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 4

Exhibit 4: U.S. Patent No. 7,469,381 and WO 03/081458 to Lira / U.S. Patent No. 7,872,640 to Lira

WO 03/081458 to Lira / U.S. Patent No. 7,872,640 to Lira1

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

Lira discloses a computer-implemented method.
For example, Lira discloses a method for viewing and navigating a document on “a device having a
small display or a small display window, such as, for example, a PDA, a telephone, a handheld
computer, or an electronic book.” Lira at p. 1 lns. 16-18.

(a) at a device with a touch
screen display

Lira discloses a computer-implemented method at a device with a touch screen.
For example, the display of the device “may include a touch screen and tracking motion of the input tool
may include tracking motion of the input tool on the touch screen.” Id. at p. 3 lns. 10-11.

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

Lira discloses displaying a first portion of an electronic document.
For example, Lira discloses an electronic device for browsing an electronic document. Lira at p. 1 ln.
28 – p. 2 ln. 3. As part of that browsing of an electronic document, Lira will display a first portion of an
electronic document.
As explained and illustrated in Lira, a display screen can be thought of as a small field-of-view window
over a large image or electronic document. As disclosed in Lira, the electronic document may be a web
page with structured elements such as columns.
Lira discloses several ways for a display screen to pan through a document whose size exceeds the size
of the display screen. Specifically, Lira discloses several ways for the panning to utilize structures in
the document in order to align the display screen with structures in the document.

1

Cites are to WO 03/081458.

01980.51871/4304993.3

1

One such mechanism is an animated “snap” feature that “snaps” the edge of the display screen to the
edge of a structure in the document when a panning operation ends (for example, when a user lifts their
finger off a touch-screen display). This “snap” feature is disclosed in Lira as one of several solutions for
ensuring that a display screen panning through a large document remains properly aligned with the data
in that large electronic document. See, e.g., Lira at p. 14-15.
Lira illustrates the steps of panning and scrolling an electronic document in its figures. Fig. 2 of Lira
shows a webpage (item 100) that is too large to display in its entirety on the relatively small screen of a
device such as a PDA. Instead, only a portion of the web page can be displayed in the PDA’s browser
window at any given time. This is illustrated in Fig. 2 by a display window (item 200) superimposed
onto the web page. Since the web page is larger than the display window 200, the user must scroll back
and forth (indicated in Fig. 2 by arrows that indicate potential scrolling directions) to view different
areas of the web page.

01980.51871/4304993.3

2

Lira discloses scrolling through this web page by illustrating the position over time of one browser
window performing a panning operation. In Fig. 10, Lira illustrates a horizontal scrolling operation by
showing multiple display windows that represent the path of a single window scrolling horizontally
through the web page:

01980.51871/4304993.3

3

Fig. 12 likewise illustrates scrolling this window in horizontal, vertical, or diagonal directions using a
stylus:

01980.51871/4304993.3

4

Figure 14B of Lira also shows how Lira displays a first portion of an electronic document. Figure 14B
shows a path along which the user moves her input tool to pan the display window through portions of
the underlying web page. This series of windows in Fig. 14B depicts the positions over time of a single
window as the window vertically scrolls through an underlying web page.

01980.51871/4304993.3

5

As shown in the figure, the logical column 1220 is an electronic document. For example, this logical
column 1220 has boundaries. Lira at p. 15 ln. 25 – 29. Logical columns 1215 and 1225 are likewise
each electronic documents. All of these logical columns 1215, 1220, and 1225 are sub-documents in a
larger electronic document: the web page.
Fig. 14B illustrates several different portions of the electronic document 1220 being displayed in the
display window over time. Any one of these displayed area of the logical column 1220 is a first portion

01980.51871/4304993.3

6

of that electronic document.
(c) detecting a movement
of an object on or near the
touch screen display;

Lira discloses detecting a movement of an object on or near the touch screen display. For example, Lira
discloses that the user can browse through an electronic document using a touch screen display, which
will detect when a user touches or presses the display.
For example, Lira discloses:
In another general aspect, navigating on a display includes tracking motion of an input
tool on a display, comparing the motion of the input tool to a threshold, changing the
position of the visible portion of a page of information on the display if the motion
exceeds the threshold, and constraining the position of the visible portion of the page of
information on the display if the motion does not exceed the threshold.
...
The display may include a touch screen and tracking motion of the input tool may include
tracking motion of the input tool on the touch screen. The touch screen may include, for
example, a resistive sensor, a capacitive sensor, an acoustic wave sensor, or an infrared
sensor. The touch screen may include a sensor activated by touch activation force by the
input tool on the display.
Lira at p. 3 lns. 1-14.

(d) 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,

01980.51871/4304993.3

Lira discloses 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. For
example, Lira discloses that in response to detecting the movement of the finger on the touch screen,
panning through the electronic document.
For example, Lira discloses:
In another general aspect, navigating on a display includes tracking motion of an input
tool on a display, comparing the motion of the input tool to a threshold, changing the
position of the visible portion of a page of information on the display if the motion

7

exceeds the threshold, and constraining the position of the visible portion of the page of
information on the display if the motion does not exceed the threshold.
Lira at p. 3 lns. 1-14.
Lira further discloses “touch-and-drag” scrolling, where the user can “scroll the display window by
placing a stylus 600 on the display window 605 and then dragging the stylus 600.” Lira at p. 11 lns. 2729. See also Lira at p. 14 ln. 29 – p. 15 ln. 30 & Fig. 12.
As the user drags the document to scroll in a first direction, a second portion of the electronic document
that is different than the first portion of the electronic document will be displayed, as illustrated in
Figure 14B.

01980.51871/4304993.3

8

(e) wherein the second
Lira discloses the second portion is different from the first portion. For example, the first and second
portion is different from the portions are different because the user has scrolled down the document, as shown in Fig. 14B.
first portion:

01980.51871/4304993.3

9

(f) in response to an edge
of the electronic document
being reached while
translating the electronic
document in the first
direction while the object is

01980.51871/4304993.3

Lira discloses 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:
displaying an area beyond the edge of the document.
For example, in one mode described in Lira, if the user moves the screen away from the column being

10

still detected on or near the
touch screen: displaying an
area beyond the edge of the
document, and

read, an area beyond the edge of the column will be displayed.
For example, Lira discloses “vertical alignment control” which will align the display window to an edge
of the electronic document. In one embodiment, “the vertical alignment control is enabled when the
user lifts the pen 1200 from the display 1205,” which causes the column “to snap into alignment with
the display window as the user stops scrolling.” Lira at p. 15 lns. 18-31.
Figure 14B illustrates this “snap-to” behavior, including the conditions that trigger this “snap” behavior.
As shown in the figure, the display window 1205 is displaying an area beyond the edge of the logical
column 1220. Specifically, the display window 1205 is displaying an area of logical column 1220 and
also displaying an area of logical column 1225 (a separate electronic document).

(g) displaying a third

01980.51871/4304993.3

Lira discloses displaying a third portion of the electronic document that is smaller than the first portion.
11

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

For example, as the user continues to drag the display window beyond the edge of the logical column
1220, the display window will increasingly pan over areas of logical column 1225. When this occurs,
because the display window is only devoting a portion of its display area to the display of logical
column 1220, the third portion of the column 1220 being displayed is smaller than the first portion of
column 1220.

(h) in response to detecting
that the object is no longer

Lira 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 beyond the edge of the electronic

01980.51871/4304993.3

12

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,

document is no longer displayed to display a fourth portion of the electronic document.
For example, Lira discloses that “as the pen 1200 is lifted from the screen” certain actions occur
depending on whether the panning operation moving the display from column 1220 to column 1225 has
exceeded some threshold. Specifically, when the user lifts the stylus or finger from the screen, “the
logical column 1220 [will] snap into alignment with the display window 1205 as the user stops
scrolling. The user can adjust the snap sensitivity by, for example, setting the alignment control to snap
to the nearest logical column based on a user-defined threshold. If the user’s scrolling does not exceed
the threshold, which indicates an intention to continue to view the text column 1220, the display 1205
centers the logical column 1210 as the pen 1200 is lifted from the screen.” Lira at p. 15 lns. 19-25.
This snap-to function will move the document in a second direction, as indicated in the arrow in Fig.
14B, until the area beyond the edge of the column is no longer displayed. This will result in a fourth
portion of the column 1220 being displayed, and will also result in no area of column 1225 being
displayed, as shown in Fig. 14B:

01980.51871/4304993.3

13

(i) wherein the fourth
Lira discloses the fourth portion is different from the first portion. For example, the fourth portion will
portion is different from the be different from the first portion because the user has scrolled down through the electronic document,
first portion.
as shown in Figure 14B.

01980.51871/4304993.3

14

Claim 2
The computer-implemented
method of claim 1, wherein
the first portion of the
electronic document, the
second portion of the
electronic document, the

01980.51871/4304993.3

Lira discloses 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. For example, the first, second, third, and fourth
portions of the electronic document are all displayed at the same magnification. As Figure 14B
illustrates, the magnification of the document is not changed as the page turning animation progresses:

15

third portion of the
electronic document, and
the fourth portion of the
electronic document are
displayed at the same
magnification.

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

01980.51871/4304993.3

Lira discloses that the touch screen input occurs in response to the user touching or pressing the touch
screen display:
The display may include a touch screen and tracking motion of the input tool may include
tracking motion of the inptu tool on the touch screen. The touch screen may include, for
16

example, a resistive sensor, a capacitive sensor, an acoustic wave sensor, or an infrared
sensor. The touch screen may include a sensor activated by touch activation force by the
input tool on the display.
Lira at p. 3 lns. 10-14.
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.
Claim 6
The computer-implemented
method of claim 1, wherein
the electronic document is
a web page.
Claim 7
The computer-implemented
method of claim 1, wherein
the electronic document is
a digital image.

01980.51871/4304993.3

Lira discloses that the user can operate the touch screen using his finger. For example, Lira discloses
“the input tool may be a pen stylus or a finger, and the tracking motion of the input tool may include
tracking the pen or finger on the display surface.” Lira at p. 3 lns. 6-9.
Lira discloses that the first direction is a vertical direction.
For example, Lira discloses “vertical alignment control” that can be used to minimize wobble “during
vertical scrolling.” Lira at p. 14 lns. 29-30. See also Figures 12 & 14B.

Currently not at issue.

Lira does not explicitly disclose applying its methods to a digital image. However, because images can
be included within an HTML page, the techniques disclosed by Lira are explicitly applied to electronic
documents that include digital images. Thus it would have been obvious to one of ordinary skill in the
art to modify the computing device disclosed by Lira so that the electronic document is a digital image.
The user interface features identified above as anticipating claim 1 of the ‘381 patent operate
independently of the nature of the underlying electronic document. In other words, the user can use
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. Additionally, because digital images are commonly
displayed on computing devices, one of skill in the art would be motivated to modify Lira so that its
user interface features would operate on digital images as well.

17

Claim 8
The computer-implemented Currently not at issue.
method of claim 1, wherein
the electronic document is
a word processing,
spreadsheet, email or
presentation document.
Claim 9
The computer-implemented Lira discloses the electronic document includes a list of items. For example, as shown in Fig. 14B, the
method of claim 1, wherein logical columns of the web page as disclosed by Lira include lists of items.
the electronic document
includes a list of items.

01980.51871/4304993.3

18

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

As noted above, Lira discloses that the first direction can be horizontal, vertical, or diagonal, such that
the first direction can be any direction – including the opposite direction of the “snap to” operation. The
goal of Lira’s snap-to function is to “cause[] the logical column 1220 to snap into alignment with the
display window 1205 as the user stop scrolling.” Lira at p. 15 lns. 19 – 21.

Claim 11

01980.51871/4304993.3

19

The computer-implemented
method of claim 1, wherein
translating in the first
direction prior to reaching
an edge of the document
has an associated speed of
translation that corresponds
to a speed of movement of
the object.
Claim 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.
Claim 14
The computer-implemented
method of claim 1, wherein
the area beyond the edge of
the document is visually
distinct from the document.
Claim 15
The computer-implemented
method of claim 1, wherein

01980.51871/4304993.3

Currently not at issue.

Currently not at issue.

Lira does not explicitly disclose the area beyond the edge of the column displayed is black, gray, a solid
color, or white. However, the area beyond the edge will be dictated by the particular web page being
scrolled. If the background of the web page is a solid color, that will be the color of the area beyond the
edge of the column. Thus, it would be obvious to one of skill in the art that the area beyond the edge of
the column displayed can be black, gray, a solid color, or white.

Lira discloses the area beyond the edge of the document is visually distinct from the document. For
example, Fig. 14B shows the neighboring column displayed beyond the edge of the document, which is
visually distinct from the document.

Currently not at issue.

20

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
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
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

01980.51871/4304993.3

Lira 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, Lira’s snap-to function “causes the logical column 1220 to
snap into alignment with the display window 1205 as the user stop scrolling.” Lira at p. 15 lns. 19 – 21.
This snap-to-align function makes the edge of the electronic document appear to be elastically attached
to an edge of the touch screen display.

Currently not at issue.

21

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.
Claim 18
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 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

01980.51871/4304993.3

22

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
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; 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
an area beyond an edge of

01980.51871/4304993.3

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

See claim 1(b).

See claim 1(c) – 1(e).

See claim 1(f) – 1(g).

23

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
See claim 1(h) – 1(i).
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
See preamble of claim 1 and claim 1(a).
storage medium having
stored therein instructions,
which when executed by a

01980.51871/4304993.3

24

device with a touch screen
display, cause the device
to:
display a first portion of an See claim 1(b).
electronic document;
detect a movement of an
See claim 1(c) – 1(e).
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;
display an area beyond an
See claim 1(f) – 1(g).
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

01980.51871/4304993.3

25

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.

01980.51871/4304993.3

See claim 1(h) – 1(i).

26