Motorola Mobility, Inc. v. Apple, Inc.

Filing 118

NOTICE by Apple, Inc. of Page 21 of its Responsive Claim Construction Brief (Attachments: # 1 Supplement In Color Page 21 of Responsive Brief)(Pace, Christopher)

Further, the portion of the antenna
Motorola contends may be disposed within the
housing is not the antenna, but contact terminals
201 and 202 (yellow). Id. at 3:7-8 (“The pager
antenna is coupled to the pager receiver circuitry
via terminals 201 and 202 . . . .”). Figure 3
provides another illustration of the contact terminals 201 and 202 (yellow) and the pager antenna
212 (red). It is through these contact terminals 201 and 202 that the external pager antenna 212
attaches to the pager receiver circuitry. It is these contact terminals 201 and 202 that may be
disposed in the housing.
The ’987 patent further confirms that the
entire pager antenna is outside the housing. The
specification teaches: “The first preferred location
of the pager antenna 212 is disposed outside the
shielded portion 204 of the front housing 102 . . . .”
See id. at 3:26-34. The title of the patent reads:
“Receiver having concealed external antenna.”
The abstract states: “The pager antenna 212 is located outside the housing (102, 104) . . . .” See
id. at abstract. Nowhere in the ’987 patent is any portion of the claimed antenna described as
being inside the housing.
For these reasons and those set forth in Apple’s opening brief, the Court should construe
the limitation, “the antenna . . . is disposed between an outside surface of the housing and the at
least a portion of the user interface,” as referring to the entire antenna.
(2)

The Patentee Narrowed the Meaning of “Housing” to
the “Receiver’s Case” During Prosecution

Motorola cites nothing to support its contention that construing the “housing” to mean the
“receiver’s case” would introduce an ambiguous term. Motorola Br. at 46. This is likely

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