 2, lines 23-35.
plurality of cities.
Structure: Memory.

Identified by Apple.
“means for receiving a
reference time from a
signal received from a
remote system” (claim 1)

Function: receiving a reference time
from a signal received from a remote
system.

Intrinsic Evidence
Fig. 1, item 124; Col. 2, line 51.

Structure: An antenna.
Identified by Apple.
“means for counting a
duration of time that
elapses from when said
reference time is acquired”
(claim 1)

Function: counting a duration of
time that elapses from when said
reference time is acquired.

Intrinsic Evidence
Fig. 1, item 110; Col. 3, lines 2-4.

Structure: A controller.

Identified by Apple.
“means for selecting at
least one of said plurality
of cities and automatically
calculating a local time of
said selected city” (claim

Function: selecting at least one of
said plurality of cities and
automatically calculating a local time
of said selected city.

Intrinsic Evidence
Col. 4, lines 20-22.

44
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,069,055
Claim Term
1)

Proposed Construction
Structure: A controller programmed
to detect user input.

Supporting Evidence

Identified by Apple.
“means for outputting said
local time” (claim 1)

Function: outputting said local time.
Structure: A display.

Intrinsic Evidence
Fig. 1, item 123; Col. 3, lines 1-2.

Identified by Apple.

45
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,200,792
Claim Term
“first/second
deinterleaver” (claims 1116)

Proposed Construction
Plain and ordinary meaning.

Supporting Evidence

Identified by Apple.
“symbol” (claims 11, 14)

Plain and ordinary meaning.

Identified by Apple.

46
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,362,867
Claim Term
“primary scrambling
code”
(claims 25, 26, 27 and 30)

Proposed Construction
a scrambling code that differentiates
a base-station from other basestations in the system.

Supporting Evidence
Intrinsic Evidence
1:23-25, 1:29-37, 1:48-2:1; Request for Reconsideration (June 7,
2007) at 3-4.

Identified by Apple.
“means for delaying at
least one of the primary
scrambling codes and
secondary scrambling
code to produce Q-channel
components”
(claim 30)

Function: delaying at least one of the Intrinsic Evidence
primary scrambling codes and
See ‘867 Patent at 3:14-17, 3:64-67, 8:48-50, 10:2-19 , 11:42-52,
secondary scrambling code to
12:4-6 , 13:2-4; Figures 2, 4, 7, 8, 10 and 11
produce Q-channel components
Structure: an adder, register or delay
element as shown in figures 2, 4, 7, 8,
10, and 11

Identified by Apple.

47
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,386,001
Claim Term
“radio frame matcher”
(claims 1-7, 9-12, and
14-16)

Proposed Construction
Software and/or hardware that
segments received data frames into
radio frames and sequentially
outputs the segmented radio frames.

Supporting Evidence
Intrinsic Evidence
See U.S. Patent No. 7,386,001 (“‘001 Patent”) at 3:43-64

Identified by Apple.

48
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,447,516
Claim Term
“gain scaling unit” (claim
15)

Proposed Construction
Plain and ordinary meaning.

Supporting Evidence

Identified by Apple.

49
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,675,941
Claim Term
“header inserter” (claim
10)

Proposed Construction
Plain and ordinary meaning.

Identified by Apple.
“one-bit field setter”
(claim 10)

Plain and ordinary meaning.

Identified by Apple.
“LI inserter” (claims 10
and 13)

Plain and ordinary meaning.

Identified by Apple.
“header and LI remover”
(claim 15)

Plain and ordinary meaning.

Identified by Apple.
“reassembler” (claim 15)

Supporting Evidence

Plain and ordinary meaning.

Identified by Apple.

50
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)

U.S. Patent No. 7,698,711
Claim Term
“applet” (claims 1, 9, 17)

Proposed Construction
A small application designed to run
within another program.

Supporting Evidence
Intrinsic Evidence
Col. 3, lines 10-14.

Identified by Apple.
Extrinsic Evidence
Applet : a small application designed to run within another
program. Wiley Electrical and Electronics Engineering
Dictionary, 2004.

51
SAMSUNG’S PATENT LOCAL RULE 4-2 DISCLOSURES (EXHIBIT A)