Apple Inc. v. Samsung Electronics Co. Ltd. et al
Filing
1586
EXHIBITS re 1585 Objection, Ex. A to Ketan Decl filed bySamsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Related document(s) 1585 ) (Maroulis, Victoria) (Filed on 8/6/2012)
EXHIBIT A
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
1
TABLE OF CONTENTS
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I.
II.
III.
IV.
V.
Page
INTRODUCTION .............................................................................................................. 1
QUALIFICATIONS ........................................................................................................... 1
MATERIALS CONSIDERED ........................................................................................... 4
LEGAL PRINCIPLES ........................................................................................................ 6
DETAILED OPINION REGARDING THE ’381 PATENT ............................................. 9
A.
The ’381 Patent ..................................................................................................... 10
B.
Person of Ordinary Skill in the Art ....................................................................... 12
C.
Apple’s Practice Of The ’381 Patent .................................................................... 12
D.
Samsung’s Emulation Of Apple And The Features Of The ’381 Patent .............. 13
E.
Samsung’s Knowledge of the ’381 Patent ............................................................ 17
F.
Samsung’s Infringement of Claim 1 of the ’381 Patent........................................ 17
G.
Samsung’s Infringement of Claim 2 of the ’381 Patent........................................ 27
H.
Samsung’s Infringement of Claim 3 of the ’381 Patent........................................ 28
I.
Samsung’s Infringement of Claim 4 of the ’381 Patent........................................ 28
J.
Samsung’s Infringement of Claim 5 of the ’381 Patent........................................ 28
K.
Samsung’s Infringement of Claim 6 of the ’381 Patent........................................ 29
L.
Samsung’s Infringement of Claim 7 of the ’381 Patent........................................ 30
M.
Samsung’s Infringement of Claim 8 of the ’381 Patent........................................ 30
N.
Samsung’s Infringement of Claim 9 of the ’381 Patent........................................ 32
O.
Samsung’s Infringement of Claim 10 of the ’381 Patent...................................... 33
P.
Samsung’s Infringement of Claim 11 of the ’381 Patent...................................... 34
Q.
Samsung’s Infringement of Claim 13 of the ’381 Patent...................................... 35
R.
Samsung’s Infringement of Claim 14 of the ’381 Patent...................................... 36
S.
Samsung’s Infringement of Claim 15 of the ’381 Patent...................................... 37
T.
Samsung’s Infringement of Claim 16 of the ’381 Patent...................................... 38
U.
Samsung’s Infringement of Claim 17 of the ’381 Patent...................................... 39
V.
Samsung’s Infringement of Claim 18 of the ’381 Patent...................................... 41
W.
Samsung’s Infringement of Claim 19 of the ’381 Patent...................................... 42
X.
Samsung’s Infringement of Claim 20 of the ’381 Patent...................................... 51
Y.
Difficulty of Design Around ................................................................................. 58
Z.
Non-Infringement Contentions ............................................................................. 59
AA. Supplementation.................................................................................................... 62
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i
Apple v. Samsung
Confidential – Attorneys’ Eyes Only
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attempts to scroll the electronic document beyond its edge, the iPhone 4 displays an area beyond
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the edge of the electronic document along with a third smaller portion of the electronic document.
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When the user lifts his finger from the touch screen, the electronic document moves back into
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place to fill the screen, and a fourth portion of the electronic document different from the first
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portion is displayed.
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49.
Based on my examination of the aforementioned Apple products, I conclude that
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they practice the asserted apparatus and system claims of the ’381 patent, and their ordinary and
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intended use practices the asserted method claims of the ’381 patent. I have examined portions of
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the source code for Apple’s iOS version 4.1 operating system and confirmed the behavior I saw
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on the iPhone 4 in the following source code modules: the UIScrollView class or subclass (for
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example, UIWebBrowserView and UIWebDocumentView); the touch panel (e.g., Grape) driver;
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UIKit classes; IOKit classes; SBHIDinterface.m; the SpringBoard application; and
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UIPanGestureRecognizer class or subclasses.
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50.
Moreover, my examination was further confirmed by the testimony of the inventor
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of the ’381 patent, Bas Ording, who testified generally that certain applications on an iPhone 4
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behaved in a manner consistent with his ideas in the ’381 patent. (Ording 8/9/11 Dep. Tr. at
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198:6 – 201:3.)
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D.
Samsung’s Emulation Of Apple And The Features Of The ’381 Patent
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51.
I have also reviewed a number of documents produced by Samsung in this
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litigation, including analyses of features in Apple products and email messages. Based on my
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review of these documents, it appears that Samsung studied a number of Apple products that
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embody the asserted claims of the ’381 patent, recognized the benefits of the ’381 patent, and
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implemented the features of the ’381 patent in Samsung products.
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52.
As just one example, in the document titled “Behold3 Usability Evaluation
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Results” (SAMNDCA00508318 – 508411), Samsung evaluated its Behold3 phone against
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Apple’s iPhone. (SAMNDCA00508331; see translations of excerpts in Apple’s Appendix of
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Certified Translations in Support of Opening Expert Reports (“Translations App’x”).) This
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evaluation concluded that Samsung’s “Behold3 [was] shown inferior to Apple’s iPhone in both
EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK
13
Apple v. Samsung
Confidential – Attorneys’ Eyes Only
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the task success rate (68.5%) and satisfaction score (86).” (SAMNDCA00508333.) On a page
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titled “Aesthetics_Browsing,” the document notes that the iPhone has “a ‘bouncing’ visual
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effect,” which “generates fun for the user,” while the Behold3 has “no visual effect” when “a web
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page is dragged to its endpoint.” (SAMNDCA00508383.) On that page, there is a side by side
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comparison between the Behold3 and the iPhone, where the rubber-banding feature of the ’381
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patent is being demonstrated on a web page displayed on the iPhone. (Id.) Specifically, the
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displayed web page is being pulled to the upper right hand corner, revealing an area beyond the
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edge of the web page to the left and below. (Id.) The caption notes that “If a web page is
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dragged to the edge, and the hand is released, a ‘bouncing’ visual effect is provided.” At the
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bottom of the page, following the column “Direction of Improvement,” is a direction to “Provide
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a fun visual effect when dragging a web page.” (Id.) Based on the existence of this feature in the
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Samsung devices I examined, it appears that this instruction was carried out.
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53.
As another example, in the document titled “P5 Usability Evaluation Results”
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(SAMNDCA00176053 – 176171; see translation of excerpts in Translations App’x), Samsung
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evaluated a prototype of its “GT-P7300” (the Galaxy Tab 8.9) against Apple’s iPad 2.
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(SAMNDCA00176053.) The document notes that the “GUI and Visual Effect are lacking in
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comparison to iPad 2.” (SAMNDCA00176055.) Subsequently, the evaluation notes that when a
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Browser application window is scrolled to the top or bottom, the P5 “lack[s] bounce effect,” and
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that the Samsung’s product “Lacks Fun, Wow Effect.” (SAMNDCA00176071.) This issue
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appears to have been designated “Critical,” with the direction that the “Bounce effect is scheduled
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to be reviewed.” (Id.) Later in the evaluation, there is a side by side comparison between the P5
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and the iPad 2, where the rubber-banding feature of the ’381 patent is being demonstrated on a
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web page displayed on the iPad 2. (SAMNDCA00176125.) Specifically, the displayed web page
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is being pulled to the lower right hand corner, revealing an area beyond the edge of the web page
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to the left and above. (Id.) To the right, it states that “In case of iPad 2, there is a fun element
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from a natural Bounce effect that follows hand gestures.” (Id.) Based on this statement, it
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appears that Samsung understood at least part of the purpose and value of the rubber banding
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feature of the ’381 patent, which were to provide a natural, intuitive experience for the user that
EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK
14
Apple v. Samsung
Confidential – Attorneys’ Eyes Only
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could also inspire wonder and a sense of delight. On the other hand, the P5 prototype is described
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as lacking the “Bounce effect.” (Id.) Finally, the evaluation notes as an area for “Proposed
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Improvement” of the P5 the incorporation of the “Bounce effect” from the iPad 2. (Id.)
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54.
I have also reviewed a spreadsheet titled “Analysis of Galaxy tab Operation Speed
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and Screen Effects” (SAMNDCA00201771 – 201780; see translation in Translations App’x.)
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This ten-page chart shows a detailed side-by-side comparison and analysis of over 70 features in
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the iPad and the Galaxy Tab. Samsung concluded that its Memo and Browser applications had
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“no emotional impact” because they lacked the “Bounce effect” included in the iPad.
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(SAMNDCA00201773-6.) As discussed above, the “bouncing” or “bounce” feature described in
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Samsung’s documents is an example of a feature covered by the ’381 patent. Based on my
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analysis of the Galaxy Tab and Galaxy Tab 10.1, I conclude that Samsung implemented this
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feature in the Galaxy Tab and Galaxy Tab 10.1 products as well.
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55.
I understand that Samsung has identified Mr. Wookyun Kho as a person involved
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in the implementation of the “bounce” feature in Samsung products. (See Samsung’s
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Supplemental Response to Apple’s Interrogatory No. 16.) Based on Samsung emails and the
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portions of the Wookyun Kho deposition transcript I reviewed, it appears that Mr. Kho studied
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the “bounce” or “bouncing” feature in various Apple products including the iPhone 3GS, iPhone
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4, iPad, and iPad 2 in order to improve Samsung’s products. (See, e.g., W. Kho 1/12/12 Dep. Tr.
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at 40:1-44:11, 48:18-49:21.) In particular, Mr. Kho appears to have worked with an outside
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contractor company called NemusTech to emulate the features of the iPad and make the “bounce
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effect” in Samsung’s Galaxy Tab prototype similar to the iPad. (SAMNDCA10851706-7;
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SAMNDCA10850604-6; see translations in Translations App’x.)
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56.
Other documents I have reviewed also indicate that Samsung carried out extensive
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analysis of various Apple products and emulated many of Apple’s features beyond the ’381
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patent features discussed above. For example, in December 2007, Samsung analyzed various
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multi-touch features of the iPhone and compared the iPhone with non-touch-based phones from
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other competitors. (SAMNDCA11394122-26; see translation of excerpts in Translations App’x.)
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Observing that the iPhone represented a “new paradigm” in the mobile phone market and
EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK
15
Apple v. Samsung
Confidential – Attorneys’ Eyes Only
1
provided “Intuitive, Inventive UI,” Samsung considered an internal development proposal for
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implementing the touch features of the iPhone, including multi-touch features, in its future
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products. (SAMNDCA11394125, 31, 32.)
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57.
In April 2008, Samsung compared the iPhone and the phones from other
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competitors with its products. (SAMNDCA00229011-108.) None of the phones from Samsung
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or other competitors had the iPhone’s multi-touch user interface. (SAMNDCA00229018.)
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Samsung remarked that the iPhone had a “highly animated interface,” and that it was “a delight to
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the eye as well as a highly usable device.” (SAMNDCA00229020.) Samsung conducted many
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more detailed studies of the iPhone user interface from 2008 to 2010 comparing it with various
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Samsung products and/or other competitors’ products. (SAMDNCA10248844-913;
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SAMNDCA10244357-412; SAMNDCA10993206-211; SAMNDCA10252803-841;
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SAMNDCA10988469-504.)
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58.
Although Samsung looked at phones from most of its competitors, Samsung had
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decided by the end of 2009 to follow the design of the iPhone. For example, the “CEO’s
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Directives” given out in December 2009 included a direction that “[g]oing forward our
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comparison standard is Apple iPhone.” (SAMNDCA10907803; see translation in Translations
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App’x.) In March 2010, an email from a high level UX (user experience) designer at Samsung
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conveyed the CEO’s message that “strongly criticized Samsung UX’s mindset of ‘clinging to the
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past generation’,” which the designer interpreted as an “instruction to think about and decide all
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matters from the perspective of the user,” the most representative example of which was
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“obviously the iPhone.” (SAMNDCA10247549; see translation in Translations App’x.)
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59.
A Samsung report dated April 2, 2010, titled “Next Phase UX Direction”
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summarized the status of the Samsung UX as: “Benchmarking iPhone led to cut and paste
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improvements resulting in lack of consistent philosophy.” (SAMNDCA10998232; see translation
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of excerpts in Translations App’x.) The same document characterized the “Philosophy and
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Characteristics” of the iPhone’s UX as “Easy and simple Usability,” “Modern and minimal Look
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& style,” and “Emotional and joyful Experiencing.” (SAMNDCA10998214.) I understand that
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Samsung’s Galaxy S phone was released in the United States during the summer of 2010.
EXPERT REPORT OF RAVIN BALAKRISHNAN, PH.D. REGARDING INFRINGEMENT OF THE ‘381 PATENT
Case No. 11-cv-01846-LHK
16
Apple v. Samsung
Confidential – Attorneys’ Eyes Only
1
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
17
EXHIBIT 3
Exhibit 3 – Infringement Claim Chart for U.S. Patent No. 7,469,381
Claim 1 of U.S. Patent No. 7,469,381
A computer-implemented method,
comprising: at a device with a touch screen
display:
Representative Samsung Products
The Exhibit 4G phone is a mobile computing device with a touch screen display.
(Exhibit 4G phone User Manual (APLNDC-Y0000066320).)
(Vibrant User Manual (APLNDC-Y0000057339).)
(Captivate User Manual (APLNDC-Y0000062795).)
-1-
Claim 1 of U.S. Patent No. 7,469,381
Representative Samsung Products
(Galaxy Tab 10.1 User Manual (APLNDC-Y0000060376).)
displaying a first portion of an electronic
document;
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.)
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
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.)
-2-
Claim 1 of U.S. Patent No. 7,469,381
document, wherein the second portion is
different from the first portion;
Representative Samsung Products
The detection of a user’s finger and translation of the electronic document are
performed in the following source code modules for the Exhibit 4G phone, which runs
Android 2.3: RenderView.java, GLSurfaceView.java, GridLayer.java, and
GridInputProcessor.java. (SAMNDCA-C000007890-7999.) 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.
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
-3-
Claim 1 of U.S. Patent No. 7,469,381
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.
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
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.)
The detection of a user’s finger and translation of the electronic document are
performed in the following source code modules: RenderView.java,
-4-
Claim 1 of U.S. Patent No. 7,469,381
Representative Samsung Products
GLSurfaceView.java, GridLayer.java, and GridInputProcessor.java. (SAMNDCAC000007890-7999; see also SAMNDCA-C000008045 - 8180; SAMNDCAC000007702-7746.) The GridInputProcessor.java file identifies the edge of the
photograph and displays an area beyond the edge of the photograph.
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.
-5-
Claim 1 of U.S. Patent No. 7,469,381
Representative Samsung Products
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.
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.)
The detection of a user’s lifting of his finger from the touch screen and translation of
the electronic document in a second direction are performed in the following source
code modules: GridInputProcessor.java and GridCameraManager.java. (SAMNDCAC000007967-8007; see also SAMNDCA-C000008045-8180; SAMNDCAC000007730-7746; SAMNDCA-C000007781-7786.)
-6-
Claim 2 of U.S. Patent No. 7,469,381
Representative Samsung Products
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.
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.)
-7-
Claim 2 of U.S. Patent No. 7,469,381
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.)
-8-
Claim 2 of U.S. Patent No. 7,469,381
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.)
-9-
Claim 2 of U.S. Patent No. 7,469,381
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.)
- 10 -
Claim 3 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.
Representative Samsung Products
In the sequences illustrated for Claims 1 and 2, the movement of the finger is on the
touch screen display.
Claim 4 of U.S. Patent No. 7,469,381
The computer-implemented method of
claim 1, wherein the object is a finger.
Representative Samsung Products
In the sequences illustrated in Claims 1 and 2, the object that moves on the touch
screen display is a finger.
Claim 5 of U.S. Patent No. 7,469,381
The computer-implemented method of
claim 1, wherein the first direction is a
vertical direction, a horizontal direction, or
a diagonal direction.
Representative Samsung Products
In the sequences illustrated in Claims 1 and 2, the first direction is a horizontal
direction — specifically, to the right.
- 11 -
Claim 6 of U.S. Patent No. 7,469,381
Representative Samsung Products
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.
The source code for detecting a user’s finger movement, translating an electronic
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
modules in the Galaxy Tab 10.1’s Browser application: WebView.java and View.java.
(SAMNDCA-C000003501 – 3549.)
- 12 -
Claim 7 of U.S. Patent No. 7,469,381
Representative Samsung Products
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.
- 13 -
Claim 8 of U.S. Patent No. 7,469,381
Representative Samsung Products
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.
- 14 -
Claim 9 of U.S. Patent No. 7,469,381
The computer-implemented method of
claim 1, wherein the electronic document
includes a list of items.
Representative Samsung Products
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.)
- 15 -
Claim 9 of U.S. Patent No. 7,469,381
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.)
- 16 -
Claim 9 of U.S. Patent No. 7,469,381
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.)
- 17 -
Claim 10 of U.S. Patent No. 7,469,381
The computer-implemented method of
claim 1, wherein the second direction is
opposite the first direction.
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.)
Claim 11 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.
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.
Claim 13 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.
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.
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 visually distinct from
the document.
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. These areas are visually distinct, respectively, from the photographs themselves,
which are in color, and the presentation document, which is white with additional
colors.
- 18 -
Claim 15 of U.S. Patent No. 7,469,381
Representative Samsung Products
The computer-implemented method of
claim 1, wherein translating the document
in the second direction is a damped motion.
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.
Claim 16 of U.S. Patent No. 7,469,381
Representative Samsung Products
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.
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.)
- 19 -
Claim 17 of U.S. Patent No. 7,469,381
Representative Samsung Products
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.
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.
Finger
Movement
Figure 37
- 20 -
Document
Movement
Claim 17 of U.S. Patent No. 7,469,381
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.
Finger
Movement
Figure 38
- 21 -
Document
Movement
Claim 18 of U.S. Patent No. 7,469,381
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.
Representative Samsung Products
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.
Figure 39
- 22 -
Claim 18 of U.S. Patent No. 7,469,381
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.
Figure 40
- 23 -
Claim 19 of U.S. Patent No. 7,469,381
Representative Samsung Products
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:
(Exhibit 4G phone User Manual (APLNDC-Y0000066320).)
(Vibrant User Manual (APLNDC-Y0000057339).)
(Captivate User Manual (APLNDC-Y0000062795).)
(Galaxy Tab 10.1 User Manual (APLNDC-Y0000060376).)
- 24 -
Claim 19 of U.S. Patent No. 7,469,381
Representative Samsung Products
Exhibit 4G: “1-GHz Hummingbird” processor that uses
“Android 2.3, Gingerbread OS.” (APLNDCY0000066850)
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 -
Claim 19 of U.S. Patent No. 7,469,381
instructions for displaying a first portion of
an electronic document;
Representative Samsung Products
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.)
- 26 -
Claim 19 of U.S. Patent No. 7,469,381
Representative Samsung Products
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;
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.)
The detection of a user’s finger and translation of the electronic document are
performed in the following source code modules for the Exhibit 4G phone, which runs
Android 2.3: RenderView.java, GLSurfaceView.java, GridLayer.java, and
GridInputProcessor.java. (SAMNDCA-C000007890-7999.) 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.
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
- 27 -
Claim 19 of U.S. Patent No. 7,469,381
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.
- 28 -
Claim 19 of U.S. Patent No. 7,469,381
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
Representative Samsung Products
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.)
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. (SAMNDCAC000007890-7999; see also SAMNDCA-C000008045 - 8180; SAMNDCAC000007702-7746.) The GridInputProcessor.java file identifies the edge of the
photograph and displays an area beyond the edge of the photograph.
- 29 -
Claim 19 of U.S. Patent No. 7,469,381
Representative Samsung Products
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.
- 30 -
Claim 19 of U.S. Patent No. 7,469,381
Representative Samsung Products
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 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.)
The detection of a user’s lifting of his finger from the touch screen and translation of
the electronic document in a second direction are performed in the following source
code modules: GridInputProcessor.java and GridCameraManager.java. (SAMNDCAC000007967-8007; see also SAMNDCA-C000008045-8180; SAMNDCAC000007730-7746; SAMNDCA-C000007781-7786.)
- 31 -
Claim 20 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:
Representative Samsung Products
The Exhibit 4G phone, Vibrant, Captivate, and Galaxy Tab 10.1 are mobile computing
devices with touch screen displays, processors, and memory.
(Exhibit 4G phone User Manual (APLNDC-Y0000066320).)
(Vibrant User Manual (APLNDC-Y0000057339).)
(Captivate User Manual (APLNDC-Y0000062795).)
- 32 -
Claim 20 of U.S. Patent No. 7,469,381
Representative Samsung Products
(Galaxy Tab 10.1 User Manual (APLNDC-Y0000060376).)
Exhibit 4G: “1-GHz Hummingbird” processor that uses
“Android 2.3, Gingerbread OS.” (APLNDCY0000066850)
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 -
Claim 20 of U.S. Patent No. 7,469,381
display a first portion of an electronic
document;
Representative Samsung Products
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.)
- 34 -
Claim 20 of U.S. Patent No. 7,469,381
Representative Samsung Products
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;
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.)
The detection of a user’s finger and translation of the electronic document are
performed in the following source code modules for the Exhibit 4G phone, which runs
Android 2.3: RenderView.java, GLSurfaceView.java, GridLayer.java, and
GridInputProcessor.java. (SAMNDCA-C000007890-7999.) 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.
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
- 35 -
Claim 20 of U.S. Patent No. 7,469,381
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.
- 36 -
Claim 20 of U.S. Patent No. 7,469,381
Representative Samsung Products
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
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.)
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. (SAMNDCAC000007890-7999; see also SAMNDCA-C000008045 - 8180; SAMNDCAC000007702-7746.) The GridInputProcessor.java file identifies the edge of the
photograph and displays an area beyond the edge of the photograph.
- 37 -
Claim 20 of U.S. Patent No. 7,469,381
Representative Samsung Products
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.
- 38 -
Claim 20 of U.S. Patent No. 7,469,381
Representative Samsung Products
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.
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.)
The detection of a user’s lifting of his finger from the touch screen and translation of
the electronic document in a second direction are performed in the following source
code modules: GridInputProcessor.java and GridCameraManager.java. (SAMNDCAC000007967-8007; see also SAMNDCA-C000008045-8180; SAMNDCAC000007730-7746; SAMNDCA-C000007781-7786.)
- 39 -
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