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

Filing 1430

JOINT STATEMENT REGARDING JURY BINDER by Apple Inc.. (Attachments: # 1 Exhibit 1)(Jacobs, Michael) (Filed on 7/28/2012) Modified text on 7/30/2012 (dhm, COURT STAFF).

EXHIBIT 1

CHART OF ASSERTED UTILITY PATENT CLAIMS AND CLAIM CONSTRUCTIONS
Apple’s ’381 Patent
Claim 19
A device, comprising:

Apple’s Proposal
The term “displaying” means “showing or
revealing to the viewer.”

Samsung’s Proposal
Agreed.

a touch screen display;
* * * *

* * * *
one or more processors;
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:
instructions for displaying a first portion of
an electronic document;
instructions for detecting a movement of
an object on or near the touch screen
display;

The term “first direction” does not require
a strictly linear finger movement.

Agreed.

* * * *

* * * *

The term “electronic document” means “a
document stored in a digital format.” An
“electronic document” includes, but is not
limited to, a web page; a digital image; a
word processing, spreadsheet or
presentation document; or a list of items in
a digital format.

The term “electronic document” means “a
document stored in a digital format. An
‘electronic document’ includes, but is not
limited to, a web page; a digital image; a
word processing, spreadsheet or
presentation document; or a list of items in
a digital format.” An electronic document
need not be stored in a single file.

(Dkt. No. 1266, 7/20/12 Order Construing
Disputed Claim Terms at 6:23-26.)

(Docket No. 1266, 7/20/12 Order
Construing Disputed Claim Terms at 6:5-7
(“This conclusion – that an electronic
document need not be stored in a single
file or location – is consistent with the
Court’s April 2012 Claim Construction
Order.”), 23-26.

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
1

the movement;
* * * *
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
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.

* * * *

The term “edge of the electronic
Agreed.
document” has its plain and ordinary
meaning. An edge of an electronic
document is not limited to an external edge
and may be internal.
* * * *

* * * *

The term “translating the electronic
document in a second direction” was not
proposed for construction, or construed,
and therefore has its plain and ordinary
meaning.

The term “translating the electronic
document in a second direction…” means
“when a user scrolls past the edge of the
electronic document, the electronic
document must always snap back when the
user lifts her finger.”

Samsung’s proposal is not a construction
of any term by the Court from asserted
device claim 19 of the ’381 patent. See
Dkt. No. 452, 12/2/11 Order Denying
Preliminary Injunction at 60:17-24 (“As
written, Claim 1 of the ’381 patent is
fatalistic . . . [b]ecause the claimed method
explicitly defines the inputs which will
trigger the snap-back response, the method
incorporates the response to all such inputs
as a limitation of the claim”) (emphases
added).

(Docket No. 449, 12/2/11 Order
Denying Preliminary Injunction at 59:6-7
(“The ‘381 patent contains no second
behavior when a user scrolls past a certain
threshold; the screen must always snap
back.”); 60:17-19 (“As written, Claim 1 of
the ‘381 patent is fatalistic: if a user
scrolls past the edge of an electronic
document in the first direction, the screen
must snap back to that document when the
user lifts her finger.”)

2

Apple’s ’915 Patent
Claim 8

Agreed Language for Jury Binder

A machine readable storage medium storing executable program
instructions which when executed cause a data processing system to
perform a method comprising:

The term “invokes” means “causes” or “causes a
procedure to be carried out.”
* * * *

receiving a user input, the user input is one or more input points applied
to a touch-sensitive display that is integrated with the data processing
system;
creating an event object in response to the user input;
determining whether the event object invokes a scroll or gesture
operation by distinguishing between a single input point applied to
the touch-sensitive display that is interpreted as the scroll operation
and two or more input points applied to the touch-sensitive display
that are interpreted as the gesture operation;
issuing at least one scroll or gesture call based on invoking the scroll or
gesture operation;
responding to at least one scroll call, if issued, by scrolling a window
having a view associated with the event object; and
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.

3

The term “scrolling a window having a view associated
with the event object” has its plain and ordinary meaning.

Apple’s ’163 Patent
Claim 50
A portable electronic device, comprising:
a touch screen display;
one or more processors;

Apple’s Proposal
The Court has not construed any
terms from this patent, and
therefore the terms from this
patent should be given their plain
and ordinary meaning.

memory; and
(Dkt. No. 1266, 7/20/12 Order
one or more programs, wherein the one or more programs are Construing Disputed Claim Terms
at 9:15-17 (“Accordingly, no
stored in the memory and configured to be executed by
construction is necessary for the
the one or more processors, the one or more programs
term ‘structured electronic
including;
document’”.)
instructions for displaying at least a portion of a structured
electronic document on the touch screen display, wherein
the structured electronic document comprises a plurality
of boxes of content;
instructions for 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;
instructions for enlarging and translating the structured
electronic document so that the first box is substantially
centered on the touch screen display;

4

Samsung’s Proposal
The term “electronic document”
means “a document stored in a
digital format. An electronic
document includes, but is not
limited to, a web page; a digital
image; a word processing,
spreadsheet or presentation
document; or a list of items in a
digital format. An electronic
document need not be stored in a
single file.
(Docket No. 1266,
7/20/12 Order Construing
Disputed Claim Terms at 6:5-7
(“This conclusion – that an
electronic document need not be
stored in a single file or location
– is consistent with the Court’s
April 2012 Claim Construction
Order.”), 23-26.)

instruction for, while the first box is enlarged, detecting a
second gesture on a second box other than the first box;
and
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.

5

Samsung’s ’460 Patent
Claim 1
A data transmitting method for a portable
composite communication terminal which
functions as both a portable phone and a
camera, comprising the steps of:

Apple’s Proposal

Samsung’s Proposal

The Court has not construed any terms
from this patent, and therefore the terms
from this patent should be given their plain
and ordinary meaning.

The Court has construed the claim to
require three functions: sending an e-mail
transmission with a message from a first
e-mail submode; sending an e-mail
transmission with an image and a message
from a second e-mail sub-mode; and
sequentially displaying other images with
a scroll key. The Court has further
determined that the steps of the ‘460
Patent do not need to be performed in
order.

entering a first E-mail transmission
sub-mode upon user request for E-mail
transmission while operating in a
portable phone mode, the first e-mail
transmission sub-mode performing a
portable phone function;
entering a second E-mail transmission
sub-mode upon user request for E-mail
transmission while operating in a
display sub-mode, the second e-mail
transmission sub-mode displaying an
image most recently captured in a
camera mode;

(Docket No. 1156, 6/29/12 Order
Denying In Part Apple’s Motion For
Partial Summary Judgment at 17 :3-6
(“The Court adopts Samsung’s
construction of claim 1, which is also the
first alternative proposed by Apple. The
first construction adopted by the Court
excludes the other two proposed
constructions, and therefore the Court
need not consider the two alternative
constructions proposed by Apple.”);
15:22-26 (“Moreover, claim 1, read in
light of the specification and prosecution
history, only meets the construction
offered by Samsung. Samsung argues that
claim 1 establishes three functionalities:

sequentially displaying other images
stored in a memory through the use of
scroll keys;
transmitting the address of the other
party and a message received through a
user interface in the first E-mail
transmission sub-mode; and
transmitting the address of the other
party and the message received through
6

the user interface and the image
displayed on the display as an E-mail in
the second E-mail transmission submode.

sending an e-mail transmission from a
first e-mail submode; sending an e-mail
transmission with an image from a second
e-mail sub-mode; and sequentially
displaying other images with a scroll
key.”).)

7

Samsung’s ’711 Patent
Claim 9
A multi-tasking apparatus in a pocket-sized mobile
communication device including an MP3 playing
capability, the multi-tasking apparatus comprising:
a controller for generating a music background
play object, wherein the music background play
object includes an application module including at
least one applet, for providing an interface for
music play by the music background play object,
for selecting an MP3 mode in the pocket-sized
mobile communication device using the interface,
for selecting and playing a music file in the
pocket-sized mobile communication device in the
MP3 mode, for switching from the MP3 mode to
a standby mode while the playing of the music
file continues and for selecting and performing at
least one function of the pocket-sized mobile
communication device from the standby mode
while the playing of the music file continues; and

Apple’s Proposal

Samsung’s Proposal

The term “applet” means “an
application designed to run within an
application module.”

The term “applet” means “an
application designed to run within an
application module that need not be
operating system-independent.”

(Dkt. 849, 4/4/12 Order Construing
Disputed Claim Terms at 11:5-6
(“Accordingly, the Court construes
'applet' to mean “An application
designed to run within an
application module.”) (emphasis in
original).)

(Docket No. 848, 4/4/12
Order Construing Disputed Claim
Terms at 11:5-6; 8:10-11
(“Therefore, it is inappropriate to
include the limitation of operating
system-independence urged by
Apple.”).)

a display unit for displaying an indication that the
music file is being played in the standby mode
and for continuing to display the indication that
the music file is being played while performing
the selected function.

8

Samsung’s ’893 Patent
Claim 10

Agreed Language for Jury Binder

A digital image processing apparatus comprising:
an optical system for receiving a light reflected from a subject;
a photoelectric conversion module in optical communication with the
optical system for converting the light to image data;
a recording medium for storing the image data in an image file;
a display screen for displaying the image data; and
a controller connected with the photoelectric conversion module, the
recording medium and the display screen, the controller being operative in
a photographing mode to process the image data for storage in the
recording medium and, in a stored-image display mode, being operative to
control the display screen for displaying a single image relative to the
image data,
wherein upon a user performing a mode-switching operation defined by
switching from the stored-image display mode to the photographing mode
and back to the stored-image display mode the controller causes the display
screen to first display a single image file that was most recently displayed
before the mode-switching operation, the single image file being different
from a most-recently stored image file, and the single image file being first
displayed irrespective of a duration that the camera was used in the
photographing mode during the mode-switching operation

9

The Court has not construed any terms from this
patent, and therefore the terms from this patent
should be given their plain and ordinary meaning.

Samsung’s ’941 Patent
Claim 10

Agreed Language for Jury Binder

An apparatus for transmitting data in a mobile communication system,
comprising:
a transmission buffer for receiving a service data unit (SDU) from a higher
layer, determining whether the SDU can be comprised in one protocol data
unit (PDU) segmenting the SDU into a plurality of segments according to a
transmittable PDU size if the SDU does not be comprised in one PDU, and
constructing one or more PDUs;
a header inserter for constructing a header of each PDU, wherein the
header comprises a serial number (SN) field, a one-bit field, at least one
Length Indicator (LI) field; a one-bit field setter for setting the one-bit field
of the at least one PDU to indicate whether the PDU contains an entire
SDU in the data field;
an LI inserter for inserting an LI field after the one-bit field in the at least
one PDU if the SDU is not comprised in one PDU, and setting an LI field
to a predefined value indicating that the PDU contains neither a first
segment nor a last segment of the SDU to contain the intermediate segment
of the SDU; and
a transmitter for sending the PDUs to a receiver

10

The Court has not construed any terms from this
patent, and therefore the terms from this patent
should be given their plain and ordinary meaning.

Samsung’s ’941 Patent
Claim 15

Agreed Language for Jury Binder

An apparatus for receiving data in a mobile communication system,
comprising:
a reception buffer for receiving a protocol data unit (PDU) from a
transmitter and storing the PDU;
a reassembly controller for detecting a sequence number (SN) field and a
one-bit field indicating whether the PDU contains an entire service data
unit (SDU) in its data field from the header, detecting the following length
indicator (LI) field from the header of the PDU and determining whether
the LI field is set to a predefined value indicating that the PDU contains an
intermediate segment that is neither a first segment nor a last segment of
the SDU if the one-bit field indicates that the PDU does not contain an
entire SDU in its data field;
a header and LI remover for eliminating the SN field, the one-bit field, and
the LI field if the one-bit field indicates that the PDU does not contain the
entire SDU in its data field; and
a reassembler for receiving the intermediate segment from the header and
LI remover and constructing the SDU by combining the intermediate
segment with at least one previous segment extracted from a data field of at
least one previous PDU and at least one following segment extracted from
a data field of at least one following PDU.

11

The Court has not construed any terms from this
patent, and therefore the terms from this patent
should be given their plain and ordinary meaning.

Samsung’s ’516 Patent
Claim 15

Agreed Language for Jury Binder

An apparatus for transmitting data of a first channel not supporting Hybrid
Automatic Repeat reQuest (HARQ) and a second channel supporting the
HARQ in a mobile telecommunication system which supports an enhanced
uplink service, the apparatus comprising:

The Court has not construed any terms from this
patent, and therefore the terms from this patent
should be given their plain and ordinary meaning.

a controller for determining transmit power factors for the channels,
determining if total transmit power required for transmission of the
channels exceeds the maximum allowed power, and scaling down the
transmit power factor for the second channel if the total transmit power
exceeds the maximum allowed power;
first and second channel generators for generating first and second data
frames by performing channel-coding and modulation of the first and
second channel data; and
a gain scaling unit for adjusting the transmit powers of the first and second
channels, with which the data frames of the first and second channels is
transmitted, using the scaled transit power factor for the second channel
and the transmit power factor for the first channel.
Claim 16

Agreed Language for Jury Binder

The apparatus as claimed in claim 15, wherein the controller scales the
transmit power factor for the second channel from slot to slot when the total
transmit power exceeds the maximum allowed power.

12

The Court has not construed any terms from this
patent, and therefore the terms from this patent
should be given their plain and ordinary meaning.