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).

EXHIBIT 6

EXHIBIT G-7
SAMSUNG’S INVALIDITY CLAIM CHARTS FOR GLIMPSE1 COMMERCIALLY SOLD, PUBLICLY KNOWN, OR
PUBLICLY USED BEFORE JANUARY 7, 2007 (“Glimpse”)
U.S. Patent No. 7,469,381
[1A] A computer-implemented
method, comprising:

Glimpse
Glimpse discloses a computer-implemented method.
For example, Forlines discloses, “We have used both a TabletPC and a touch sensitve
DiamondTouch surface as our pressure sensitive input device.” Forlines at 2.
The images shown herein come from a Toshiba Portege M200, an example of a TabletPC operating
Glimpse.

1

Glimpse is a program disclosed in Forlines, C. Shen, C., and Buxton, B. “Glimpse: a Novel Input Model for Multi-level
Devices (“Forlines”). In CHI '05 Extended Abstracts on Human Factors in Computing Systems (Portland, OR, USA, April 02 - 07,
2005). CHI '05. ACM Press, New York, NY, 1375-1378. The device was demonstrated at the 2005 CHI Conference, among other
locations, more than one year prior to the filing date of the ’381 patent.

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U.S. Patent No. 7,469,381

[1B] at a device with a touch
screen display

Glimpse

Glimpse discloses a device with a touch screen display (e.g. Tablet PC).
For example, Forlines discloses, “The technique we propose provides a method for editing objects
with a multi-level input device such as a pressure sensitive stylus, pressure sensitive touch screen,
or popthrough mouse.” Forlines at 2.
The Toshiba Portege M200 is a tablet PC with a display sensitive to touches from a stylus.

[1C] displaying a first portion
of an electronic document;

Glimpse discloses displaying a first portion of an electronic document (e.g. satellite photo).
For example, by translating the stylus to the right Glimpse displays a first portion of the electronic
document (a satellite image) as shown below:

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U.S. Patent No. 7,469,381

[1D] 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

02198.51855/4556457.1

Glimpse

Glimpse detects a movement of an object (e.g. stylus) on or near the touch screen display. In
response to detecting the movement (e.g. movement of the stylus), the touchscreen display
translates 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.
For example, as the user moves the stylus to the left, the electronic document is seen moving to the
right to display a second portion of the electronic document.

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U.S. Patent No. 7,469,381

Glimpse

portion is different from the
first portion;

[1E] 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, and displaying a
third portion of the electronic

02198.51855/4556457.1

Glimpse discloses that in response to an edge of the electronic document being reached while
translating the electronic document in the first direction while the object (e.g. stylus) 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.
For example, as the user reaches the leftmost edge of the electronic document, a white background
area beyond the edge of the electronic document is displayed. There is no content within or beyond
this area.

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U.S. Patent No. 7,469,381

Glimpse

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

[1F] 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

02198.51855/4556457.1

Glimpse discloses that in response to detecting that the object (e.g. stylus) 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.
When the user lifts her finger in the process of scrolling, the interface will automatically snap back
to realign the document to a predetermined position. This position can be set at the edge of the
electronic document, as shown below. 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
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U.S. Patent No. 7,469,381

Glimpse

portion of the electronic
document, wherein the fourth
portion is different from the
first portion.

beyond the edge of the electronic document can no longer be seen. As a result, a fourth portion of
the document is displayed. The fourth portion is different from the first portion.

[2] 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

Glimpse discloses the first, second, third, and fourth portions are all at the same magnification.

02198.51855/4556457.1

For example, the four portions previously described are all displayed at the same magnification.

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U.S. Patent No. 7,469,381
document are displayed at the
same magnification.
[3] The computer implemented
method of claim 1, wherein the
movement of the object is on
the touch screen display.
[4] The computer-implemented
method of claim 1, wherein the
object is a finger.

Glimpse

Glimpse detects the movement of an object on a touch screen display.
For example, the touch screen display accept input from a stylus.
Glimpse detects the movement of a finger on the touch screen display.
For example, Glimpse installed on a DiamondTouch system accepts inputs based on the movement
of a finger. Forlines discloses, “We have used both a TabletPC and a touch sensitve DiamondTouch
surface as our pressure sensitive input device.” Forlines at 2. Forlines also discloses, “In other
words, the pointing device itself (be it finger or stylus) becomes the tracking pointer.” Id.

[5] The computer-implemented
method of claim 1, wherein the
first direction is a vertical
direction, a horizontal direction,
or a diagonal direction.

Glimpse discloses the first direction is a vertical direction, a horizontal direction, or a diagonal
direction.

[6] The computer-implemented
method of claim 1, wherein the
electronic document is a web
page.

Glimpse discloses the electronic document is a web page.

For example, Glimpse permits the first direction to be any direction on the screen, because it allows
the user to scroll freely across the image.

For example, Glimpse operates on a TabletPC running Microsoft Windows. That computer could
also run a web browser.
To the extent that Glimpse does not disclose this claim element, having a web page would have

02198.51855/4556457.1

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U.S. Patent No. 7,469,381

Glimpse
been a simple design choice representing a trivial and predictable variation. It was well-known in
the art to have a web page. For example, Lira, another graphical user interface, discloses a web
page. It would have been obvious to one of ordinary skill in the art to combine the disclosures of
Glimpse with Lira, because these references describe graphical user interfaces involving scrolling
on touch-screen display-based electronic devices. Furthermore, these references describe the
specific use of reversal of scrolling direction to convey information to the user. See Exhibit G-1.

[7] The computer-implemented
method of claim 1, wherein the
electronic document is a digital
image.

02198.51855/4556457.1

Glimpse discloses the electronic document is a digital image.
For example, Glimpse operates on the digital image below.

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U.S. Patent No. 7,469,381

Glimpse

[8] The computer-implemented
method of claim 1, wherein the
electronic document is a word
processing, spreadsheet, email
or presentation document.

Glimpse discloses the electronic document is a word processing, spreadsheet, email or presentation
document.
For example, Glimpse also discloses that the electronic document is a spreadsheet: “When
navigating through a dataset using a pan and zoom interface, one often wants to temporarily zoomin in order to take a more detailed look at some portion of the data before returning to the current
zoom level.”
Glimpse also discloses the electronic document is a word processing document: “While working on
this paper, the authors commonly scrolled to the end of this document in order to glance at the
paper’s references. Similarly, when editing code, a programmer often uses a scroll bar to take a
quick look at the details of another method or the definition of a variable. Our technique would
enable a user to scroll to and view another portion of a long document before returning to the exact
location they were previously editing.”

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U.S. Patent No. 7,469,381

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

Glimpse

Glimpse discloses the electronic document includes a list of documents.
For example, word processing or spreadsheet documents can include a list of items. See [8].
To the extent that Glimpse does not disclose this claim element, having an electronic document that
includes a list of items would have been a simple design choice representing a trivial and
predictable variation. It was well-known in the art that an electronic document could include a list
of items. For example, Van Den Hoven and Ording both disclose the use of a list of items. It
would have been obvious to one of ordinary skill in the art to combine the disclosures of the
Glimpse with Van Den Hoven and Ording, because these references describe graphical user

02198.51855/4556457.1

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U.S. Patent No. 7,469,381

Glimpse
interfaces involving scrolling on touch-screen display-based electronic devices. Furthermore, these
references describe the specific use of reversal of scrolling direction to convey information to the
user. See Exhibits G-2 and G-3.

[10] The computerimplemented method of claim
1, wherein the second direction
is opposite the first direction

02198.51855/4556457.1

Glimpse discloses that the second direction is opposite the first direction.
For example, the first and second directions in the example below are in opposite directions.

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U.S. Patent No. 7,469,381

Glimpse

[11] The computerimplemented 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.

To the extent that Glimpse does not disclose this claim element, having an associated speed of
translation that corresponds to a speed of movement of the object would have been a simple design
choice representing a trivial and predictable variation. It was well-known in the art to have an
associated speed of translation that corresponds to a speed of movement. For example, both Ording
and Van Den Hoven, which also involve graphical user interfaces, disclose having an associated
speed of translation that corresponds to a speed of movement. It would have been obvious to one of
ordinary skill in the art to combine the disclosures of Glimpse with any one of Van Den Hoven or
Ording, because all of these references describe graphical user interfaces involving scrolling on
touch-screen display-based electronic devices. See Exhibits G-2 and G-3.

[12] The computerimplemented method of claim
1, wherein translating in the
first direction is in accordance
with a simulation of an
equation of motion having
friction.

Glimpse discloses that translating in the first direction is in accordance with a simulation of an
equation of motion having friction.

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U.S. Patent No. 7,469,381

Glimpse

To the extent Glimpse does not disclose this claim element, a simulation of an equation of motion
having friction would have been a simple design choice representing a trivial and predictable
variation. It was well-known in the art to use a simulation of an equation of motion having friction.
For example, both Ording and Van Den Hoven, which also involve graphical user interfaces,
disclose a simulation of an equation of motion having friction. It would have been obvious to one
of ordinary skill in the art to combine the disclosures of Glimpse with any one of Van Den Hoven or
Ording, because all of these references describe graphical user interfaces involving scrolling on
touch-screen display-based electronic devices. See Exhibits G-2 and G-3.
[13] The computerimplemented method of claim
1, wherein the area beyond the
edge of the document is black,
gray, a solid color, or white.

02198.51855/4556457.1

Glimpse discloses the area beyond the edge of the document is black, gray, a solid color, or white.
For example, the area beyond the edge appears white.

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U.S. Patent No. 7,469,381

Glimpse

[14] The computerimplemented method of claim
1, wherein the area beyond the
edge of the document is
visually distinct from the
document.

Glimpse discloses the area beyond the edge of the document is visually distinct from the document.

[15] The computerimplemented method of claim
02198.51855/4556457.1

For example, the area beyond the edge is white, while the image is various colors of gray.

Glimpse discloses that translating the document in the second direction is a damped motion.
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U.S. Patent No. 7,469,381

Glimpse

1, wherein translating the
document in the second
direction is a damped motion.

To the extent that Glimpse does not disclose this claim element, translating the document in the
second direction with a damped motion would have been a simple design choice representing a
trivial and predictable variation. It was well-known in the art to use a damped motion. For
example, both Ording and Van Den Hoven, which also involve graphical user interfaces, disclose
using a damped motion. It would have been obvious to one of ordinary skill in the art to combine
the disclosures of Glimpse with any one of Van Den Hoven or Ording, because all of these
references describe graphical user interfaces involving scrolling on touch-screen display-based
electronic devices. Furthermore, all of these references describe the specific use of reversal of
scrolling direction to convey information to the user. See Exhibits G-2 and G-3.

[16] The computerimplemented method of claim
1, wherein changing from
translating in the first direction

02198.51855/4556457.1

See [1F].

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U.S. Patent No. 7,469,381
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.
[17] The computerimplemented 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.

02198.51855/4556457.1

Glimpse

To the extent that Glimpse does not disclose this claim element, having the second associated
translating distance be less than a distance of movement of the object after reaching the edge of the
electronic document would have been a simple design choice representing a trivial and predictable
variation. It was well-known in the art to have a second translating distance less than a distance of
movement of the object. For example, both Ording and Van Den Hoven, which also involve
graphical user interfaces, disclose Claim 17. It would have been obvious to one of ordinary skill in
the art to combine the disclosures of Glimpse with any one of Van Den Hoven or Ording, because
all of these references describe graphical user interfaces involving scrolling on touch-screen
display-based electronic devices. Furthermore, all of these references describe the specific use of
reversal of scrolling direction to convey information to the user. See Exhibits G-2 and G-3.

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U.S. Patent No. 7,469,381

Glimpse

[18] The computerimplemented 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.
[19A] A device, comprising:
[19B] a touch screen display;
[19C] one or more processors;

To the extent that Glimpse does not disclose this claim element, Claim 18 would have been a simple
design choice representing a trivial and predictable variation. It was well-known in the art to have
the second associated translating speed slower than the first associated translating speed. For
example, both Ording and Van Den Hoven, which also involve graphical user interfaces, disclose
Claim 18. It would have been obvious to one of ordinary skill in the art to combine the disclosures
of Glimpse with any one of Van Den Hoven or Ording, because all of these references describe
graphical user interfaces involving scrolling on touch-screen display-based electronic devices.
Furthermore, all of these references describe the specific use of reversal of scrolling direction to
convey information to the user. See Exhibits G-2 and G-3.

[19D] memory; and
[19E] 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:

02198.51855/4556457.1

See [1A].
See [1B].
See [1A].
See [1A].
See [1A].
Moreover, to the extent that Glimpse does not disclose this claim element, the use of 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, would have been a simple design choice representing a
trivial and predictable variation. It was well-known in the art to use one or more programs. For
example, Ording, which also involves graphical user interfaces, discloses the use of one or more
programs. It would have been obvious to one of ordinary skill in the art to combine the disclosures
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U.S. Patent No. 7,469,381

Glimpse
of Glimpse with Ording, because these references describe graphical user interfaces involving
scrolling on touch-screen display-based electronic devices. Furthermore, these references describe
the specific use of reversal of scrolling direction to convey information to the user. See Exhibit G3.

[19F] instructions for
displaying a first portion of an
electronic document;

[19G] 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;
[19H] instructions for
displaying an area beyond an

02198.51855/4556457.1

See [1C].
Moreover, to the extent that Glimpse does not disclose this claim element, the use of instructions for
displaying a first portion of an electronic document would have been a simple design choice
representing a trivial and predictable variation. It was well-known in the art to use instructions for
displaying a first portion of an electronic document. For example, Ording, which also involves
graphical user interfaces, discloses the use of instructions for displaying a first portion of an
electronic document. It would have been obvious to one of ordinary skill in the art to combine the
disclosures of Glimpse with Ording, because these references describe graphical user interfaces
involving scrolling on touch-screen display-based electronic devices. Furthermore, these references
describe the specific use of reversal of scrolling direction to convey information to the user. See
Exhibit G-3.
See [1D].
Moreover, to the extent that Glimpse does not disclose this claim element, the use of instructions
would have been a simple design choice representing a trivial and predictable variation. It was
well-known in the art to use instructions. For example, Ording, which also involves graphical user
interfaces, discloses the use of instructions. It would have been obvious to one of ordinary skill in
the art to combine the disclosures of Glimpse with Ording, because these references describe
graphical user interfaces involving scrolling on touch-screen display-based electronic devices.
Furthermore, these references describe the specific use of reversal of scrolling direction to convey
information to the user. See Exhibit G-3.

See [1E].

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U.S. Patent No. 7,469,381

Glimpse

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
[19I] 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.
[20A] A computer readable
storage medium having stored
therein instructions, which
when executed by a device with
a touch screen display, cause
the device to:

Moreover, to the extent that Glimpse does not disclose this claim element, the use of instructions
would have been a simple design choice representing a trivial and predictable variation. It was
well-known in the art to use instructions. For example, Ording, which also involves touch screen
user interfaces, discloses the use of instructions. It would have been obvious to one of ordinary skill
in the art to combine the disclosures of Glimpse with Ording, because these references describe
graphical user interfaces involving scrolling on touch-screen display-based electronic devices.
Furthermore, these references describe the specific use of reversal of scrolling direction to convey
information to the user. See Exhibit G-3.

02198.51855/4556457.1

See [1F].
Moreover, to the extent that Glimpse does not disclose this claim element, the use of instructions
would have been a simple design choice representing a trivial and predictable variation. It was
well-known in the art to use instructions. For example, Ording, which also involves touch screen
user interfaces, discloses the use of instructions. It would have been obvious to one of ordinary skill
in the art to combine the disclosures of Glimpse with Ording, because these references describe
graphical user interfaces involving scrolling on touch-screen display-based electronic devices.
Furthermore, these references describe the specific use of reversal of scrolling direction to convey
information to the user. See Exhibit G-3.

See [1A]-[1B].
Moreover, to the extent that Glimpse does not disclose this claim element, a computer readable
storage medium having instructions would have been a simple design choice representing a trivial
and predictable variation. It was well-known in the art to use a computer readable storage medium
having instructions. For example, Ording, which also involves touch screen user interfaces,
discloses a computer readable storage medium having instructions. It would have been obvious to
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U.S. Patent No. 7,469,381

Glimpse
one of ordinary skill in the art to combine the disclosures of Glimpse with Ording, because these
references describe graphical user interfaces involving scrolling on touch-screen display-based
electronic devices. Furthermore, these references describe the specific use of reversal of scrolling
direction to convey information to the user. See Exhibit G-3.

[20B] display a first portion of
an electronic document;
[20C] 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;
[20D] 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
[20E] translate the electronic
02198.51855/4556457.1

See [1C]
See [1D].

See [1E].

See [1F].
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U.S. Patent No. 7,469,381

Glimpse

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.

02198.51855/4556457.1

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