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

Filing 91

Declaration of Ravin Balakrishnan in Support of #86 MOTION for Preliminary Injunction filed byApple Inc.. (Attachments: #1 Exhibit 1, #2 Errata 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 13a, #14 Exhibit 13b, #15 Exhibit 13c, #16 Exhibit 13d, #17 Exhibit 13e, #18 Exhibit 13f, #19 Exhibit 13g, #20 Exhibit 13h)(Related document(s) #86 ) (Bartlett, Jason) (Filed on 7/1/2011)

Exhibit 12

displaying a first portion of an electronic
document;

A computer-implemented method,
comprising: at a device with a touch screen
display:

Claim 1 of U.S. Patent No. 7,469,381

-1-

The Galaxy Tab 10.1 includes an application called “Gallery” that displays electronic
documents — more specifically, photographs — on the touch screen display. When
running the “Gallery” application, the Galaxy Tab 10.1 displays a first portion of a
photograph. (Ex. 13g.)

(Galaxy Tab 10.1 User Manual (Ex. 9) at 10.)

The Galaxy Tab 10.1 is a mobile computing device with a touch screen display.

Samsung Galaxy Tab 10.1

Infringement Claim Chart for U.S. Patent No. 7,469,381 v. Samsung Galaxy Tab 10.1

The Galaxy Tab 10.1 detects the movement of an “object” — for instance, a finger —
on its touch screen. In response, it scrolls the photograph in the same direction to
display a second, different portion of the photograph. (Ex. 13g.)

detecting a movement of an object on or
near the touch screen display; in response
to detecting the movement, translating the
electronic document displayed on the touch
screen display in a first direction to display
a second portion of the electronic
document, wherein the second portion is
different from the first portion;

-2-

Samsung Galaxy Tab 10.1

Claim 1 of U.S. Patent No. 7,469,381

In response to reaching an edge of a photograph, while a finger continues to move the
photograph in the same direction, the Galaxy Tab 10.1 displays a black region beyond
the photograph’s edge, and thus displays a third, smaller portion of the photograph.
(Ex. 13g.)

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 display:
displaying an area beyond the edge of the
document, and displaying a third portion of
the electronic document, wherein the third
portion is smaller than the first portion; and

-3-

Samsung Galaxy Tab 10.1

Claim 1 of U.S. Patent No. 7,469,381

In response to detecting that the finger is no longer on the touch screen, the Galaxy Tab
10.1 scrolls the photograph in the opposite direction until it no longer displays the area
beyond the photograph’s edge. What is then displayed is a fourth portion of the
photograph that is different from the first portion. (Ex. 13g.)

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

-4-

Samsung Galaxy Tab 10.1

Claim 1 of U.S. Patent No. 7,469,381

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 document are
displayed at the same magnification.

Claim 2 of U.S. Patent No. 7,469,381

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The entire sequence illustrated in Claim 1 is depicted below in a side-by-side
comparison. As is evident from this comparison, the portions of the photograph are
displayed at the same magnification.

Samsung Galaxy Tab 10.1

Samsung Galaxy Tab 10.1

In the sequence illustrated in Claim 1, the first direction is a horizontal direction —
specifically, to the right.

Samsung Galaxy Tab 10.1

In the sequence illustrated in Claim 1, the object that moves on the touch screen
display is a finger.

Samsung Galaxy Tab 10.1

In the sequence illustrated in Claim 1, the movement of the finger is on the touch
screen display.

Samsung Galaxy Tab 10.1

-6-

The computer-implemented method of
In the sequence illustrated in Claim 1, the electronic document is a digital image,
claim 1, wherein the electronic document is namely a digital photograph.
a digital image.

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

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

Claim 5 of U.S. Patent No. 7,469,381

The computer-implemented method of
claim 1, wherein the object is a finger.

Claim 4 of U.S. Patent No. 7,469,381

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

Claim 3 of U.S. Patent No. 7,469,381

The Galaxy Tab 10.1 also includes a web browser application called “Browser” that
displays an electronic document including a list of items – specifically, a list of news
articles. For instance, the Browser application may display a web page, such as the
New York Times home page, that includes a list of links to articles. When running the
“Browser” application on such a web page, the Galaxy Tab 10.1 performs the method
of claim 1. (Ex. 13h.)

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

-7-

Samsung Galaxy Tab 10.1

Claim 9 of U.S. Patent No. 7,469,381

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

Claim 14 of U.S. Patent No. 7,469,381

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

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

Claim 10 of U.S. Patent No. 7,469,381

-8-

In the sequence illustrated in Claim 1, the area beyond the edge of the photograph is
black. This area is visually distinct from the photograph itself, which is in color.

Samsung Galaxy Tab 10.1

In the sequence illustrated in Claim 1, the area beyond the edge of the photograph is
black.

Samsung Galaxy Tab 10.1

In the sequence illustrated in Claim 1, the “first direction” is to the right, while the
“second direction” is opposite, to the left.

Samsung Galaxy Tab 10.1

In the sequence illustrated in Claim 1, in response to detecting that the finger is no
longer on the touch screen, the Galaxy Tab 10.1 changes from scrolling the photograph
in the first direction (to the right) to scrolling the photograph in the opposite direction
(to the left). This change makes the photograph appear to “snap” or “bounce” back to
the left, as though the photograph were elastically attached to the edge of the touch
screen display.

Samsung Galaxy Tab 10.1

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

-9-

A device, comprising: a touch screen
The Galaxy Tab 10.1 is a mobile computing device with a touch screen display:
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
(Galaxy Tab 10.1 User Manual (Ex. 9) at 10); a “Dual Core Tegra 2 processor” (Ex. 5
more processors, the programs including:
at 5); “Memory Internal” of “16 GB” (Ex. 5 at 7); and the “Gallery” and “Browser”
applications stored in memory. (Exs. 13g-13h.)

Samsung Galaxy Tab 10.1

Claim 16 of U.S. Patent No. 7,469,381

The Galaxy Tab 10.1 includes an application called “Gallery” with instructions for
displaying electronic documents — more specifically, photographs — on the touch
screen display. When running the “Gallery” application, the Galaxy Tab 10.1 displays
a first portion of a photograph. (Ex. 13g.)

instructions for displaying a first portion of
an electronic document;

- 10 -

Samsung Galaxy Tab 10.1

Claim 19 of U.S. Patent No. 7,469,381

The Galaxy Tab 10.1 includes instructions for detecting the movement of an “object”
— for instance, a finger — on its touch screen. In response, it scrolls the photograph in
the same direction to display a second, different portion of the photograph. (Ex. 13g.)

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;

- 11 -

Samsung Galaxy Tab 10.1

Claim 19 of U.S. Patent No. 7,469,381

instructions for displaying an area beyond
an edge of the electronic document and
displaying a third portion of the electronic
document, wherein the third portion is
smaller than the first portion, in response to
the edge of the electronic document being
reached while translating the electronic
document in the first direction while the
object is still detected on or near the touch
screen display; and

Claim 19 of U.S. Patent No. 7,469,381

- 12 -

The Galaxy Tab 10.1 includes instructions for displaying a black region beyond the
photograph’s edge in response to reaching an edge of a photograph, while a finger
continues to move the photograph in the same direction, and thus displays a third,
smaller portion of the photograph. (Ex. 13g.)

Samsung Galaxy Tab 10.1

The Galaxy Tab 10.1 includes instructions for scrolling the photograph in the opposite
direction until it no longer displays the area beyond the photograph’s edge, in response
to detecting that the finger is no longer on the touch screen. What is then displayed is a
fourth portion of the photograph that is different from the first portion. (Ex. 13g.)

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.

- 13 -

Samsung Galaxy Tab 10.1

Claim 19 of U.S. Patent No. 7,469,381

display a first portion of an electronic
document;

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

Claim 20 of U.S. Patent No. 7,469,381

- 14 -

The Galaxy Tab 10.1 includes an application called “Gallery” that displays electronic
documents — more specifically, photographs — on the touch screen display. When
running the “Gallery” application, the Galaxy Tab 10.1 displays a first portion of a
photograph. (Ex. 13g.)

(Galaxy Tab 10.1 User Manual (Ex. 9) at 10); a “Dual Core Tegra 2 processor” for
executing instructions (Ex. 5 at 5); a computer readable storage medium (“Memory
Internal” of “16 GB”) (Ex. 5 at 7); and the “Gallery” and “Browser” applications stored
in memory. (Exs. 13g-13h.)

The Galaxy Tab 10.1 is a mobile computing device with a touch screen display:

Samsung Galaxy Tab 10.1

The Galaxy Tab 10.1 detects the movement of an “object” — for instance, a finger —
on its touch screen. In response, it scrolls the photograph in the same direction to
display a second, different portion of the photograph. (Ex. 13g.)

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

- 15 -

Samsung Galaxy Tab 10.1

Claim 20 of U.S. Patent No. 7,469,381

In response to reaching an edge of a photograph, while a finger continues to move the
photograph in the same direction, the Galaxy Tab 10.1 displays a black region beyond
the photograph’s edge, and thus displays a third, smaller portion of the photograph.
(Ex. 13g.)

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

- 16 -

Samsung Galaxy Tab 10.1

Claim 20 of U.S. Patent No. 7,469,381

In response to detecting that the finger is no longer on the touch screen, the Galaxy Tab
10.1 scrolls the photograph in the opposite direction until it no longer displays the area
beyond the photograph’s edge. What is then displayed is a fourth portion of the
photograph that is different from the first portion. (Ex. 13g.)

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.

- 17 -

Samsung Galaxy Tab 10.1

Claim 20 of U.S. Patent No. 7,469,381