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

Filing 1350

UNREDACTED NOTICE OF MOTIONS AND MOTIONS in Limine by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company) re 1256 Order on Administrative Motion to File Under Seal, (Attachments: # 1 Exhibit C to the D'Amato Declaration, # 2 Exhibit E to the D'Amato Declaration, # 3 Exhibit G to the D'Amato Declaration, # 4 Exhibit H to the D'Amato Declaration, # 5 Exhibit J to the D'Amato Declaration, # 6 Exhibit K to the D'Amato Declaration, # 7 Exhibit L to the D'Amato Declaration, # 8 Exhibit M to the D'Amato Declaration, # 9 Exhibit N to the D'Amato Declaration, # 10 Exhibit T to the D'Amato Declaration, # 11 Exhibit V to the D'Amato Declaration, # 12 Exhibit W to the D'Amato Declaration)(Maroulis, Victoria) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

Apple v. Samsung
Confidential – Attorneys’ Eyes Only

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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APPLE INC., a California corporation,

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Plaintiff,
v.

Case No.

11-cv-01846-LHK

EXPERT REPORT OF RAVIN
BALAKRISHNAN, PH.D.
REGARDING INFRINGEMENT
OF U.S. PATENT NO. 7,469,381

SAMSUNG ELECTRONICS CO., LTD., A
Korean business entity; SAMSUNG
ELECTRONICS AMERICA, INC., a New York
corporation; SAMSUNG
TELECOMMUNICATIONS AMERICA, LLC, a
Delaware limited liability company,
Defendants.

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**CONFIDENTIAL – CONTAINS MATERIAL DESIGNATED AS HIGHLY
CONFIDENTIAL – ATTORNEYS’ EYES ONLY PURSUANT
TO A PROTECTIVE ORDER**

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EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

Apple v. Samsung
Confidential – Attorneys’ Eyes Only

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I.

INTRODUCTION
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I, Ravin Balakrishnan, Ph.D., have been asked by counsel for Apple Inc. (“Apple”)

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to provide an opinion in the above-captioned case. I understand that Apple has alleged that

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Defendants Samsung Electronics Co. Ltd., Samsung Electronics America, Inc., and Samsung

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Telecommunications America, LLC (collectively “Samsung”) have infringed various patents

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assigned to Apple. I have been asked to provide opinions as to whether Samsung has infringed

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United States Patent No. 7,469,381 (“the’381 patent”). My opinions as to the ’381 patent are set

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forth below in this report and in the accompanying exhibits.
2.

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I submit this expert report in compliance with Federal Rule of Civil Procedure

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26(a)(2). I reserve the right to supplement or amend this report pursuant to Rule 26(e) and as

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otherwise provided if additional data or other information that affects my opinions becomes

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available. I expect to testify at trial regarding the matters expressed in this report and any

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supplemental reports that I may prepare for this litigation. I also may prepare and rely on

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audiovisual aids to demonstrate various aspects of my testimony at trial. I also expect to testify

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with respect to any matters addressed by any expert testifying on behalf of Samsung, if asked to

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do so.
3.

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I am being compensated at my standard consulting rate of $430 per hour for my

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work in connection with this action. I am separately being reimbursed for any out-of-pocket

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expenses. My compensation is not based in any way on the outcome of the litigation or the nature

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of the opinions that I express.

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II.

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QUALIFICATIONS
4.

Here, I provide a brief summary of my qualifications. My qualifications are stated

more fully in my curriculum vitae, which is attached to this report as Exhibit 1.
5.

I earned my B.Sc. (1st Class Honours) degree in computer science from the

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University of New Brunswick, Canada, in May 1993. Subsequently, I received my M.Sc. and

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Ph.D. degrees in computer science from the University of Toronto, Canada, in January 1997 and

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February 2001, respectively.

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EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

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Apple v. Samsung
Confidential – Attorneys’ Eyes Only

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60.

Additional Samsung documents show that Samsung continued its analysis of

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Apple and its examination and comparison of Apple products, including the iPhone, iPad, and

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iPad 2, throughout 2010 and 2011. (See SAMNDCA00203811-3879; SAMNDCA00203880-

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4010; SAMNDCA00229399-9409; SAMNDCA00229449-9451; SAMNDCA00525347-5349;

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SAMNDCA00525353-5356; SAMNDCA00525362; SAMNDCA10244357-4412;

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SAMNDCA10247283-7372; SAMNDCA10252803-2841; SAMNDCA10988469-88504;

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SAMNDCA10989107-9179; SAMNDCA10989363-9379; SAMNDCA10989840-9941;

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SAMNDCA10990627-0713; SAMNDCA10992025-2057; SAMNDCA10992072-2131;

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SAMNDCA10993206-3226; SAMNDCA10997825-7879; SAMNDCA10998016-8035;

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SAMNDCA11289451-9473; and SAMNDCA11313301-3303; see select translations in

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Translations App’x.)

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E.

Samsung’s Knowledge of the ’381 Patent

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61.

I understand that Samsung knew of the ’381 patent by no later than August 27,

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2010. On that day, Chip Lutton, counsel for Apple, sent an email to K.J. Kim, counsel for

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Samsung, that attached two presentations that identified the ’381 patent and provided an overview

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of its features. (See APLNDC00001101-1102 (email), APLNDC00001103-1123 (presentation

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identifying ’381 patent), and APLNDC00001126-1192 (’381 overview at (1152-1153).))

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F.

Samsung’s Infringement of Claim 1 of the ’381 Patent

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62.

Claim 1. Claim 1 of the ’381 patent recites:

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A computer-implemented method, comprising:

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[a] at a device with a touch screen display:

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[b] displaying a first portion of an electronic document;

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[c] 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;

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[d] 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 display:
displaying an area beyond the edge of the document, and displaying

EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

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Apple v. Samsung
Confidential – Attorneys’ Eyes Only

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a third portion of the electronic document, wherein the third portion
is smaller than the first portion; and

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[e] 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.

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63.

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In my opinion, the ordinary and intended use of the Accused Products (Gallery)

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infringes independent claim 1 of the ’381 patent. As shown in the exemplary infringement claim

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chart attached hereto as Exhibit 3, which is incorporated by reference, and for the reasons

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discussed below, the ordinary and intended use of these devices infringes claim 1 of the ’381

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patent.

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64.

Claim 1, Preamble: “A computer-implemented method, comprising:”

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65.

While I understand that the question of whether this preamble is limiting is a legal

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matter, for the purposes of this report, I have assumed that it must be met.
66.

The ordinary and intended use of the Accused Products (Gallery) meets the

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preamble of claim 1. This is because these Samsung devices are mobile computing devices with

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processors that run the Android software platform, and that implement a number of methods of

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displaying electronic documents on their screens.

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67.

devices with the following features:
x

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68.

Exhibit 4G: “1-GHz Hummingbird” processor that uses “Android
2.3, Gingerbread OS.” (APLNDC-Y0000066850); and

x

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Vibrant: “1 GHz Cortex A8 Hummingbird Application Processor”
that uses “Android 2.2, Froyo.” (APLNDC-Y0000066798);

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Captivate: “1 GHz, Cortex A8 Hummingbird Processor” that uses
“Android 2.3, Gingerbread.” (APLNDC-Y0000066835);

x

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For example, as Samsung describes its own products, they are mobile computing

Galaxy Tab 10.1: “1 Ghz Dual Core Nvidia Tegra2 Processor” that
uses “Android 3.2, Honeycomb.” (APLNDC-Y0000066820-821.)

While the accused Samsung mobile phones such as the Captivate, Vibrant, and

Exhibit 4G phone are often referred to as smartphones, this is analogous to saying that these

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EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

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Apple v. Samsung
Confidential – Attorneys’ Eyes Only

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devices are hand held computers. These devices employ processors similar to those used in

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laptop computers, and implement software that performs functions typically performed on a

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computer, such as displaying electronic documents on the screens of those devices. In addition,

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the “Tab” in Galaxy Tab and Galaxy Tab 10.1 is an abbreviation for “tablet” computer. The

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Galaxy Tab and Galaxy Tab 10.1 also implement software that displays electronic documents on

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their screens. Therefore, the ordinary and intended use of these Samsung devices meets the

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preamble of claim 1.

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69.

Claim 1, Element [a]: “at a device with a touch screen display:”

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70.

Based upon my personal observation, all of the accused Samsung devices have

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touch screen displays. By way of example, the user manual for the Exhibit 4G phone confirms

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that the Exhibit 4G phone is a phone, or device, with a touch screen display:

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(APLNDC-Y0000066320.)
71.

Each of the other Accused Products (Gallery) is also a device with a touch screen

display. (See, e.g., Ex. 3.) It is my opinion that this claim limitation is satisfied.

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72.

Claim 1, Element [b]: “displaying a first portion of an electronic document.”

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73.

The ordinary and intended use of all the Accused Products (Gallery) meets this

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claim limitation. Each of these Samsung devices includes an application called “Gallery” that

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allows for the display of electronic documents, or more specifically, photographs, on the touch

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screen display of the device. By way of example, the “Gallery” application icon on the Exhibit

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4G phone is depicted below, circled in red.

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(Ex. V5.)
EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

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Apple v. Samsung
Confidential – Attorneys’ Eyes Only

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74.

An image being viewed on these Samsung devices may be too large to be seen in

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its entirety, or may be magnified, or zoomed in on, such that the entire image cannot be seen all at

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once. When this occurs, a user will see only portions of the image, and will need to scroll or

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translate the image to view the remainder. Accordingly, these Samsung devices can display a

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first portion of an electronic document, such as a digital photograph. By way of example, the

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Exhibit 4G phone is capable of displaying a first portion of an electronic document, as depicted

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below.

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(Ex. 3.)
75.

Each of the other Accused Products (Gallery) can also display a first portion of an

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electronic document, as demonstrated in Exhibits 3, V1, V3, V5, and V8. It is my opinion that

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the ordinary and intended use of all these Samsung devices meets this claim limitation.

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76.

Claim 1, Element [c]: “detecting a movement of an object on or near the

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touch screen display; in response to detecting the movement, translating the electronic

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document displayed on the touch screen display in a first direction to display a second

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portion of the electronic document, wherein the second portion is different from the first

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portion;”

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77.

The ordinary and intended use of all the Accused Products (Gallery) meets this

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claim limitation. When a user is viewing a photograph in the Gallery application of these

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devices, and places a finger on the touch sensitive screen and moves it, the Samsung devices

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detect that movement, and translate the electronic document, or in this case, the photograph, in

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the same direction, resulting in the display of another portion of the photograph which is different

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EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

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Apple v. Samsung
Confidential – Attorneys’ Eyes Only

1

from the first portion. By way of example, when running the Gallery application, the Exhibit 4G

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phone is capable of detecting the movement of a finger on its touch screen, and in response,

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scrolling the photograph in the same direction, thus displaying a second, different portion of the

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photograph, as depicted below.

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(Ex. 3.)
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78.
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The source code for the Gallery application on the Exhibit 4G phone confirms

what I experienced while using this device. The detection of a user’s finger and translation of the
electronic document are performed in the following source code modules: RenderView.java,
GLSurfaceView.java, GridLayer.java, and GridInputProcessor.java. (SAMNDCA-C0000078907999.) As noted above, the Exhibit 4G phone runs Android 2.3. Based on my inspection of
Samsung source code for each major release of Android running on Samsung phones accused of
infringing the claims of the ’381 patent, similar code for devices running Android 2.2 can be
found, for example, at SAMNDCA-C000008045 - 8180. Similar source code for devices running
Android 2.1 can be found, for example, at SAMNDCA-C000007702-7746.
79.

Each of the other Accused Products (Gallery) can also detect the movement of a

finger on their touch screens, and in response, scroll a photograph in the direction of the finger
movement, displaying a second, different portion of the photograph, as demonstrated in Exhibits
3, V1, V3, V5, and V8. It is my opinion that the ordinary and intended use of all these Samsung
devices meets this claim limitation.

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EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

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Apple v. Samsung
Confidential – Attorneys’ Eyes Only

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80.

To the extent that this limitation is not met literally, in my opinion it is met under

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the doctrine of equivalents because the Accused Products (Gallery) are insubstantially different

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from the device as recited in claim 1.

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81.

In particular, the devices with touch screen displays perform substantially the same

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function of translating an electronic document in a first direction to display a second portion of

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the electronic document, substantially the same way by displaying the movement of an electronic

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document to display another portion of the electronic document, to achieve substantially the same

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result of showing a second portion of the electronic document following movement in a direction.

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82.

Moreover, translating a document in a first direction based on the movement of a

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human finger with minor irregularity is not substantially different from doing so based on an

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absolutely precise movement. Translating a document in a first direction based on the movement

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of a human finger operates to perform substantially the same function (translating the document),

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in substantially the same way (by detecting the movement of an object), to obtain substantially

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the same result (translation of a document in a first direction) as translating based on the

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movement of an object with absolute precision.

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83.

Claim 1, Element [d]: “in response to an edge of the electronic document

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being reached while translating the electronic document in the first direction while the

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object is still detected on or near the touch screen display: displaying an area beyond the

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edge of the document, and displaying a third portion of the electronic document, wherein

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the third portion is smaller than the first portion; and”

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84.

The ordinary and intended use of all the Accused Products (Gallery) meets this

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claim limitation. Like its physical counterpart, a digital photograph displayed on the Samsung

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devices has a rectangular shape bounded by four edges. As the user scrolls around the image to

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view each portion, he may, while scrolling in one direction, encounter the edge of the photograph,

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but perhaps not realizing it, attempt to continue scrolling in the same direction beyond the edge.

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When this occurs, the photograph will keep scrolling in the same direction and, as it is scrolled, a

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black region will fill in the area beyond the edge of the photograph, in effect providing a visual

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EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

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Apple v. Samsung
Confidential – Attorneys’ Eyes Only

1

indication that the image does not extend any further and that the edge of the image has been

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reached.

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85.

By way of example, the Exhibit 4G phone, in response to reaching an edge of a

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photograph, while a finger continues to move the photograph in the same direction, will display a

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black region beyond the edge of the photograph, and thereby display a smaller third portion of the

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photograph, as depicted below.

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(Ex. 3.)
86.

The source code for the Gallery application on the Exhibit 4G phone confirms

what I experienced while using this device. The detection of a user’s finger and translation of the
electronic document are performed in the following source code modules: RenderView.java,
GLSurfaceView.java, GridLayer.java, and GridInputProcessor.java. (SAMNDCA-C0000078907999; see also SAMNDCA-C000008045 - 8180; SAMNDCA-C000007702-7746.) The
GridInputProcessor.java file identifies the edge of the photograph and displays an area beyond the
edge of the photograph.
87.

Each of the other Accused Products (Gallery) exhibits the same behavior. The

Gallery application on each of these products, in response to reaching an edge of a photograph
while scrolling, and while a finger continues to move the photograph in the same direction, will
also display a black region beyond the edge of the photograph, and thereby display a smaller third
portion of the photograph, as demonstrated in Exhibits 3, V1, V3, V5, and V8. It is my opinion
that the ordinary and intended use of all these Samsung devices meets this claim limitation.

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EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

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Apple v. Samsung
Confidential – Attorneys’ Eyes Only

1

88.

To the extent that this limitation is not met literally, in my opinion it is met under

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the doctrine of equivalents because the Accused Products (Gallery) are insubstantially different

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from the device as recited in claim 1.

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89.

In particular, the devices with touch screen displays perform substantially the same

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function of displaying an area beyond the edge of the electronic document in response to an edge

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of the electronic document being reached while translating the electronic document in the first

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direction, substantially the same way by displaying an area beyond the edge of the electronic

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document when a user attempts to move the electronic document beyond its edge, to achieve

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substantially the same result of showing an area beyond the edge of the electronic document.

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90.

In addition, displaying black in an area beyond the edge of a document on a screen

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by not illuminating the area is not substantially different from doing so by filtering or blocking

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light in the area. An AMOLED screen displaying black operates to perform substantially the

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same function (displaying a black area), in substantially the same way (avoiding emission of

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light), to obtain substantially the same result (showing a black area) as a screen that displays

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black by filtering or blocking light.

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91.

Claim 1, Element [e]: “in response to detecting that the object is no longer on

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or near the touch screen display, translating the electronic document in a second direction

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until the area beyond the edge of the electronic document is no longer displayed to display a

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fourth portion of the electronic document, wherein the fourth portion is different from the

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first portion.”

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92.

The ordinary and intended use of all the Accused Products (Gallery) meets this

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claim limitation. In the Gallery application on these Samsung devices, once the user encounters

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the edge of a photograph, if he continues to move his finger in the same direction, more of the

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area beyond the edge of the photograph will be revealed as long as the user keeps his finger on or

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near the touch screen device. Eventually, either because he has reached the edge of the touch

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screen itself or otherwise wants to stop scrolling, the user will lift his finger off the screen,

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thereby terminating contact. When this happens, the photograph will scroll back to cover the area

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beyond the edge that was previously displayed.
EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

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Apple v. Samsung
Confidential – Attorneys’ Eyes Only

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93.

By way of example, the Exhibit 4G phone, in response to detecting that the finger

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is no longer on the touch screen, will scroll the photograph in the other direction until the area

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beyond the edge of the photograph is no longer displayed. What is then displayed constitutes a

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fourth portion of the photograph that is different from the first portion, as depicted below.

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(Ex. 3.)
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94.

The entire sequence is depicted below in a side by side comparison. None of the

portions of the photograph as represented in Figures 1 – 4 is identical to another displayed portion.

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EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

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Apple v. Samsung
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95.

The source code for the Gallery application on the Exhibit 4G confirms what I

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experienced while using this device. The detection of a user’s lifting of his finger from the touch

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screen and translation of the electronic document in a second direction are performed in the

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following source code modules: GridInputProcessor.java and GridCameraManager.java.

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(SAMNDCA-C000007967-8007; see also SAMNDCA-C000008045-8180; SAMNDCA-

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C000007730-7746; SAMNDCA-C000007781-7786.)

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96.

Each of the other Accused Products (Gallery), in response to detecting that the

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finger is no longer on the touch screen, will scroll the photograph in the other direction until the

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area beyond the edge of the photograph is no longer displayed. What is then displayed is a fourth

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portion of the photograph that is different from the first portion, as demonstrated in Exhibits 3,

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V1, V3, V5, and V8. It is my opinion that the ordinary and intended use of all these Samsung

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devices meets this claim limitation.

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97.

To the extent that this limitation is not met literally, in my opinion it is met under

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the doctrine of equivalents because the Accused Products (Gallery) are insubstantially different

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from the device as recited in claim 1.

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98.

In particular, the devices with touch screen displays perform substantially the same

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function of translating the electronic document in a second direction until the area beyond the

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edge of the electronic document is no longer displayed to display a fourth portion of the

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electronic document, substantially the same way by translating the electronic document so that it

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returns to fill the screen, to achieve substantially the same result of not showing an area beyond

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the edge of the electronic document.

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99.

Based on the foregoing analysis of documents and the operation of the Accused

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Products (Gallery), as indicated in more detail in the accompanying exemplary claim chart, I

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conclude that each and every element of claim 1 is met by the ordinary and intended use of these

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Samsung devices. Therefore, the ordinary and intended use of these Samsung devices infringes

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that claim.

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100.

Though my analysis is based on the plain and ordinary meaning of the term “edge

of the electronic document,” even under Samsung’s construction (“a boundary of the electronic
EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

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Apple v. Samsung
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document that distinguishes it from another electronic document, other content, or a background

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area”), each and every element of claim 1 is met by the ordinary and intended use of these

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Samsung devices since the edge of the electronic document that is reached, and beyond which is a

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distinct region, is a “boundary of the electronic document that distinguishes it from . . . a

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background area.”

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101.

I note that the ordinary and intended use of the Accused Products (Browser),

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Accused Products (Contacts), and Accused Products (ThinkFree Office) also infringes this claim,

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but through the Browser, Contacts, and ThinkFree Office applications, which are described in

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detail in my discussion of claims 6, 8, and 9 below.

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102.

Although it is my opinion that the ordinary and intended use of the Accused

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Products (Gallery), Accused Products (Browser), Accused Products (Contacts), and Accused

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Products (ThinkFree Office) as described above literally infringes claim 1, in the alternative it is

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my opinion that such use would infringe under the doctrine of equivalents. It is my opinion that

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these devices perform substantially the same functions, in substantially the same way, to achieve

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substantially the same results as in the limitations of claim 1, and that any differences between the

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operation of these products and the limitations of claim 1 is insubstantial.

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G.

Samsung’s Infringement of Claim 2 of the ’381 Patent

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103.

Claim 2: Claim 2 recites:

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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 same magnification.

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104.

Claim 2 depends from claim 1 and further requires that each of the four portions of

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an electronic document, or more specifically in this case, a photograph, is displayed at the same

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magnification. As can be seen in the side by side comparison of the four figures, or portions,

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above and in Exhibit 3, all of the portions are displayed at the same magnification.

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105.

Accordingly, it is my opinion that the ordinary and intended use of the Accused

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Products (Gallery) infringes claim 2. I note that the ordinary and intended use of the Accused

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Products (Browser), Accused Products (Contacts), and Accused Products (ThinkFree Office) also
EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
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Apple v. Samsung
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infringes this claim, but through the Browser, Contacts, and ThinkFree Office applications, which

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are described in detail in my discussion of claims 6, 8, and 9 below.

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H.

Samsung’s Infringement of Claim 3 of the ’381 Patent

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106.

Claim 3: Claim 3 recites:

5

The computer-implemented method of claim 1, wherein the
movement of the object is on the touch screen display.

6
107.

Claim 3 depends from claim 1 and further requires that the movement of the

7
object, such as the user’s finger, is on the touch screen display. As can be seen in the side by side
8
comparison of the four figures above and in Exhibit 3, the movement of the finger is on the touch
9
screen display.
10
108.

Accordingly, it is my opinion that the ordinary and intended use of the Accused

11
Products (Gallery) infringes claim 3. I note that the ordinary and intended use of the Accused
12
Products (Browser), Accused Products (Contacts), and Accused Products (ThinkFree Office) also
13
infringes this claim, but through the Browser, Contacts, and ThinkFree Office applications, which
14
are described in detail in my discussion of claims 6, 8, and 9 below.
15
I.

Samsung’s Infringement of Claim 4 of the ’381 Patent

109.

16

Claim 4: Claim 4 recites:

17
The computer-implemented method of claim 1, wherein the object
is a finger.

18
19

110.

Claim 4 depends from claim 1 and further requires that the object in contact with

20

or proximity to the touch screen is a finger. As can be seen in the side by side comparison of the

21

four figures above and in Exhibit 3, the object in contact with the touch screen is a finger.

22

111.

Accordingly, it is my opinion that use of the Accused Products (Gallery) infringes

23

claim 4. I note that the ordinary and intended use of the Accused Products (Browser), Accused

24

Products (Contacts), and Accused Products (ThinkFree Office) also infringes this claim, but

25

through the Browser, Contacts, and ThinkFree Office applications, which are described in detail

26

in my discussion of claims 6, 8, and 9 below.

27

J.

Samsung’s Infringement of Claim 5 of the ’381 Patent

28

112.

Claim 5: Claim 5 recites:

EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

28

Apple v. Samsung
Confidential – Attorneys’ Eyes Only

1
2

AA.

Supplementation

3

267.

I reserve the right to supplement this report with new information and/or

4

documents that may be discovered or produced in this case, or to address any new claim

5

constructions offered by Samsung or ordered by the Court.

6

268.

In connection with my anticipated testimony in this action, I may use as exhibits

7

various documents produced in this case that refer or relate to the matters discussed in this

8

report. In addition, I may have demonstrative exhibits prepared to assist in the presentation of my

9

testimony and opinions as set forth or cited in my report.

10
11
12

Dated: March 22, 2012
RAVIN BALAKRISHNAN

13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK

61

EXHIBIT 3

A computer-implemented method,
comprising: at a device with a touch screen
display:

Claim 1 of U.S. Patent No. 7,469,381

-1-

(Captivate User Manual (APLNDC-Y0000062795).)

(Vibrant User Manual (APLNDC-Y0000057339).)

(Exhibit 4G phone User Manual (APLNDC-Y0000066320).)

The Exhibit 4G phone is a mobile computing device with a touch screen display.

Representative Samsung Products

Exhibit 3 – Infringement Claim Chart for U.S. Patent No. 7,469,381

The Exhibit 4G phone detects the movement of an “object” — for instance, a finger —
on its touch screen. In response, it scrolls the photograph in the same direction to
display a second, different portion of the photograph. (Ex. V5.)

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

-2-

The Exhibit 4G phone includes an application called “Gallery” that displays electronic
documents — more specifically, photographs — on the touch screen display. When
running the “Gallery” application, the Exhibit 4G phone displays a first portion of a
photograph. (Ex. V5.)

(Galaxy Tab 10.1 User Manual (APLNDC-Y0000060376).)

Representative Samsung Products

displaying a first portion of an electronic
document;

Claim 1 of U.S. Patent No. 7,469,381

Claim 1 of U.S. Patent No. 7,469,381
document, wherein the second portion is
different from the first portion;

-3-

To the extent that Samsung contends that all instances of translating in the “first
direction” require that the document be translated in the same direction with absolute
precision and that a human finger is incapable of such precise movement, the use of the
Exhibit 4G phone would nevertheless meet this limitation under the doctrine of
equivalents. Translating a document in a first direction based on the movement of a
human finger with minor irregularity is not substantially different from doing so based
on an absolutely precise movement. Moreover, translating a document in a first
direction based on the movement of a human finger operates to perform substantially

The detection of a user’s finger and translation of the electronic document are
g
p
performed in the following source code modules for the Exhibit 4G phone, which runs
g
p
,
Android 2.3: RenderView.java, GLSurfaceView.java, GridLayer.java, and
j ,
j ,
y j ,
GridInputProcessor.java. (
(SAMNDCA-C000007890-7999.) Similar code for devices
p
j
(SAMNDCA-C000007890-7999.)
)
running Android 2.2 can be found, for example, at SAMNDCA-C000008045 - 8180.
g
,
p ,
Similar source code for devices running Android 2.1 can be found, for example, at
r
2
SAMNDCA-C000007702-7746.

Representative Samsung Products

In response to reaching an edge of a photograph, while a finger continues to move the
photograph in the same direction, the Exhibit 4G phone displays a black region beyond
the photograph’s edge, and thus displays a third, smaller portion of the photograph.
(Ex. V5.)

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 display:
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; and

-4-

The detection of a user’s finger and translation of the electronic document are
g
performed in the following source code modules: RenderView.java,

Representative Samsung Products
the same function (translating the document), in substantially the same way (by
detecting the movement of an object), to obtain substantially the same result
(translation of a document in a first direction) as translating based on the movement of
an object with absolute precision.

Claim 1 of U.S. Patent No. 7,469,381

Claim 1 of U.S. Patent No. 7,469,381

-5-

To the extent that Samsung contends any of the accused devices contain an AMOLED
screen and that such screen does not “display[] an area beyond the edge” because the
screen does not emit light or otherwise illuminate a black area, such device would
nevertheless meet this limitation under the doctrine of equivalents. Displaying black in
a specific area of a screen by not illuminating the area is not substantially different
from doing so by filtering or blocking light in the area. Moreover, an AMOLED
screen displaying black operates to perform substantially the same function (displaying
a black area), in substantially the same way (avoiding emission of light), to obtain
substantially the same result (showing a black area) as a screen that displays black by
filtering or blocking light.

Representative Samsung Products
GLSurfaceView.java, GridLayer.java, and GridInputProcessor.java. (SAMNDCAj ,
y j ,
p
j
(
C000007890-7999; see also SAMNDCA-C000008045 - 8180; SAMNDCA;
;
C000007702-7746.) The GridInputProcessor.java file identifies the edge of the
)
p
.j
photograph and displays an area beyond the edge of the photograph.

In response to detecting that the finger is no longer on the touch screen, the Exhibit 4G
phone scrolls the photograph in the opposite direction until it no longer displays the
area beyond the photograph’s edge. What is then displayed is a fourth portion of the
photograph that is different from the first portion. (Ex. V5.)

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.

-6-

The detection of a user’s lifting of his finger from the touch screen and translation of
g
g
the electronic document in a second direction are performed in the following source
p
g
code modules: GridInputProcessor.java and GridCameraManager.java. (
p
j
g j
(SAMNDCAC000007967-8007; see also SAMNDCA-C000008045-8180; SAMNDCA;
C000007730-7746; SAMNDCA-C000007781-7786.)

Representative Samsung Products

Claim 1 of U.S. Patent No. 7,469,381

The entire sequence illustrated in Claim 1 is depicted below in a side-by-side
comparison for the Exhibit 4G phone. As is evident from this comparison, the portions
of the photograph are displayed at the same magnification. (Ex. V5.)

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 same magnification.

-7-

Representative Samsung Products

Claim 2 of U.S. Patent No. 7,469,381

Claim 2 of U.S. Patent No. 7,469,381

-8-

Representative Samsung Products
The entire sequence described in Claim 1 is depicted below in a side-by-side
comparison for the Captivate. As is evident from this comparison, the portions of the
photograph are displayed at the same magnification. (Ex. V1.)

Claim 2 of U.S. Patent No. 7,469,381

-9-

Representative Samsung Products
The entire sequence described in Claim 1 is depicted below in a side-by-side
comparison for the Vibrant. As is evident from this comparison, the portions of the
photograph are displayed at the same magnification. (Ex. V3.)

Claim 2 of U.S. Patent No. 7,469,381

- 10 -

Representative Samsung Products
The entire sequence described in Claim 1 is depicted below in a side-by-side
comparison for the Galaxy Tab 10.1. As is evident from this comparison, the portions
of the photograph are displayed at the same magnification. (Ex. V8.)

The computer-implemented method of
claim 1, wherein the first direction is a
vertical direction, a horizontal direction, or
a diagonal direction.

Claim 5 of U.S. Patent No. 7,469,381

The computer-implemented method of
claim 1, wherein the object is a finger.

Claim 4 of U.S. Patent No. 7,469,381

The computer-implemented method of
claim 1, wherein the movement of the
object is on the touch screen display.

Claim 3 of U.S. Patent No. 7,469,381

- 11 -

In the sequences illustrated in Claims 1 and 2, the first direction is a horizontal
direction — specifically, to the right.

Representative Samsung Products

In the sequences illustrated in Claims 1 and 2, the object that moves on the touch
screen display is a finger.

Representative Samsung Products

In the sequences illustrated for Claims 1 and 2, the movement of the finger is on the
touch screen display.

Representative Samsung Products

Representative Samsung Products

- 12 -

The source code for detecting a user’s finger movement, translating an electronic
g
g
,
g
,
g
g
g
,
g
document, detecting a user’s lifting of his finger from the touch screen, and translating
an electronic document in a second direction can be found in the following source code
g
modules in the Galaxy Tab 10.1’s Browser application: WebView.java and View.java.
y
(SAMNDCA-C000003501 – 3549.)

The computer-implemented method of
On the Galaxy Tab 10.1, for example, the method of claim 1 can be performed using a
claim 1, wherein the electronic document is web page. (Ex. V9.)
a web page.

Claim 6 of U.S. Patent No. 7,469,381

Representative Samsung Products

- 13 -

The computer-implemented method of
In the sequence illustrated in Claim 1, the electronic document is a digital image,
claim 1, wherein the electronic document is namely a digital photograph.
a digital image.

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

Representative Samsung Products

- 14 -

The computer-implemented method of
On the Exhibit 4G phone, for example, the method of claim 1 can be performed using a
claim 1, wherein the electronic document is presentation document. (Ex. V7.)
a word processing, spreadsheet, email or
presentation document.

Claim 8 of U.S. Patent No. 7,469,381

The Exhibit 4G phone also includes an application called “Contacts” that displays an
electronic document including a list of items — specifically, a list of contacts — on the
touch screen display. When running the “Contacts” application, the Exhibit 4G phone
performs the method of claim 1. (Ex. V6.)

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

- 15 -

Representative Samsung Products

Claim 9 of U.S. Patent No. 7,469,381

Claim 9 of U.S. Patent No. 7,469,381

- 16 -

Representative Samsung Products
The Captivate also includes an application called “Contacts” that displays an electronic
document including a list of items — specifically, a list of contacts — on the touch
screen display. When running the “Contacts” application, the Captivate performs the
method of claim 1. (Ex. V2.)

Claim 9 of U.S. Patent No. 7,469,381

- 17 -

Representative Samsung Products
The Vibrant also includes an application called “Contacts” that displays an electronic
document including a list of items — specifically, a list of contacts — on the touch
screen display. When running the “Contacts” application, the Vibrant performs the
method of claim 1. (Ex. V4.)

In Exhibits V1, V3, V5, V7, V8, and V9, the areas beyond the edges of the
photographs are black, and the area beyond the edge of the presentation document is
gray. These areas are visually distinct, respectively, from the photographs themselves,
which are in color, and the presentation document, which is white with additional
colors.

The computer-implemented method of
claim 1, wherein the area beyond the edge
of the document is visually distinct from
the document.

- 18 -

Representative Samsung Products

In Exhibits V1, V3, V5, V7, V8, and V9, the areas beyond the edges of the
photographs are black, and the area beyond the edge of the presentation document is
gray.

Representative Samsung Products

In Exhibits V1-V9, the speed of translation of the photograph, contacts list, web page,
or presentation document prior to reaching an edge of the document corresponds to the
speed of movement of the user’s finger.

Representative Samsung Products

In the sequence illustrated in Claim 1, the “first direction” is to the right, while the
“second direction” is opposite, to the left. (See also Exs. V1-V9.)

Representative Samsung Products

Claim 14 of U.S. Patent No. 7,469,381

The computer-implemented method of
claim 1, wherein the area beyond the edge
of the document is black, gray, a solid
color, or white.

Claim 13 of U.S. Patent No. 7,469,381

The computer-implemented 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.

Claim 11 of U.S. Patent No. 7,469,381

The computer-implemented method of
claim 1, wherein the second direction is
opposite the first direction.

Claim 10 of U.S. Patent No. 7,469,381

In Exhibits V1, V3, V5, and V8, as the electronic document scrolls back in the second
direction to fill the screen, it exhibits damped motion and slows as it reaches the end of
its movement.

Representative Samsung Products
In the sequence illustrated in Claim 1, in response to detecting that the finger is no
longer on the touch screen, the Exhibit 4G phone changes from scrolling the
photograph in the first direction (to the right) to scrolling the photograph in the
opposite direction (to the left). This change makes the photograph appear to “snap” or
“bounce” back to the left, as though the photograph were elastically attached to the
edge of the touch screen display. (See also Exs. V1 – V6, V8, V9.)

The computer-implemented method of
claim 1, wherein translating the document
in the second direction is a damped motion.

Claim 16 of U.S. Patent No. 7,469,381

The computer-implemented 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.

- 19 -

Representative Samsung Products

Claim 15 of U.S. Patent No. 7,469,381

- 20 -

Figure 37

Document
Movement

On the Galaxy Tab 10.1, 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 user’s finger prior to reaching the edge of the electronic
document.

The computer-implemented 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 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.

Finger
Movement

Representative Samsung Products

Claim 17 of U.S. Patent No. 7,469,381

Claim 17 of U.S. Patent No. 7,469,381

Finger
Movement

- 21 -

Figure 38

Document
Movement

Representative Samsung Products
When the Galaxy Tab 10.1displays an area beyond the edge of the electronic
document, it translates the electronic document in the first direction for a second
associated translating distance. The second associated translating distance is less than
a distance of movement of the user’s finger after reaching the edge of the electronic
document.

- 22 -

On the Galaxy Tab 10.1, 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 user’s finger. The speed of translation is essentially the
same as the speed with which the user’s finger moves.

The computer-implemented 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.

Figure 39

Representative Samsung Products

Claim 18 of U.S. Patent No. 7,469,381

Claim 18 of U.S. Patent No. 7,469,381

- 23 -

Figure 40

Representative Samsung Products
When the Galaxy Tab 10.1 displays an area beyond the edge of the electronic
document, it translates the electronic document in the first direction at a second
associated translating speed. The second associated translating speed is slower than the
first associated translating speed. The document translates more slowly in the first
direction when the area beyond the edge is displayed.

Representative Samsung Products

- 24 -

(Galaxy Tab 10.1 User Manual (APLNDC-Y0000060376).)

(Captivate User Manual (APLNDC-Y0000062795).)

(Vibrant User Manual (APLNDC-Y0000057339).)

(Exhibit 4G phone User Manual (APLNDC-Y0000066320).)

A device, comprising: a touch screen
The Exhibit 4G phone, Vibrant, Captivate, and Galaxy Tab 10.1 are mobile computing
display; one or more processors; memory;
devices with touch screen displays, processors, and memory.
and 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:

Claim 19 of U.S. Patent No. 7,469,381

Claim 19 of U.S. Patent No. 7,469,381

Vibrant: “1 GHz Cortex A8 Hummingbird Application
Processor” that uses “Android 2.2, Froyo.” (APLNDCY0000066798);
Captivate: “1 GHz, Cortex A8 Hummingbird Processor”
that uses “Android 2.3, Gingerbread.” (APLNDCY0000066835); and
Galaxy Tab 10.1: “1 Ghz Dual Core Nvidia Tegra2
Processor” that uses “Android 3.2, Honeycomb.”
(APLNDC-Y0000066820-821.)

Exhibit 4G: “Internal Memory” of “512 MB.”
(APLNDC-Y0000066850);
Vibrant: “Internal Memory” of “2 GB.” (APLNDCY0000066800);
Captivate: “Internal Memory” of “2 GB.” (APLNDCY0000066836); and
Galaxy Tab 10.1: “16 GB Internal Memory.”
(APLNDC-Y0000066850.)

!

!

!

!
!
!
!

- 25 -

Exhibit 4G: “1-GHz Hummingbird” processor that uses
“Android 2.3, Gingerbread OS.” (APLNDCY0000066850)

!

Representative Samsung Products

instructions for displaying a first portion of
an electronic document;

Claim 19 of U.S. Patent No. 7,469,381

- 26 -

The Exhibit 4G phone includes an application called “Gallery” with instructions for
displaying electronic documents — more specifically, photographs — on the touch
screen display. When running the “Gallery” application, the Exhibit 4G phone
displays a first portion of a photograph. (Ex. V5.)

Representative Samsung Products

The Exhibit 4G phone includes instructions for detecting the movement of an “object”
— for instance, a finger — on its touch screen. In response, it scrolls the photograph in
the same direction to display a second, different portion of the photograph. (Ex. V5.)

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 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;

- 27 -

To the extent that Samsung contends that all instances of translating in the “first
direction” require that the document be translated in the same direction with absolute
precision and that a human finger is incapable of such precise movement, the use of the

The detection of a user’s finger and translation of the electronic document are
g
p
performed in the following source code modules for the Exhibit 4G phone, which runs
g
p
,
Android 2.3: RenderView.java, GLSurfaceView.java, GridLayer.java, and
j ,
j ,
y j ,
GridInputProcessor.java. (
p
j
(SAMNDCA-C000007890-7999.) Similar code for devices
)
running Android 2.2 can be found, for example, at SAMNDCA-C000008045 - 8180.
g
,
p ,
Similar source code for devices running Android 2.1 can be found, for example, at
SAMNDCA-C000007702-7746.

Representative Samsung Products

Claim 19 of U.S. Patent No. 7,469,381

Claim 19 of U.S. Patent No. 7,469,381

- 28 -

Representative Samsung Products
Exhibit 4G phone would nevertheless meet this limitation under the doctrine of
equivalents. Translating a document in a first direction based on the movement of a
human finger with minor irregularity is not substantially different from doing so based
on an absolutely precise movement. Moreover, translating a document in a first
direction based on the movement of a human finger operates to perform substantially
the same function (translating the document), in substantially the same way (by
detecting the movement of an object), to obtain substantially the same result
(translation of a document in a first direction) as translating based on the movement of
an object with absolute precision.

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

Claim 19 of U.S. Patent No. 7,469,381

- 29 -

The detection of a user’s finger and translation of the electronic document are
g
p
performed in the following source code modules: RenderView.java,
g
j ,
GLSurfaceView.java, GridLayer.java, and GridInputProcessor.java. (SAMNDCAj ,
y j ,
p
j
(
C000007890-7999; see also SAMNDCA-C000008045 - 8180; SAMNDCA;
;
C000007702-7746.) The GridInputProcessor.java file identifies the edge of the
)
p
j
photograph and displays an area beyond the edge of the photograph.

The Exhibit 4G phone includes instructions for displaying a black region beyond the
photograph’s edge in response to reaching an edge of a photograph, while a finger
continues to move the photograph in the same direction, and thus displays a third,
smaller portion of the photograph. (Ex. V5.)

Representative Samsung Products

Claim 19 of U.S. Patent No. 7,469,381

- 30 -

To the extent that Samsung contends any of the accused devices contain an AMOLED
screen and that such screen does not “display[] an area beyond the edge” because the
screen does not emit light or otherwise illuminate a black area, such device would
nevertheless meet this limitation under the doctrine of equivalents. Displaying black in
a specific area of a screen by not illuminating the area is not substantially different
from doing so by filtering or blocking light in the area. Moreover, an AMOLED
screen displaying black operates to perform substantially the same function (displaying
a black area), in substantially the same way (avoiding emission of light), to obtain
substantially the same result (showing a black area) as a screen that displays black by
filtering or blocking light.

Representative Samsung Products

The Exhibit 4G phone includes instructions for scrolling the photograph in the opposite
direction until it no longer displays the area beyond the photograph’s edge, in response
to detecting that the finger is no longer on the touch screen. What is then displayed is a
fourth portion of the photograph that is different from the first portion. (Ex. V5.)

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.

- 31 -

The detection of a user’s lifting of his finger from the touch screen and translation of
g
g
the electronic document in a second direction are performed in the following source
p
g
code modules: GridInputProcessor.java and GridCameraManager.java. (
d
p
j
g j
(SAMNDCA(SAMNDCAC000007967-8007; see also SAMNDCA-C000008045-8180; SAMNDCA;
SAMNDCA-C
C000008045-8180;
C000007730-7746; SAMNDCA-C000007781-7786.)

Representative Samsung Products

Claim 19 of U.S. Patent No. 7,469,381

A computer readable storage medium
having stored therein instructions, which
when executed by a device with a touch
screen display, cause the device to:

Claim 20 of U.S. Patent No. 7,469,381

- 32 -

(Captivate User Manual (APLNDC-Y0000062795).)

(Vibrant User Manual (APLNDC-Y0000057339).)

(Exhibit 4G phone User Manual (APLNDC-Y0000066320).)

The Exhibit 4G phone, Vibrant, Captivate, and Galaxy Tab 10.1 are mobile computing
devices with touch screen displays, processors, and memory.

Representative Samsung Products

Claim 20 of U.S. Patent No. 7,469,381

Vibrant: “1 GHz Cortex A8 Hummingbird Application
Processor” that uses “Android 2.2, Froyo.” (APLNDCY0000066798);
Captivate: “1 GHz, Cortex A8 Hummingbird Processor”
that uses “Android 2.3, Gingerbread.” (APLNDCY0000066835); and
Galaxy Tab 10.1: “1 Ghz Dual Core Nvidia Tegra2
Processor” that uses “Android 3.2, Honeycomb.”
(APLNDC-Y0000066820-821.)

Exhibit 4G: “Internal Memory” of “512 MB.”
(APLNDC-Y0000066850);
Vibrant: “Internal Memory” of “2 GB.” (APLNDCY0000066800);
Captivate: “Internal Memory” of “2 GB.” (APLNDCY0000066836); and
Galaxy Tab 10.1: “16 GB Internal Memory.”
(APLNDC-Y0000066850.)

!

!

!

!
!
!
!

- 33 -

Exhibit 4G: “1-GHz Hummingbird” processor that uses
“Android 2.3, Gingerbread OS.” (APLNDCY0000066850)

!

Representative Samsung Products
(Galaxy Tab 10.1 User Manual (APLNDC-Y0000060376).)

display a first portion of an electronic
document;

Claim 20 of U.S. Patent No. 7,469,381

- 34 -

The Exhibit 4G phone includes an application called “Gallery” that displays electronic
documents — more specifically, photographs — on the touch screen display. When
running the “Gallery” application, the Exhibit 4G phone displays a first portion of a
photograph. (Ex. V5.)

Representative Samsung Products

The Exhibit 4G phone detects the movement of an “object” — for instance, a finger —
on its touch screen. In response, it scrolls the photograph in the same direction to
display a second, different portion of the photograph. (Ex. V5.)

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;

- 35 -

To the extent that Samsung contends that all instances of translating in the “first
direction” require that the document be translated in the same direction with absolute
precision and that a human finger is incapable of such precise movement, the use of the

The detection of a user’s finger and translation of the electronic document are
g
p
performed in the following source code modules for the Exhibit 4G phone, which runs
g
p
,
Android 2.3: RenderView.java, GLSurfaceView.java, GridLayer.java, and
j ,
j ,
y j ,
GridInputProcessor.java. (
p
j
(SAMNDCA-C000007890-7999.) Similar code for devices
)
running Android 2.2 can be found, for example, at SAMNDCA-C000008045-8180.
g
,
p ,
Similar source code for devices running A
Android 2.1 can be found, for example, at
SAMNDCA-C000007702-7746.

Representative Samsung Products

Claim 20 of U.S. Patent No. 7,469,381

Claim 20 of U.S. Patent No. 7,469,381

- 36 -

Representative Samsung Products
Exhibit 4G phone would nevertheless meet this limitation under the doctrine of
equivalents. Translating a document in a first direction based on the movement of a
human finger with minor irregularity is not substantially different from doing so based
on an absolutely precise movement. Moreover, translating a document in a first
direction based on the movement of a human finger operates to perform substantially
the same function (translating the document), in substantially the same way (by
detecting the movement of an object), to obtain substantially the same result
(translation of a document in a first direction) as translating based on the movement of
an object with absolute precision.

In response to reaching an edge of a photograph, while a finger continues to move the
photograph in the same direction, the Exhibit 4G phone displays a black region beyond
the photograph’s edge, and thus displays a third, smaller portion of the photograph.
(Ex. V5.)

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 display; and

- 37 -

The detection of a user’s finger and translation of the electronic document are
g
p
performed in the following source code modules: RenderView.java,
g
d
j ,
GLSurfaceView.java, GridLayer.java, and GridInputProcessor.java. (SAMNDCAj ,
y j ,
p
j
(
C000007890-7999; see also SAMNDCA-C000008045 - 8180; SAMNDCA;
;
C000007702-7746.) The GridInputProcessor.java file identifies the edge of the
)
p
j
photograph and displays an area beyond the edge of the photograph.

Representative Samsung Products

Claim 20 of U.S. Patent No. 7,469,381

Claim 20 of U.S. Patent No. 7,469,381

- 38 -

To the extent that Samsung contends any of the accused devices contain an AMOLED
screen and that such screen does not “display[] an area beyond the edge” because the
screen does not emit light or otherwise illuminate a black area, such device would
nevertheless meet this limitation under the doctrine of equivalents. Displaying black in
a specific area of a screen by not illuminating the area is not substantially different
from doing so by filtering or blocking light in the area. Moreover, an AMOLED
screen displaying black operates to perform substantially the same function (displaying
a black area), in substantially the same way (avoiding emission of light), to obtain
substantially the same result (showing a black area) as a screen that displays black by
filtering or blocking light.

Representative Samsung Products

In response to detecting that the finger is no longer on the touch screen, the Exhibit 4G
phone scrolls the photograph in the opposite direction until it no longer displays the
area beyond the photograph’s edge. What is then displayed is a fourth portion of the
photograph that is different from the first portion. (Ex. V5.)

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.

- 39 -

The detection of a user’s lifting of his finger from the touch screen and translation of
g
g
the electronic document in a second direction are performed in the following source
p
g
code modules: GridInputProcessor.java and GridCameraManager.java. (SAMNDCAp
j
g j
(
C000007967-8007; see also SAMNDCA-C000008045-8180; SAMNDCA;
SAMNDCA-C000008045-8
8180;
C000007730-7746; SAMNDCA-C000007781-7786.)

Representative Samsung Products

Claim 20 of U.S. Patent No. 7,469,381