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

Filing 672

*** EXHIBIT 4 FILED IN ERROR WITH CONFIDENTIAL INFORMATION . DOCUMENT LOCKED. DOCUMENT TO BE REFILED LATER.. *** EXHIBITS re #667 Administrative Motion to File Under Seal re Samsung's Motion to Supplement Invalidity Contentions (Briggs Declaration in Support of Samsung's Motion to Supplement Invalidity Contentions) filed bySamsung Electronics Co. Ltd.. (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)(Related document(s) #667 ) (Maroulis, Victoria) (Filed on 1/27/2012) Modified on 1/27/2012 (feriab, COURT STAFF).

Download PDF
EXHIBIT 5 EXHIBIT D-8 SAMSUNG’S INVALIDITY CLAIM CHARTS FOR SUPERCLOCK! VERSION 4.0.4 FOR THE SYSTEM 7 OPERATING SYSTEM ON A MACINTOSH POWERBOOK ("SuperClock! for System 7") SuperClock! 4.0.4 is an application written by Steven Christensen for the Macintosh System 6 and System 7 operating systems. It is further described in the SuperClock! 4.0.4 ReadMe file, as discussed in the Deposition of Steven Christensen, October 26, 2011, Exhibit 984 ("ReadMe File"). For demonstrative purposes, this chart uses a Macintosh PowerBook 165c (first released on February 10, 1993) running Mac OS System 7.1 (first released in August, 1992); however, other portable computers using System 6 or 7 and running SuperClock! are also included as prior art to the '002 patent. Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 [1A] An interactive computercontrolled display system comprising: SuperClock! for System 7 discloses an interactive computer-controlled display system comprising a processor and a data display screen coupled to the processor. a processor; For example, the Mac PowerBook 165c, which was sold with System 7 installed, is a laptop computer including one or more processors and a display screen coupled to the processors. a data display screen coupled to the processor; 02198.51855/4429789.1 Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 [1B] a cursor control device coupled to said processor for positioning a cursor on said data display screen; SuperClock! for System 7 discloses a cursor control device (e.g. trackball) coupled to said processor for positioning a cursor on said data display screen. [1C] a window generation and control logic coupled to the processor and data display screen to create an operating environment for a plurality of individual programming modules associated with different application programs that provide status and/or control functions, SuperClock! for System 7 discloses a window generation and control logic coupled to the processor and data display screen to create an operating environment for a plurality of individual programming modules (e.g. a clock module and a battery status module) associated with different application programs (a clock program and a battery program) that provide status (the time and the battery status) and/or control functions. 02198.51855/4429789.1 Asserted Claims From U.S. Patent No. 6,493,002 [1D] wherein the window generation and control logic generates and displays a first window region having a plurality of display areas on said data display screen, 02198.51855/4429789.1 SuperClock! for System 7 SuperClock! for System 7 discloses that the window generation and control logic generates and displays a first window region (e.g. menu bar) having a plurality of display areas (e.g. the clock area and the battery status area) on said data display screen. Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 [1E] wherein the first window region is independently displayed and independently active of any application program, and SuperClock! for System 7 discloses that the first window region (e.g. menu bar) is independently displayed and independently active of any application program. 02198.51855/4429789.1 For example, System 7 includes a single, universal menu bar that remains present across all programs. Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 [1F] wherein each of the plurality SuperClock! for System 7 discloses that each of the plurality of display areas (e.g. the clock area of display areas is associated with and battery status area) is associated with one of the plurality of individual programming modules one of the plurality of individual (e.g. the clock module and the battery status module). programming modules, For example, "SuperClock! displays the time and date near the right end of the menu bar. If you're using a portable Macintosh, it will also display the battery level; the battery icon will include a little lightning bolt when the battery is charging." ReadMe File at ¶1. 02198.51855/4429789.1 Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 [1G] the first window region and the plurality of independent display areas implemented in a window layer that appears on top of application programming windows that may be generated; and SuperClock! for System 7 discloses that first window region (e.g. the menu bar) and the plurality of independent display areas (e.g. the clock are and the battery status area) are implemented in a window layer that appears on top of application programming windows (e.g. Microsoft Word) that may be generated. 02198.51855/4429789.1 Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 (Showing that the menu bar is on top of the word programming application.) [1H] an indicia generation logic coupled to the data display screen to execute at least one of the plurality of individual programming modules to generate information for display in one of the plurality of display areas in the first window region, 02198.51855/4429789.1 SuperClock! for System 7 discloses an indicia generation logic coupled to the data display screen to execute at least one of the plurality of individual programming modules to generate information for display in one of the plurality of display areas in the first window region. For example, "SuperClock! displays the time and date near the right end of the menu bar. If you're using a portable Macintosh, it will also display the battery level; the battery icon will include a little lightning bolt when the battery is charging." ReadMe File at ¶1. Asserted Claims From U.S. Patent No. 6,493,002 [1I] wherein at least one of the plurality of display areas and its associated programming module is sensitive to user input, and SuperClock! for System 7 SuperClock! for System 7 discloses that at least one of the plurality of display areas and its associated programming module is sensitive to user input. For example, "If you want to hide the clock for awhile (for instance, if you're doing a presentation in MacroMind Director ), hold down the option key and click on the clock." ReadMe File at ¶3. "If you're running on a portable Macintosh, hold down the control key and click on the battery 02198.51855/4429789.1 Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 indicator to put the computer to sleep." ReadMe File at ¶4. "Clicking on the clock (with no keys held down) toggles between the time, date, and a count down/count up timer (clicking on the little timer icon will start or stop the timer)." ReadMe File at ¶5. (Clicking on the clock area twice changes the clock into a timer. Clicking on the timer icon then starts and stops the timer.) [1J] further wherein the window generation and control logic and the indicia generation logic use message-based communication to exchange information to coordinate activities of the indicia 02198.51855/4429789.1 SuperClock! for System 7 discloses that the window generation and control logic and the indicia generation logic use message-based communication to exchange information to coordinate activities of the indicia generation logic to enable interactive display activity. For example, SuperClock! communicates with other programs: "Starting with version 4.0, SuperClock! uses a new method of determining when a screen saver is running that essentially Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 generation logic to enable interactive display activity. asks the screen saver itself. Support for this feature was developed by Berkeley Systems for After Dark. It's also supported in recent versions of Pyro! and DarkSide. What this means is that SuperClock! will not hide for older screen savers (Moire comes to mind), and some presentation applications in full screen mode. If you run into one of these cases and can get in touch with the author, please feel free to point him/her to me and I can let 'em know about a really easy change that needs to be made." ReadMe File at ¶7. [2] The display system defined in claim 1 wherein the first window region comprises a control strip. SuperClock! for System 7 discloses that the first window region comprises a control strip. For example, to the extent that this claim is more limited than Claim 1, the menu bar permits control of the clock: "If you want to hide the clock for awhile (for instance, if you're doing a presentation in MacroMind Director ), hold down the option key and click on the clock." ReadMe File at ¶3. "If you're running on a portable Macintosh, hold down the control key and click on the battery indicator to put the computer to sleep." ReadMe File at ¶4. Clicking on the clock (with no keys held down) toggles between the time, date, and a count down/count up timer (clicking on the little timer icon will start or stop the timer). ReadMe File at ¶5. Furthermore, the menu bar allows for the selection of menu options from a given application. 02198.51855/4429789.1 Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 (Ctrl-clicking on the battery puts the computer to sleep.) (The menu bar allows for control of computer functions.) [3] The display system defined in claim 1 wherein said at least one display area is variably sized. 02198.51855/4429789.1 SuperClock! for System 7 discloses that at least one display area is variably sized. Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 (SuperClock! showing that the clock area is variably sized depending on the number of characters in the time.) [4] The display system defined in claim 1 wherein size of the first window region is variable. The size of the first window region (e.g. menu bar) is variable. (Compare Apple's Infringement Contentions at Ex. 1-3.) Furthermore, it would have been obvious to a person having ordinary skill in the art of user interface design to combine the menu bar with the well-known principals of image and window 02198.51855/4429789.1 Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 re-sizing. Other windows of System 7 are fully re-sizeable. Moreover, the asserted '002 patent itself states: "Adjustments to the size of the window may comprise either an increase in the height of the window, the width of the window, or both. . . . The definition and use of windows is well-known in the art." U.S. Patent No. 6,439,002 (Christensen) at 7:6-10 (emphasis added). [6] The display system defined in claim 4 wherein the first window region is sized such that all of the plurality of display areas are visible. SuperClock! for System 7 discloses the first window region sized such that all of the plurality of display areas are visible. [7] The display system defined in claim 4 wherein the first window region is sized such that a portion of the plurality of display areas is visible. SuperClock! for System 7 discloses the first window region sized such that a portion of the plurality of display areas is visible. For example, all menu options are typically visible. "Once it's installed, it [SuperClock!] will display the time on the menu bar as long as there's room for it." ReadMe File at ¶3. For example, "Once it's installed, it will display the time on the menu bar as long as there's room for it; various combinations of small screen sizes, large number of menus, or a large clock font could cause the clock to be hidden. If you want to hide the clock for awhile (for instance, if you're doing a presentation in MacroMind Director ), hold down the option key and click on the clock." ReadMe File at ¶3. Furthermore, it would have been obvious to a person having ordinary skill in the art of user interface design to combine the menu bar with the well-known principals of image and window re-sizing. Other windows of System 7 are fully re-sizeable. Moreover, the asserted '002 patent itself states: "Adjustments to the size of the window may comprise either an increase in the height of the window, the width of the window, or both. . . . The definition and use of windows is well-known in the art." U.S. Patent No. 6,439,002 (Christensen) at 7:6-10 (emphasis added). 02198.51855/4429789.1 Asserted Claims From U.S. Patent No. 6,493,002 [9] The display system defined in claim 1 wherein at least one of the display areas acts to provide access to control information when selected. SuperClock! for System 7 SuperClock! for System 7 discloses that at least one of the display areas acts to provide access to control information when selected. For example, the System 7 menu bar includes an Apple Icon, which provides access to system controls. (The Apple Icon provides access to Control Panels and application controls.) [10] The display system of claim 9 wherein said at least one of the plurality of display areas displays an additional display element. 02198.51855/4429789.1 SuperClock! for System 7 discloses that at least one of the plurality of display areas displays an additional display element. For example, the System 7 menu bar includes a clock that will display a timer when selected. Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 (Clicking on the clock area twice changes the clock into a timer.) Furthermore, the System 7 Apple Icon displays additional menu options when selected. (Touching the Apple Icon on the menu bar displays a control menu tab.) Moreover, the Control Panels option brings up a Control Panel when selected. 02198.51855/4429789.1 Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 (Compare Apple's Infringement Contentions at Ex. 1-3, e.g. Claim 4.) (Selecting "Control Panels" brings up a control panel allowing system control.) [11] The display system defined in claim 1 wherein each of the plurality of display areas is individually and variably sized. 02198.51855/4429789.1 SuperClock! for System 7 discloses that each of the plurality of display areas (e.g. the clock area and battery status area) is individually and variably sized. Asserted Claims From U.S. Patent No. 6,493,002 [12] The display system defined in claim 1 wherein the first window region always appears in front of application windows. 02198.51855/4429789.1 SuperClock! for System 7 SuperClock! for System 7 discloses that the first window region always appears in front of application windows. Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 (Showing that the menu bar is on top of the word programming application.) [13] The display system defined in claim 1 wherein the first window region is implemented in a private window layer that appears in front of windows for all applications layers. 02198.51855/4429789.1 SuperClock! for System 7 discloses that the first window region is implemented in a private window layer that appears in front of windows for all applications layers. Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 (Showing that the menu bar is on top of the word programming application.) [14A] An interactive computercontrolled display system comprising: See [1A]. a processor; a data display screen coupled to the processor; [14B] a cursor control device coupled to said processor for positioning a cursor on said data display screen; [14C] window generation and control logic coupled to the processor and data display screen to create an operating environment for a plurality of individual programming modules 02198.51855/4429789.1 See [1B]. See [1C]. Asserted Claims From U.S. Patent No. 6,493,002 associated with different application programs that provide status and/or control functions, [14D] wherein the window generation and control logic generates and displays a first window-region having a plurality of display areas on said data display screen, [14E] wherein the first window region is independently displayed and independently active of any application program, and [14F] wherein each of the plurality of display areas is associated with one of the plurality of individual programming modules, [14G] the first window region and the plurality of independent display areas implemented in a window layer that appears on top of application programming windows that may be generated; and [14H] at least one indicia graphics generation logic coupled to the processor and the window generation and control logic, 02198.51855/4429789.1 SuperClock! for System 7 See [1D]. See [1E]. See [1F]. See [1G]. See [1H] and [1I]. Asserted Claims From U.S. Patent No. 6,493,002 wherein said at least one indicia graphics generation logic generates user sensitive graphics for display in at least one data display area by executing at least one of the plurality of individual programming modules; [14I] wherein the window generation and control logic determines when said at least one data display area has been selected by the user and signals said at least one indicia graphics generation logic in response to user selection, and further wherein said at least one indicia graphics generation logic initiates a response from said at least one of the plurality of programming modules. 02198.51855/4429789.1 SuperClock! for System 7 SuperClock! for System 7 discloses that the window generation and control logic determines when at least one data display area (e.g., clock area) has been selected by the user and signals at least one indicia graphics generation logic in response to the user selection, where the indicia graphics generation logic initiates a response from at least one of the plurality of programming modules (e.g., clock module). For example, "If you want to hide the clock for awhile (for instance, if you're doing a presentation in MacroMind Director ), hold down the option key and click on the clock." ReadMe File at ¶3. "If you're running on a portable Macintosh, hold down the control key and click on the battery indicator to put the computer to sleep." ReadMe File at ¶4. "Clicking on the clock (with no keys held down) toggles between the time, date, and a count down/count up timer (clicking on the little timer icon will start or stop the timer)." ReadMe File at ¶5. Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 (Clicking on the clock area twice changes the clock into a timer. Clicking on the timer icon then starts and stops the timer.) See also [1J]. [15] The display system defined in claim 14 wherein the first window region is always visible to the user. 02198.51855/4429789.1 SuperClock! for System 7 discloses that the first window region is always visible to the user. Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 (Showing that the menu bar is on top of the word programming application.) [16] The display system defined in claim 14 wherein the first window region comprises a control strip. [17] The display system defined in claim 14 wherein said at least one display area is variably sized. [18] The display system defined in claim 14 wherein each of the plurality of display areas is individually and variably sized. [19] The display system defined in claim 14 wherein the first window region always appears in front of application windows. [20] The display system defined in claim 14 wherein the first window region is implemented in 02198.51855/4429789.1 See [2]. See also [11]. See [11]. See [12]. See [13]. Asserted Claims From U.S. Patent No. 6,493,002 a private window layer that appears in front of windows for all applications layers. [25A] A system comprising: a window generation and control logic to create an operating environment for a plurality of individual programming modules associated with different application programs that provide status and/or control functions, [25B] wherein the window generation and control logic generates and displays a first window region having a plurality of display areas, [25C] wherein the first window region is independently displayed and independently active of any application program, and [25D] wherein each of the plurality of display areas is associated with one of the plurality of individual programming modules, [25E] an indicia generation logic coupled to the data display screen to execute at least one of the plurality of individual 02198.51855/4429789.1 SuperClock! for System 7 See [1C]. See [1D]. See [1E]. See [1F]. See [1H]. Asserted Claims From U.S. Patent No. 6,493,002 programming modules to generate information for display in one of the plurality of display areas in the first window region, [25F] wherein at least one of the plurality of display areas and its associated programming module is sensitive to user input, and [25G] further wherein the window generation and control logic and the indicia generation logic use message-based communication to exchange information to coordinate activities of the indicia generation logic to enable interactive display activity. [26A] An interactive computercontrolled display system comprising: a means for positioning a cursor on a data display screen; [26B] a means for creating an operating environment for a plurality of individual programming modules associated with different application programs that provide status and/or control functions, 02198.51855/4429789.1 SuperClock! for System 7 See [1I]. See [1J]. See [1B]. In its infringement contentions, Apple only identified a “processor executing computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art. See [1C]. In its infringement contentions, Apple only identified a “processor executing computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art. Asserted Claims From U.S. Patent No. 6,493,002 [26C] wherein a first window region is displayed having a plurality of display areas on said data display screen, [26D] wherein each of the plurality of display areas is associated with one of the plurality of individual programming modules, [26E] the first window region and the plurality of independent display areas implemented in a window layer that appears on top of application programming windows that may be generated; and [26F] a means for executing at least one of the plurality of individual programming modules to generate information for display in one of the plurality of display areas in the first window region, [26G] wherein at least one of the plurality of display areas and its associated programming module is-sensitive to user input, wherein an interactive display activity is enabled. [27] The display system defined 02198.51855/4429789.1 SuperClock! for System 7 See [1D]. See [1F]. See [1G]. See [1H]. In its infringement contentions, Apple only identified a “processor executing computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art. See [1I] and [1J]. See [2]. Asserted Claims From U.S. Patent No. 6,493,002 in claim 26 wherein the first window region comprises a control strip. [28] The display system defined in claim 26 wherein said at least one of the plurality of display areas is variably sized. [29] The display system defined in claim 26 wherein size of the first window region is variable. [31] The display system defined in claim 29 wherein the first window regions is sized such that all of the plurality of display areas are visible. [32] The display system defined in claim 29 wherein the first window regions is sized such that a portion of the plurality of display areas is visible. [34] The display system defined in claim 26 wherein said at least one of the plurality of display areas acts to provide access to control information when selected. [35] The display system defined in claim 34 wherein said at least one of the data areas display an additional display element. 02198.51855/4429789.1 SuperClock! for System 7 See [3]. See [4]. See [6]. See [7]. See [9]. See [10]. Asserted Claims From U.S. Patent No. 6,493,002 [36] The display system defined in claim 26 wherein each of the plurality of display areas is individually and variably sized. [37] The display system defined in claim 26 wherein the first window region always appears in front of application windows. [38] The display system defined in claim 26 wherein the first window region is implemented in a private window layer that appears in front of windows for all application layers. [39A] An interactive computercontrolled display system comprising: a means for positioning a cursor on said data display screen; [39B] a means for creating an operating environment for a plurality of individual programming modules associated with different application programs that provide status and/or control functions, [39C] wherein a first window region is displayed having a plurality of display areas on said 02198.51855/4429789.1 SuperClock! for System 7 See [11]. See [12]. See [13]. See [1B]. In its infringement contentions, Apple only identified a “processor executing computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art. See [1C]. In its infringement contentions, Apple only identified a “processor executing computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art. See [1D]. Asserted Claims From U.S. Patent No. 6,493,002 data display screen, [39D] wherein the first window region is independently displayed and independently active of any application program, and [39E] wherein each of the plurality of display areas is associated with one of the plurality of individual programming modules, [39F] the first window region and the plurality of independent display areas implemented in a window layer that appears on top of application programming windows that may be generated; [39G] a means for generating user sensitive graphics for display in at least one data display area; SuperClock! for System 7 See [1E]. See [1F]. See [1G]. See also [1H] and [1I]. In its infringement contentions, Apple only identified a “processor executing computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art. [39H] a means for determining when said at least one data display area has been selected by the user; and See [1I]. In its infringement contentions, Apple only identified a “processor executing computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art. [39I] a means for initiating a See also [1J]. In its infringement contentions, Apple only identified a “processor executing 02198.51855/4429789.1 Asserted Claims From U.S. Patent No. 6,493,002 SuperClock! for System 7 response from said at least one of the plurality of programming modules. computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art. [40] The display system defined in claim 39 wherein the first window region is always visible to the user. [41] The display system defined in claim 39 wherein the first window region comprises a control strip. [42] The display system defined in claim 39 wherein said at least one data display area is variably sized. [43] The display system defined in claim 39 wherein each of the plurality of display areas is individually and variably sized. [44] The display system defined in claim 39 wherein the first window region always appears in front of application windows. [45] The display system defined in claim 39 wherein the first window region is implemented in a private window layer that See [15]. 02198.51855/4429789.1 See [2]. See [3]. See [11]. See [12]. See [13]. Asserted Claims From U.S. Patent No. 6,493,002 appears in front of windows for all applications layers. [50A] A system comprising: a means for window generation and control to create an operating environment for a plurality of individual programming modules associated with different application programs that provide status and/or control functions, [50B] wherein the means for window generation and control generates and displays a first window region having a plurality of display areas, SuperClock! for System 7 See [1C]. In its infringement contentions, Apple only identified a “processor executing computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art. See [1D]. In its infringement contentions, Apple only identified a “processor executing computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art. [50C] wherein the first window See [1E]. region is independently displayed and independently active of any application program, and [50D] wherein each of the See [1F]. plurality of display areas is associated with one of the plurality of individual programming modules, [50E] the first window region and See [1G]. the plurality of independent display areas implemented in a window layer that appears on top 02198.51855/4429789.1 Asserted Claims From U.S. Patent No. 6,493,002 of application programming windows that may be generated; [50F] a means for indicia generation coupled to the data display screen to execute at least one of the plurality of individual programming modules to generate information for display in one of the plurality of display areas in the first window region, [50G] wherein at least one of the plurality of display areas and its associated programming module is sensitive to user input, and [50H] further wherein the means for window generation and control and the means for indicia generation use message-based communication to exchange information to coordinate activities of the means for indicia generation to enable interactive display activity. 02198.51855/4429789.1 SuperClock! for System 7 See [1H]. In its infringement contentions, Apple only identified a “processor executing computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art. See [1I]. See [1J]. In its infringement contentions, Apple only identified a “processor executing computer instructions” as the corresponding structure. SuperClock! for System 7 discloses a “processor executing computer instructions.” In its infringement contentions, Apple failed to identify a corresponding algorithm. To the extent Apple is allowed and able to identify a corresponding algorithm, Samsung reserves the right to identify a corresponding algorithm in the prior art.

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?