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

Filing 675

Administrative Motion to File Under Seal re Exhibit 4 to Briggs Declaration in Support of Samsung's Motion to Supplement Invalidity Contentions filed by Samsung Electronics Co. Ltd.. (Attachments: #1 Baxter Declaration, #2 [Proposed] Public Redacted Version, #3 Proposed Order)(Maroulis, Victoria) (Filed on 1/27/2012)

EXHIBIT M-15
SAMSUNG’S INVALIDITY CLAIM CHARTS FOR MAC OS X, v.10.0 (Mac OS X)
Mac OS X is an operating system released by Apple on March 24, 2001. Mac OS X ran on a number of Macintosh computers,
including the Macintosh PowerBook G3, first released in 1998, and shown below. Other computers running Mac OS X are also
included as prior art to the '891 patent.

U.S. Patent No. 7,853,891
[1A] A method to display a user
interface window for a digital
processing system, the method
comprising:

02198.51855/4433168.2

Mac OS X
Mac OS X displays user interface windows for a digital processing system.

1

[1B] displaying a first window
in response to receiving a first
input from a user input device of
the digital processing system
which is capable of displaying at
least a portion of a second
window concurrently with the
first window on a screen;

02198.51855/4433168.2

Mac OS X displays a first window (e.g. brightness window) in response to receiving a first input
from a user input device (e.g. brightness key) of the digital processing system which is capable of
displaying at least a portion of a second window (e.g. "Applications" window) concurrently with
the first window on a screen.

2

[1C] starting a timer; and

Mac OS X discloses starting a timer.
F

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02198.51855/4433168.2

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[1D] closing the first window in
response to a determination that
the timer expired;

Mac OS X discloses that the first window (e.g., brightness window) is closed in response to a
determination that the timer expired (about 1 second).

(Showing display fading and closing after a set time.)

02198.51855/4433168.2

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02198.51855/4433168.2

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[1E] wherein the first window
does not close in response to any
input from a user input device of
the digital processing system,

02198.51855/4433168.2

Mac OS X discloses that the first window (e.g., brightness window) does not close in response to
any input from a user input device (e.g. mouse clicks or keyboard inputs) of the digital processing
system.

6

Mac OS X discloses that the first window (e.g., brightness window) is displayed independently
[1F] wherein the first window
has been displayed independently from a position of a cursor on the screen.
from a position of a cursor on the
screen.

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02198.51855/4433168.2

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02198.51855/4433168.2

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[2] A method as in claim 1
wherein the first window is
translucent; and the portion of
the second window is visible
while under the first window.

02198.51855/4433168.2

Mac OS X displays a translucent first window (e.g., brightness window) wherein a portion of the
second window (e.g., Application window) is visible while under the first window.

9

[3] A method as in claim 2
wherein the first window is at a
top level in a window displaying
hierarchy.

02198.51855/4433168.2

Mac OS discloses that the first window (e.g., brightness window) is displayed at the top level in a
window displaying hierarchy (e.g., user interface display hierarchy).
For example, the brightness window appears above other application windows.

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[5] A method as in claim 1
wherein said closing the first
window comprises: fading out an
image of the first window.

Mac OS X closes the first window (e.g., brightness window) by fading out the image of the first
window.

(Showing display fading and closing after a set time.)

02198.51855/4433168.2

11

[6] A method as in claim 1
wherein the second window, if
displayed, does close in response
to an input from a user input
device of the digital processing
system.

Mac OS X discloses that the second window (e.g., Applications window) closes in response to an
input from a user input device (e.g., clicking "X" using a mouse to close the Applications
window).

(Application window closing in response to clicking "X" to close.)

[7] A method as in claim 6
wherein the first window does
not respond to any input from a
user input device of the digital
processing system.

02198.51855/4433168.2

Mac OS X discloses that the first window (e.g., brightness window) does not respond to any input
from a user input device (e.g., mouse clicks and keyboard entries) of the digital processing system.

12

[14] A method as in claim 1
further comprising: determining
a position on a display of the
digital processing system
independent of a position of a
cursor on the display; wherein
the first window is displayed at
the position.

Mac OS X determines a position (e.g., bottom of the display) on a display of the digital processing
system independent of a position of a cursor on the display, and displays the first window (e.g.,
brightness window) at the position.

See also [1F].

02198.51855/4433168.2

13

[15] A method as in claim 14
wherein the position is centered
horizontally on the display.

02198.51855/4433168.2

Mac OS X displays a window (e.g. brightness window) centered horizontally on the display.

14

[16] A method as in claim 1
further comprising: restarting the
timer in response to receiving a
second input for the first
window.

Mac OS X discloses restarting the timer in response to receiving a second input (e.g. a second
brightness key press) for the first window (e.g. brightness window).
F

s not displayed when a message

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[17] A method as in claim 16
wherein the second input is
received from a user input device
of the digital processing system.

02198.51855/4433168.2

Mac OS X discloses that the second input is received form a user input device of the digital
processing system (e.g., brightness key).

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[18] A method as in claim 16
wherein the first window is
created by a first application and
the second window is created by
a second application, wherein the
first application is different from
the second application.

02198.51855/4433168.2

Mac OS X discloses that the first window (e.g. brightness window) is created by a first application
(e.g. brightness control application) and the second window (e.g. Microsoft Internet Explorer
window) is created by a second application (e.g. Microsoft Internet Explorer), wherein the first
application is different from the second application.

16

[19] A method as in claim 1
wherein the user input device is
one of: a) a keyboard; b) a
mouse; c) a track ball; d) a touch
pad; e) a touch screen; f) a joy
stick; and g) a button.

Mac OS X discloses that the user input device (e.g., brightness key) is a button.

[20A] A method to display a
user interface window for a
digital processing system, the
method comprising:

See [1A].

02198.51855/4433168.2

17

[20B] displaying a first window,
the first window being
translucent, at least a portion of a
second window being capable of
being displayed on the digital
processing system under the first
window, the portion of the
second window, when present,
being visible under the first
window on a screen; and

02198.51855/4433168.2

See [2].

18

[20C] closing the first window
without user input,

Mac OS X discloses that the first window (e.g., brightness window) is closed without user input.

(Showing display fading and closing without user input.)
See [1E].

02198.51855/4433168.2

19

[20D] wherein the first window
has been displayed independent
from a position of a cursor on the
screen.
[21] A method as in claim 20
further comprising: starting a
timer; wherein said closing the
first window is in response to
expiration of the timer.

02198.51855/4433168.2

See [1F].

See [1C].

20

[23] A method as in claim 20
further comprising: determining
whether or not a condition is
met; wherein said closing the
first window is in response to a
determination that the condition
is met.

Mac OS X determines whether a condition has been met (e.g., a timer has expired), and closes the
first window (e.g., "File" menu) upon determination that the condition was met.

(Showing display fading and closing when the timer has expired.)

02198.51855/4433168.2

21

[24] A method as in claim 20
wherein said closing the first
window comprises: fading out an
image of the first window.
[26A] A machine readable
media containing executable
computer program instructions
which when executed by a digital
processing system cause said
system to perform a method to
display a user interface window,
the method comprising:
[26B] displaying a first window
in response to receiving a first
input from a user input device of
the digital processing system
which is capable of displaying at
least a portion of a second
window concurrently with the
first window on a screen;
[26C] starting a timer; and
[26D] closing the first window
in response to a determination
that the timer expired;
[26E] wherein the first window
does not close in response to any
input from a user input device of
the digital processing system,
[26F] wherein the first window
has been displayed independently
from a position of a cursor on the
screen.

02198.51855/4433168.2

See [5].

Mac OS X discloses a machine readable media containing executable computer program
instructions which when executed by a digital processing system cause said system to perform a
method to display a user interface window.
For example, Mac OS X was distributed on optical disks.

See [1B].

See [1C].
See [1D].

See [1E].

See [1F].

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[27] A media as in claim 26
wherein the first window is
translucent; and the portion of
the second window is visible
while under the first window.
[28] A media as in claim 27
wherein the first window is at a
top level in a window displaying
hierarchy.
[30] A media as in claim 26
wherein said closing the first
window comprises: fading out an
image of the first window.
[31] A media as in claim 26
wherein the second window, if
displayed, does close in response
to an input from a user input
device of the digital processing
system.
[32] A media as in claim 31
wherein the first window does
not respond to any input from a
user input device of the digital
processing system.
[39] A media as in claim 26
wherein the method further
comprises: determining a
position on a display of the
digital processing system
independent of a position of a
cursor on the display; wherein
the first window is displayed at
the position.
02198.51855/4433168.2

See [2].

See [3].

See [5].

See [6].

See [7].

See [14].

23

[40] A media as in claim 39
wherein the position is centered
horizontally on the display.
[41] A media as in claim 26
wherein the method further
comprises: restarting the timer in
response to receiving a second
input for the first window.
[42] A media as in claim 41
wherein the second input is
received from a user input device
of the digital processing system.
[43] A machine readable media
as in claim 41 wherein the first
window is created by a first
application and the second
window is created by a second
application, wherein the first
application is different from the
second application.
[44] A media as in claim 26
wherein the user input device is
one of: a) a keyboard; b) a
mouse; c) a track ball; d) a touch
pad; e) a touch screen; f) a joy
stick; and g) a button.

02198.51855/4433168.2

See [15].

See [16].

See [17].

See [18].

See [19].

24

[45A] A machine readable
media containing executable
computer program instructions
which when executed by a digital
processing system cause said
system to perform a method to
display a user interface window,
the method comprising:
[45B] displaying a first window,
the first window being
translucent, at least a portion of a
second window being capable of
being displayed on the digital
processing system under the first
window, the portion of the
second window, when present,
being visible under the first
window on a screen; and
[45C] closing the first window
without user input,
[45D] wherein the first window
has been displayed independent
from a position of a cursor on the
screen.
[46] A media as in claim 45
wherein the method further
comprises: starting a timer;
wherein said closing the first
window is in response to
expiration of the timer.

02198.51855/4433168.2

See [20A].

See [20B].

See [20C].
See [20D].

See [21].

25

[48] A media as in claim 45
wherein the method further
comprises: determining whether
or not a condition is met;
wherein said closing the first
window is in response to a
determination that the condition
is met.
[49] A media as in claim 45
wherein said closing the first
window comprises: fading out an
image of the first window.
[51A] A digital processing
system to display a user interface
window, the system comprising:
[51B] means for displaying a
first window in response to
receiving a first input from a user
input device of the digital
processing system which is
capable of displaying at least a
portion of a second window
concurrently with the first
window on a screen;
[51C] means for starting a timer;
and

02198.51855/4433168.2

See [23],

See [5],

Mac OS X is a digital processing system to display user interface windows.

See [1B]. In its infringement contentions, Apple only identified a “processor executing computer
instructions” as the corresponding structure. Mac OS X is operated on 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. Mac OS X is operated on 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.

26

[51D] means for closing the first
window in response to a
determination that the timer
expired;
[51E] wherein the first window
does not close in response to any
input from a user input device of
the digital processing system,
[51F] wherein the first window
has been displayed independently
from a position of a cursor on the
screen.
[52] A digital processing system
as in claim 51 wherein the first
window is translucent; and the
portion of the second window is
visible while under the first
window.
[53] A digital processing system
as in claim 52 wherein the first
window is at a top level in a
window displaying hierarchy.
[55] A digital processing system
as in claim 51 wherein said
means for closing the first
window comprises: means for
fading out an image of the first
window.

02198.51855/4433168.2

See [1D]. In its infringement contentions, Apple only identified a “processor executing computer
instructions” as the corresponding structure. Mac OS X is operated on 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 [1E].

See [1F].

See [2].

See [3].

See [5].

27

[56] A digital processing system
as in claim 51 wherein the
second window, if displayed,
does close in response to an input
from a user input device of the
digital processing system.
[57] A digital processing system
as in claim 56 wherein the first
window does not respond to any
input from a user input device of
the digital processing system.
[64] A digital processing system
as in claim 51 further
comprising: means for
determining a position on a
display of the digital processing
system independent of a position
of a cursor on the display;
wherein the first window is
displayed at the position.
[65] A digital processing system
as in claim 64 wherein the
position is centered horizontally
on the display.
[66] A digital processing system
as in claim 51 further
comprising: means for restarting
the timer in response to receiving
a second input for the first
window.

02198.51855/4433168.2

See [6].

See [7].

See [14]. In its infringement contentions, Apple only identified a “processor executing computer
instructions” as the corresponding structure. Mac OS X is operated on 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 [15].

See [16]. In its infringement contentions, Apple only identified a “processor executing computer
instructions” as the corresponding structure. Mac OS X is operated on 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.

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[67] A digital processing system
as in claim 66 wherein the
second input is received from a
user input device of the digital
processing system.
[68] A digital processing system
as in claim 66 wherein the first
window is created by a first
application and the second
window is created by a second
application, wherein the first
application is different from the
second application.
[69] A digital processing system
as in claim 51 wherein the user
input device is one of: a) a
keyboard; b) a mouse; c) a track
ball; d) a touch pad; e) a touch
screen; f) a joy stick; and g) a
button.
[70A] A digital processing
system to display a user interface
window, the system comprising:
[70B] means for displaying a
first window, the first window
being translucent, at least a
portion of a second window
being capable of being displayed
on the digital processing system
under the first window, the
portion of the second window,
when present, being visible under
the first window on a screen; and
02198.51855/4433168.2

See [17].

See [18].

See [19].

See [51A].

See [20B]. In its infringement contentions, Apple only identified a “processor executing computer
instructions” as the corresponding structure. Mac OS X is operated on 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.

29

[70C] means for closing the first
window without user input,

[70D] wherein the first window
has been displayed independent
from a position of a cursor on the
screen.
[71] A digital processing system
as in claim 70 further
comprising: means for starting a
timer; wherein the first window
is closed in response to
expiration of the timer.
[73] A digital processing system
as in claim 70 further
comprising: means for
determining whether or not a
condition is met; wherein the
first window is closed in
response to a determination that
the condition is met.
[74] A digital processing system
as in claim 70 wherein said
means for closing the first
window comprises: means for
fading out an image of the first
window.

02198.51855/4433168.2

See [1E]. In its infringement contentions, Apple only identified a “processor executing computer
instructions” as the corresponding structure. Mac OS X is operated on 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 [1F].

See [51C] and [51D].

See [23]. In its infringement contentions, Apple only identified a “processor executing computer
instructions” as the corresponding structure. Mac OS X is operated on 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 [55].

30