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

Filing 143

Appendix re #142 Opposition/Response to Motion, filed byGoogle Inc.. (Related document(s) #142 ) (Candido, Amy) (Filed on 4/28/2012)

Appendix A
Apple’s April 5, 2012
Subpoena to Google
1. A copy of the Android
mobile platform, in source
code form, provided to
Samsung for use in the
Samsung Galaxy Nexus.

Previous Subpoenas from Apple
All Source Code and Software Documentation that Google provides or has
provided to HTC.
(I.T.C. 710, Aug. 10, 2010, No. 11.)
All Source Code and Software Documentation that Google provides or has
provided to HTC.
(N.D. Ill. 11-8540, May 20, 2011, No. 14.)
All Source Code and Software Documentation that Google provides or has
provided to Motorola.
(I.T.C. 750, May 16, 2011, No. 7.)
All Source Code and Software Documentation that Google provides or has
provided to HTC.
(I.T.C. 797, Feb. 2, 2012, No. 10.)

2. A copy of the Android
mobile platform, in source
code form, used by
Samsung in the Samsung
Galaxy Nexus.

All Source Code and Software Documentation for each of the Accused
Products, including but not limited to Android 1.5, 1.6, 2.1, 2.2, 2.3, 3.0, and
4.0 and any proprietary Source Code.
(I.T.C. 797, Feb. 2, 2011, No. 8.)
All Source Code and Software Documentation for each of the Motorola
Accused Products, including but not limited to Android 1.5, 1.6, 2.1, and 2.2,
and any proprietary Source Code.
(I.T.C. 710, Aug. 10, 2010, No. 9.)
All Source Code and Software Documentation for each of the Motorola
Accused Products, including but not limited to Android 1.5, 1.6, 2.1, 2.2, 2.3,
and 3.0 and any proprietary Source Code.
(N.D. Ill. 11-8540, May 20, 2011, No. 14.)
All Source Code and Software Documentation for each of the Motorola
Accused Mobile Devices, including but not limited to Android 1.5, 1.6, 2.1, 2.2,
2.3, and 3.0 and any proprietary Source Code.
(S.D. Fla. 10-23580, Nov. 3, 2011, No. 5.)
All Source Code and Software Documentation for each of the Motorola
Accused Mobile Devices, including but not limited to Android 1.5, 1.6, 2.1, 2.2,
2.3, and 3.0 and any proprietary Source Code.
(I.T.C. 750, May 16, 2011, No. 6.)

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Appendix A
Apple’s April 5, 2012
Subpoena to Google
3. Documents sufficient to
show any and all
differences between the
Android mobile platform
source code provided in
response to Request No. 1
and the Android 4.0 Ice
Cream Sandwich code
publicly available from
https://android.googlesour
ce.com/platform/manifest,
or through the process
described at
http://source.android.com/s
ource/downloading.html.

Previous Subpoenas from Apple
Documents and Things sufficient to fully describe, for each Motorola Accused
Product, the existence and nature of any differences between the Open Source
Android code available at http://source.android.com/source/download.html and
the Android Platform Source Code provided by Google to Motorola.
(N.D. Ill. 11-8540, May 20, 2011, No. 11.)
Documents and Things sufficient to fully describe, for each Motorola Accused
Mobile Device, the existence and nature of any differences between the Open
Source Android Code available at
http://source.android.com/source/download.html and the Android Platform
Source Code provided by Google to Motorola.
(S.D. Fla. 10-23580, Nov. 3, 2011, No. 5.)
For each Accused HTC Android Product, Documents sufficient to show any
and all differences in the Open Source Android code available at
http://source.android.com/source/download.html and the Android Platform
Source Code provided by Google to HTC.
(ITC 710, Aug. 27, 2010, No. 18.)
Documents and Things sufficient to fully describe, for each Motorola Accused
Mobile Device, the existence and nature of any differences between the Open
Source Android code available at
http://source.android.com/source/download.html and the Android Platform
Source Code provided by Google to Motorola.
(I.T.C. 750, May 16, 2011, No. 5 (Deposition Topic).)
Document sufficient to show any and all differences in the Open Source
Android code available at http://source.android.com/source/download.html and
the Android Source Code provided by Google to HTC.
(I.T.C. 797, Feb. 2, 2012, No. 19.)

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Appendix A
Apple’s April 5, 2012
Subpoena to Google
4. All documents that
comprise, refer, or relate to
communications between
you and Samsung relating
to Android, including but
not limited to the version
of the Android mobile
platform as used in the
Samsung Galaxy Nexus.

Previous Subpoenas from Apple
Documents and Things sufficient to fully describe all communications between
Google (or anyone acting on behalf of Google) and Motorola Solutions or
Motorola Mobility (or anyone acting on behalf of Motorola Solutions or
Motorola Mobility) regarding the Android platform; the Motorola Accused
Mobile Devices; or Apple.
(S.D. Fla. 10-23580, Nov. 3, 2011, No. 2.)
Any correspondence or materials exchanged with HTC regarding the hardware
and/or Software design or architecture of any Accused HTC Android Products.
(I.T.C. 710, Aug. 27, 2010, No. 10.)
Documents and Things sufficient to fully describe all communications between
Google (or anyone acting on behalf of Google) and Motorola Solutions,
Motorola Mobility (or anyone acting on behalf of Motorola Solutions or
Motorola Mobility) regarding the Android Platform; the Motorola Accused
Mobile Devices; or Apple.
(I.T.C. 750, May 16, 2011, No. 2.)
Any correspondence or materials exchanged with HTC regarding the hardware
and/or Software design/architecture of any Accused Products.
(I.T.C. 797, Feb. 2, 2012, No. 9.)

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Appendix A
Apple’s April 5, 2012
Subpoena to Google
5. All documents that
comprise, refer, or relate to
communications between
you and Samsung relating
to Apple, including but not
limited to communications
relating to Apple’s
products incorporating any
version of the iOS
operating system.

Previous Subpoenas from Apple
Documents and Things sufficient to fully describe all communications between
Google (or anyone acting on behalf of Google) and Motorola Solutions,
Motorola Mobility (or anyone acting on behalf of Motorola Solutions or
Motorola Mobility) regarding the Android Platform; the Motorola Accused
Products; or Apple.
(N.D. Ill. 11-8540, May 20, 2011, No. 2.)
Documents and Things sufficient to fully describe all communications between
Google (or anyone acting on behalf of Google) and Motorola Solutions or
Motorola Mobility (or anyone acting on behalf of Motorola Solutions or
Motorola Mobility) regarding the Android platform; the Motorola Accused
Mobile Devices; or Apple.
(S.D. Fla. 10-23580, Nov. 3, 2011, No. 2.)
All Communications between Google and HTC regarding the Android
Platform; the Accused HTC Android Products; Apple; any Apple Product,
including but not limited to any MacBook, iPhone, or iPad; or any litigation
involving both Apple and HTC, including but not limited to ITC Investigation
Nos. 337-TA-710 and 337-TA-721.
(I.T.C. 710, Aug. 27, 2010, No. 1.)
All Communications between Google and any Entity regarding the Asserted
Patents; Apple; any Apple product, including but not limited to any MacBook,
iPhone, or iPad; or the features or functionalities of the Android Platform.
(I.T.C. 710, Aug. 27, 2010, No. 3.)

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Appendix A
Apple’s April 5, 2012
Subpoena to Google
6. All documents that
comprise, refer or relate to
communications between
you and Samsung relating
to Slide to Unlock, Text
Correction, Unified
Search, and/or Special
Text Detection software,
features, or functionality,
including but not limited to
any version of any such
software, features, or
functionality used in the
Samsung Galaxy Nexus or
in any version of Android.
7. Documents sufficient to
show the design,
development, and
implementation in Android
4.0 Ice Cream Sandwich of
the Slide to Unlock, Text
Correction, Unified
Search, and Special Text
Detection software,
features, or functionality.

Previous Subpoenas from Apple
All communications between Google and Samsung concerning any Samsung
Accused Product(s) or Android and the display and operation of a user interface
status bar or a notification in a status bar.
(N.D. Cal. 11-1846, Feb. 15, 2012, No. 7.)
Documents and Things sufficient to fully describe all communications between
Google (or anyone acting on behalf of Google) and Motorola Solutions,
Motorola Mobility (or anyone acting on behalf of Motorola Solutions or
Motorola Mobility) regarding the Android Platform; the Motorola Accused
Mobile Devices; or Apple.
(S.D. Fla. 10-23580, Nov. 3, 2011, No. 2.)
Document and Things sufficient to fully describe all communications between
Google (or anyone acting on behalf of Google) and Motorola (or anyone acting
on behalf of Motorola) concerning any of the Apple Patents-in-Suit or this
action.
(I.T.C. 750, May 16, 2011, No. 16.)
Documents and Things sufficient to fully describe the development, use, and
implementation of all process(es) and/or functionality(ies) in the Android
Platform for locking and unlocking the touchscreen.
(N.D. Ill. 11-8540, May 20, 2011, No. 18.)
The development, use and implementation of the process(es) and/or
functionality(ies) in the Android Platform for locking and unlocking a
touchscreen, including but not limited to the gesture-to-unlock and pattern
unlock functionalities.
(I.T.C. 750, May 16, 2011, No. 12 (Deposition Topic).)

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Appendix A
Apple’s April 5, 2012
Subpoena to Google
8. Documents sufficient to
show the design of,
development of,
implementation of, and/or
decision to implement in
any version of Android the
Slide to Unlock, Text
Correction, Unified
Search, and/or Special
Text Detection software,
features, or functionality.

Previous Subpoenas from Apple
Documents and Things sufficient to fully describe the development, use, and
implementation of all process(es) and/or functionality(ies) in the Android
Platform for locking and unlocking the touchscreen, including but not limited to
gesture-to-unlock and pattern unlock functionalities.
(S.D. Fla. 10-23580, Nov. 3, 2011, No. 15.)
The development, use and implementation of the process(es) and/or
functionality(ies) in the Android Platform for locking and unlocking a
touchscreen, including but not limited to the gesture-to-unlock and pattern
unlock functionalities.
(I.T.C. 750, May 16, 2011, No. 12 (Deposition Topic).)
The development, use and implementation of the process(es) and/or
functionality(ies) that recognize and allow data structures such as telephone
numbers, email addresses, physical addresses, and Internet universal resource
locators (URLs) to be selected as hyperlinks in the messaging applications in
the Android Platform, including but not limited to the Gmail, Email, text
messaging, instant messaging (IM) and multimedia messaging service (MMS)
applications.
(N.D. Ill. 11-8540, May 20, 2011, No. 23.)
All Documents Relating to the Android Platform’s performance of actions on
detected structures, including but not limited to detected street addresses, phone
numbers, and email addresses.
(I.T.C. 710, Aug. 10, 2010, No. 138.)
All Documents Relating to the functionality in the Android Platform that causes
text, including but not limited to street addresses, phone numbers, and email
addresses, to be highlighted, underlined, bolded or otherwise emphasized on the
user display of a device or computer operating on the Android Platform.
(I.T.C. 710, Aug. 10, 2010, No. 138.)

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Appendix A
Apple’s April 5, 2012
Subpoena to Google
9. All documents relating
to any efforts or attempts,
including the analysis and
decision-making to engage
in such efforts or attempts,
to design around or
otherwise imitate without
directly copying Apple’s
products that incorporate
any version of the iOS
operating system as well as
the Slide to Unlock, Text
Correction, Unified
Search, and/or Special
Text Detection software,
features, or functionality.

Previous Subpoenas from Apple
Documents sufficient to show any plan or attempt to design any Motorola
Accused Product or the Android Platform to avoid infringement of the Apple
Patents-in-Suit.
(N.D. Ill. 11-8540, May 20, 2011, No. 10.)
Documents sufficient to show any plan or attempt to design any Motorola
Accused Device or the Android Platform to avoid infringement of the Apple
Patents-in-Suit.
(I.T.C. 750, May 16, 2011, No. 4.)
All Documents Relating To any plan or effort to design any Accused Product or
the Android Platform to avoid infringement of the Asserted Patents.
(I.T.C. 797, Feb. 2, 2012, No. 5.)
All communications between Google and Samsung concerning actual or
potential modification(s) of Android or of the Samsung Accused Product(s) to
avoid infringement of the Patents-in-Suit.
(N.D. Cal. 11-1846, Feb. 15, 2012, No. 3.)
All Communications between Google and HTC or any HTC related entity
Relating To any reverse engineering or competitive analysis or testing of any
Apple product or technology.
(I.T.C. 797, Feb. 2, 2012, No. 55.)
All Documents Relating to any plan or effort to design any Accused HTC
Android Product or the Android Platform to avoid infringement of the Asserted
Patents.
(I.T.C. 710, Aug. 10, 2010, No. 6.)

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Appendix A
Apple’s April 5, 2012
Subpoena to Google
10. All documents relating
to any analysis, review,
consideration, evaluation,
inspection, tear-down
report, or copying of any
Apple product, including
but not limited to Apple’s
products that incorporate
any version of the iOS
operating system as well as
the Slide to Unlock, Text
Correction, Unified
Search, and Special Text
Detection software,
features, or functionality.
11. All documents
constituting, reflecting, or
otherwise relating to any
analysis, review, research,
survey, consideration, or
evaluation of the
importance to consumers
and consumer purchasing
decisions of Slide to
Unlock, Text Correction,
Unified Search, and/or
Special Text Detection on
a phone or other mobile
device.

Previous Subpoenas from Apple
Evaluations, competitive analyses and/or reverse engineering by You or by
third parties Relating To or concerning Apple’s iPhone, iPad, or iPod touch
products and/or iOS operating system or any features, functions, or systems
thereof.
(I.T.C. 797, Feb. 2, 2012, No. 52 (Deposition Topic).)
All Communications between Google and any entity regarding the Asserted
Patents; Apple; any Apple product, including but not limited to any MacBook,
iPhone, or iPad; or the features or functionalities of the Android Platform.
(I.T.C. 710, Aug. 10, 2010, No. 3.)

For each Motorola Accused Product, all promotional and sales materials,
planning and strategy Documents, focus group information, press releases,
market analyses, analyst reports, and competitive analyses.
(N.D. Ill. 11-8540, May 20, 2011, No. 8.)
For each Accused Product, all promotional and sales materials, planning and
strategy Documents, focus group information, press releases, market analyses,
analyst reports, and competitive analyses.
(I.T.C. 797, Feb. 2, 2012, No. 6.)
All Documents and Things Relating To or concerning user usage and
preference for any Scrolling Feature, Overscrolling Feature, Gesturing Feature
and Orientation Change Feature as implemented in each version of the Android
Platform provided by Google to HTC or in any Google-developed application
program that Google provides to HTC, including, without limitation, any such
application programs Installed by Default by HTC.
(I.T.C. 797, Feb. 2, 2012, No. 50.)

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Appendix A
Apple’s April 5, 2012
Subpoena to Google
12. All documents
constituting, reflecting, or
otherwise relating to any
analysis, review, research,
survey, consideration, or
evaluation of the
importance to consumers
and consumer purchasing
decisions of the ability or
capability to search the
Internet on a phone or
other mobile device.

Previous Subpoenas from Apple
For each Motorola Accused Product, all promotional and sales materials,
planning and strategy Documents, focus group information, press releases,
market analyses, analyst reports, and competitive analyses.
(N.D. Ill. 11-8540, May 20, 2011, No. 8.)

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