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

Filing 168

Declaration of ANDRIES VAN DAM, PH.D IN SUPPORT OF SAMSUNG'S OPPOSITION TO APPLE'S MOTION FOR PRELIMINARY INJUNCTION filed bySamsung Electronics America, Inc., Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14)(Maroulis, Victoria) (Filed on 8/22/2011) Modified on 8/29/2011 cannot link entry-opposition has not been efiled (dhm, COURT STAFF).

EXHIBIT 3

Exhibit 3: U.S. Patent No. 7,469,381 and XNav

U.S. Pat. No. 7,469,381
Claim 1
A computer-implemented
method, comprising:

XNav
To the extent the preamble is found to be limiting, a computing device running XNav discloses a
computer that implements a method. For example, XNav is configured to run on mobile computing
devices running versions of the Windows XP operating system, including the Sony U-series ultramobile PCs.
These devices include processors and memory. For example, the Sony VGN-U750P UMPC has Intel
Pentium M processor and main memory of 512 MB DDR RAM.

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1

See Ex. 14 (Sony VGN-U750P Marketing Specification).
(a) at a device with a touch
screen display:

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A computing device running XNav discloses a device with a touch screen display. For example, XNav
can run on Sony U-series ultra-mobile PCs with touch screen displays.

2

See Ex. 14 (Sony VGN-U750P Marketing Specification).

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(b) displaying a first portion
of an electronic document;

Representative Example #1:
A computing device running XNav discloses displaying a first portion of an electronic document.
XNav includes an email program capable of displaying a list of email messages, such as an inbox, as
an electronic document. The computing device will display a portion of the email list as a first portion:

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Representative Example #2:
In another example, the electronic document is a Zone in XNav. Each tile is itself an electronic
document, and a Zone comprised of four adjacent tiles is also an electronic document. In this example,
the electronic document is the Zone located in the center of the World view. This Zone is outlined in
green in the picture below:

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The user can scroll to a neighboring Zone by touching the touch screen device with a finger and
moving the finger . If the user begins in the center Zone and moves to the left, a first portion of the
Zone will be displayed. The first portion is depicted in the picture below, outlined in green:

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Representative Example #3:
Any set of contiguous tiles could be considered an electronic document. Accordingly, two contiguous
Zones comprised of eight tiles would also constitute the electronic document recited in claim 1. Two
contiguous Zones comprised of eight tiles is shown outlined in green below:

In this example, when the user enters Zone view (e.g., from the World view or from the Application
Tile view), the user will see a single Zone that constitutes a first portion of an electronic document.
Specifically, this single Zone is one portion of an eight-tile, two-Zone 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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Representative Example #1:
A computing device running XNav discloses detecting a movement of an object on the touch screen
display and, in response, translating the electronic document to display a second portion of the
electronic document that is different from the first.
For example, in the email program, the user can scroll the list up so that a second portion is displayed:

8

Representative Example #2:
As another example, Xnav will detect movement of a finger on the touch screen and translate the
electronic document in the direction of the movement of the finger. Starting at the first portion
referenced above, obtained by having previously scrolled the Zone slightly to the left, continuing from
this position, if the user swipes her finger to the right, the electronic document will move to the right.
A second portion of the electronic document is then displayed. This second portion of the document is
different from the first portion of the document. This is depicted in the figure below:

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Representative Example #3:
In another example, where two contiguous Zones form a single electronic document, a second portion
of that document is displayed when the user scrolls. For example, if the user scrolls right, a second
Zone comprising the second half of the electronic document will be displayed. In the sequence below,
the first image illustrates the starting point just prior to a scrolling operation, and the second and third
images represent partial movement during the scrolling operation.

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(d) in response to an edge of
the electronic document
being reached while
translating the electronic

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Representative Example #1:
A computing device running XNav discloses displaying an area beyond the edge of the document and
displaying a third portion of the electronic document that is smaller than the first portion in response to

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document in the first
direction while the object is
still detected on or near the
touch screen: displaying an
area beyond the edge of the
document, and displaying a
third portion of the
electronic document,
wherein the third portion is
smaller than the first
portion; and

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an edge of the electronic document being reached.
For example, in the email program, when the user reaches the bottom of the email list when scrolling
up, the edge of the email list is displayed. Beyond that edge a blank area is also displayed. This blank
area is not part of the electronic document that consists of the email list. This results in the display of a
third portion of the document, which is smaller than the first portion of the document, because of the
blank area.

12

Representative Example #2:
As another example, as the user reaches the left edge of a Zone while scrolling to the right in the
example discussed above, an area beyond the left edge of that Zone will be displayed. That area will
consist of a solid-colored “gutter,” or border, followed by the neighboring Zone on the left. As the user
continues scrolling to the right, a third portion of the electronic document is displayed that is smaller
than the first portion of the electronic document because more of the electronic document has been
scrolled off the screen. The third portion and the area beyond the edge of the electronic document are
displayed in the picture below:

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Representative Example #3:
In another example, in the case of two contiguous Zones being the electronic document, if the user
continues scrolling to the right, the left edge of the electronic document will be encountered. As the
user scrolls past the edge, an area beyond that edge will be displayed. That area will consist of a gray
“gutter,” or border, followed by the neighboring Zone, similar to that in representative example #2.

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(e) in response to detecting
that the object is no longer
on or near the touch screen
display, translating the

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Representative Example #1:
A computing device running XNav discloses, 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

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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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beyond the edge of the electronic document is no longer displayed to display a fourth portion of the
electronic document that is different from the first portion.
For example, if the user lifts her finger after displaying the third portion of the email list, the email list
will reverse direction and “snap” back to the bottom edge of the email list, subject to the threshold
distance limitation, such that the area beyond this edge will no longer be displayed. The result will
display a fourth portion of the Zone that is different from the first portion.

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Representative Example #2:
As another example, if the user lifts her finger while in the process of scrolling between Zones, the
interface will automatically select a Zone to snap to. If the user has not scrolled past a particular
threshold in the direction of the next Zone, the application will snap back to the previous Zone. This
snap-back feature will cause the electronic document to be translated in a second direction, which will
be opposite to the first direction, until the area beyond the edge of the electronic document can no
longer be seen. As a result, a fourth portion of the document is displayed. This fourth portion is
different than the first portion.

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Representative Example #3:
In another example, in the case of two contiguous Zones being the electronic document, if the user lifts
her finger after scrolling some distance beyond the second portion of the electronic document, the
electronic document will snap back, translating in the opposite direction until the area beyond the edge
of the electronic document is no longer in view. The result will display a fourth portion of the
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electronic document that is different from the first portion.

Claim 2
The computer-implemented

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Representative Example #1:

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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.

A computing device running XNav discloses the first, second, third, and fourth portions are all at the
same magnification. For example, the four portions previously described are all displayed at the same
magnification:

Representative Example #2:
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Representative Example #3:

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Claim 3
The computer implemented
method of claim 1, wherein
the movement of the object
is on the touch screen

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A computing device running XNav can detect movement of an object on a touch screen display. For
example, in a Sony VGN-U750P UMPC, the touch screen display can accept input based on a touch
from a finger on the display. See claim 1(a).

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display.
Claim 4
The computer-implemented
method of claim 1, wherein
the object is a finger.
Claim 5
The computer-implemented
method of claim 1, wherein
the first direction is a
vertical direction, a
horizontal direction, or a
diagonal direction.

A computing device running XNav discloses that the object used to interact with the touch screen is a
finger. For example, in a Sony VGN-U750P UMPC, the touch screen display can accept input based
on a touch from a finger on the display. See claim 1(a).

Representative Example #1:
A computing device running XNav discloses the first direction is a vertical or horizontal direction. For
example, XNav permits the first direction to be in either a vertical or horizontal direction. The figure
below depicts movement in a vertical direction:

Representative Example #2:

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Representative Example #3:

Claim 6
The computer-implemented
method of claim 1, wherein
the electronic document is a

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Currently not at issue.

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web page.
Claim 7
The computer-implemented
method of claim 1, wherein
the electronic document is a
digital image.

A computing device running XNav discloses the electronic document is a digital image.
Representative Example #1:
For example, the XNav prototype email application has an electronic document that is at least one or
more digital images. In the prototype email application, the electronic document is the email list.
However, because the email application in only a prototype, each entry in the email list is actually an
individual digital image or .png file, acting as placeholders in order to emulate an operative email
application. Thus, as the email application is currently written in XNav, the electronic document
(email list) is composed of one or more digital images (.png files representing entries in the list).

Representative Example #2 & #3:
Similarly, a Zone in XNav is comprised of four tiles, and two contiguous Zones are comprised of eight
tiles. Each of these tiles is displayed as an individual image, and in fact many are .png image files. To
the extent the examples discussed above do not anticipate claim 7, it would have been obvious to one
of ordinary skill in the art to modify XNav so that the electronic document is a single digital image.

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The user interface features identified above as anticipating claim 1 of the ‘381 patent operate
independently of the nature of the underlying electronic document. An implementer could employ
these same techniques to manipulate any document displayed on the screen, regardless of whether the
document is a list of items or a digital image. Applying these techniques to a digital image would not
have presented any unique problems, or even significant effort. Additionally, because digital images
are commonly displayed on computing devices, one of skill in the art would be motivated to modify
XNav so that its user interface features would operate in the same manner described above when the
electronic document is a single digital image. Thus, it is my opinion that Claim 7 recites an obvious
modification to the functionality contained in XNav if XNav does not disclose each and every
limitation of Claim 7.

See also claim 1(b).
Claim 8
The computer-implemented
method of claim 1, wherein
the electronic document is a
word processing,
spreadsheet, email or

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Currently not at issue.

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

A computing device running XNav discloses the electronic document includes a list of items. For
example, as shown in the image below, the electronic document includes an image of an “Inbox.” This
Inbox is a list of emails. Other electronic documents also include lists of phone-related events,
including missed calls, outgoing calls, voicemail, and incoming text messages.
Representative Example #1:

Representative Example #2 & #3:

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Claim 10
The computer-implemented
method of claim 1, wherein
the second direction is
opposite the first direction,

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Representative Example #1:
A computing device running XNav discloses that the second direction is opposite the first direction.
When the zone snaps back after the user lifts his finger, the direction of the snap back is opposite the
direction in which the user was scrolling.

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Representative Example #2:

Representative Example #3:

Claim 11
The computer-implemented
method of claim 1, wherein
translating in the first

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Currently not at issue.

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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 12
The computer-implemented
method of claim 1, wherein
translating in the first
direction is in accordance
with a simulation of an
equation of motion having
friction.
Claim 13
The computer-implemented
method of claim 1, wherein
the area beyond the edge of
the document is black, gray,
a solid color, or white.

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Currently not at issue.

Representative Example #1:
A computing device running XNav discloses that the area beyond the document is a solid color.
In XNav, when the end of the list of emails is reached, the area beyond the edge of the email list is a
solid color:

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Representative Example #2 & #3:
As another example, between each of the Zones displayed in XNav is a solid-colored gray “gutter” area
that indicates a separation between the Zones. This gutter area is displayed beyond the edge of the
document. Accordingly, the gutter area beyond the edge of the document is a solid-colored gray area.
This same area surrounds an eight-tile area of two contiguous Zones and forms a solid-colored gray
area beyond the edge of that document.

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Claim 14
The computer-implemented
method of claim 1, wherein
the area beyond the edge of
the document is visually
distinct from the document.

Representative Example #1:
A computing device running XNav discloses the area beyond the edge of the document is visually
distinct from the document.
For example, in XNav, when the end of the list of emails is reached, the area beyond the edge of the
email list is visually distinct from the document. The area beyond the edge is a solid color, whereas the
email list contains text and images:

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Representative Example #2 & #3:
As another example, the area beyond the edge of the electronic document in XNav is visually distinct,
with a gray gutter area separating the area showing the next zone, which is its own separate electronic
document, and the original electronic document. This area is also displayed as a border of an eight-tile
area comprised of two contiguous Zones. This gray area is displayed beyond the edge of such a
document and is visually distinct from the document.

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Claim 15
The computer-implemented
method of claim 1, wherein
translating the document in
the second direction is a
damped motion.
Claim 16
The computer-implemented
method of claim 1, wherein
changing from translating in
the first direction to
translating in the second

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Currently not at issue.

A computing device running XNav discloses 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. For example, the snap-back
effect in XNav makes the document appear to be elastically attached to the edge of the display so that

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the edge of the document, moving in the second direction, is moving towards the edge of the display.
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.
Claim 17
The computer-implemented Currently not at issue.
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

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distance of movement of the
object after reaching the
edge of the electronic
document.
Claim 18
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.
Claim 19
A device, comprising:
a touch screen display;
one or more processors;
memory; and
one or more programs,
wherein the one or more
programs are stored in the

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Currently not at issue.

See preamble of claim 1.
See claim 1(a)
See preamble of claim 1.
See preamble of claim 1.
See preamble of claim 1.

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memory and configured to
be executed by the one or
more processors, the
programs including:
instructions for displaying a See claim 1(b).
first portion of an electronic
document;
instructions for detecting a
See claim 1(c).
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;
instructions for displaying
See claim 1(d) .
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

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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.
Claim 20
A computer readable storage
medium having stored
therein instructions, which
when executed by a device
with a touch screen display,
cause the device to:
display a first portion of an
electronic document;
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

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See claim 1(e).

See preamble of claim 1 and claim 1(a).

See claim 1(b).
See claim 1(c).

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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 ;
display an area beyond an
See claim 1(d).
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
translate the electronic
See claim 1(e).
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

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detecting that the object is
no longer on or near the
touch screen display.

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