Motorola Mobility, Inc. v. Apple, Inc.

Filing 133

NOTICE by Motorola Mobility, Inc. of Filing Copies of Presentations Relating to Tutorial Hearing (Attachments: # 1 Exhibit, # 2 Exhibit)(Giuliano, Douglas)

Motorola v. Apple
Motorola Patents
Tutorial, October 6, 2011
Judge Ursula Ungaro
District Court of Florida
Case No. 1:10cv023580-Civ-UU

1

U.S. Patent No. 5,958,006
and
U.S. Patent No. 6,101,531
Motorola Patent
2

U.S. Patent Nos. 5,958,006 & 6,101,531
•

The ‘006 and ‘531 Patents
have the same specification

3

’006/’531 Patents: Overview of the Invention

‘006 Patent, 1:11-13
‘531 Patent, 1:16-18

4

’006/’531 Patents: Problem To Be Solved

 Transferring data over a wired or wireless
network is expensive.
 More data can be more expensive for user

5

’006/’531 Patents: Problem To Be Solved
SPAM Compounds the Problem
Unsolicited Messages (“Junk Mail”)
SPAM has experienced exponential growth since the mid1990’s and now comprises about 90% of all emails sent
SPAM costs U.S. businesses tens of billions of dollars every
year
Blocking SPAM is crucial to reducing data transfer

6

’006/’531 Patents: The Prior Art

Some prior art systems transmitted only the
header information from email messages (i.e.
sender, subject, time sent) and gave the user the
option to download the contents of the message
later.

A Mobile Pen-Based Computing System for Cellular Telephone Networks, Hoshi et al. (1993)

7

’006/’531 Patents: The Prior Art

 Disadvantages:
 User cannot view any of the message content
 Difficult for the user to decide whether or not she
needs contents of the message just based on header

A Mobile Pen-Based Computing System for Cellular Telephone Networks, Hoshi et al. (1993)

8

’006/’531 Patents: Overview
 The ‘006 and ‘531 Patents address the filtering of data being
sent to the mobile device using user-definable parameters

Client
communication unit

Wireless
base
station

Data
network

See ‘006 Patent, 2:66-3:3
See ‘531 Patent, 3:4-8

9

’006/’531 Patents: Overview
 Filtering can occur anywhere, such as between the host and
communication servers

‘006 Patent, 3:3-15
‘531 Patent, 3:8-20

10

’006/’531 Patents: Overview
 They also disclose filtering data at the communication server

‘006 Patent, 3:3-15
‘531 Patent, 3:8-20

11

’006/’531 Patents: Overview
 The Filtering Process – Examples of email Criteria

‘006 Patent, 9:60-10:9
‘531 Patent, 10:1-17

12

’006/’531 Patents: Overview
 The Filtering Process – Message Size, attachments…

‘006 Patent, 9:60-10:9
‘531 Patent, 10:1-17

13

’006/’531 Patents: Overview
Qualifying and Non-Qualifying Data Units
Qualifying data units are those that meet the
parameters of the filter. Qualifying data units are
delivered to the mobile device.

Non-qualifying data units are those that do NOT meet
the parameters of the filter.
Only identifying information of non-qualifying data
units is sent to the mobile device.
See ‘006 Patent, 9:27-29, 10:21-32

14

Visual representation of filtering

No Filter: All of Incoming
Data Units Reach The
Mobile Device
15

Visual representation of filtering

3. Qualifying Data
Units

2. Filter Based
on User Criteria

Some of Incoming Data
Units Filtered Before
Reaching Mobile Device
16

Visual representation of filtering

3. Qualifying Data
Units

2. Filter Based
on User Criteria

None of Incoming Data
Units Filtered Before
Reaching Mobile Device
17

Visual representation of filtering

3. Qualifying Data
Units

2. Filter Based
on User Criteria

All of Incoming Data
Units Filtered Before
Reaching Mobile Device
18

’006/’531 Patents: Wireless and Wired Components
 The ‘006 and ‘531 Patents can be used in systems
with wireless and wired components

‘006 Patent, 4:39-43
‘531 Patent, 4:45-49

‘006 Patent, 15:62-16:7
‘531 Patent, 15:66-16:11

19

’006/’531 Patents: Wireless and Wired Components

20

‘006/’531 Patents: Accused Products
 MobileMe














Apple iPhone 3G
Apple iPhone 3G S
Apple iPhone 4G
Apple iPad / iPad with 3G
Apple iPad 2 / iPad 2 with 3G
Apple iPod Touch
Apple MacBook
Apple MacBook Pro
Apple MacBook Air
Apple iMac
Apple Mac Mini
Apple Mac Pro
21

‘006/’531 Patents: Accused Products









MobileMe
Apple iPhone 3G
Apple iPhone 3G S
Apple iPhone 4G
Apple iPad / iPad with 3G
Apple iPad 2 / iPad 2 with 3G
Apple iPod Touch








Apple MacBook
Apple MacBook Pro
Apple MacBook Air
Apple iMac
Apple Mac Mini
Apple Mac Pro
22

U.S. Patent No. 5,754,119

Motorola Patent
23

U.S. Patent No. 5,754,119

24

‘119 Patent: Overview of the Invention
 The ‘119 Patent teaches a system and method of
“synchronization” among multiple mobile devices.
 Status changes on one mobile device synchronized
to other mobile devices.

 The ‘119 Patent teaches a system and infrastructure that is
able to update such status changes without user intervention.

25

‘119 Patent: The Prior Art Problem
INFRASTRUCTURE

 The prior art recognized that where the
user has multiple devices, incoming
messages should be directed to all of
them

26

‘119 Patent: The Prior Art Problem
INFRASTRUCTURE

Unread

 But, the prior art had a problem with
synchronizing changes, e.g., unread vs.
read emails, on multiple devices

Unread
27

‘119 Patent: The Prior Art Problem
INFRASTRUCTURE

Read

 But, the prior art had a problem with
synchronizing changes, e.g., unread vs.
read emails, on multiple devices

Unread
28

‘119 Patent: The Prior Art Problem
INFRASTRUCTURE

Delete

 But, the prior art had a problem with
synchronizing changes, e.g., unread vs.
read emails, on multiple devices

Unread
29

‘119 Patent: The Prior Art Problem
 Previously, the user had to manually sync her
devices
 I.e., when a new message was read and
deleted on one device, would still be marked
as “unread” on her other devices.
 Requiring user intervention to sync changes was
inefficient, time consuming and subject to error

See `119 Patent, 1:29-48
30

‘119 Patent: The Solution - Demonstration
INFRASTRUCTURE

Unread

Unread
31

‘119 Patent: The Solution - Demonstration
INFRASTRUCTURE

Unread
Read

Unread
Read
32

‘119 Patent: The Solution
The invention of the ‘119 patent can be incorporated into ANY transceiver – i.e.,
any device that can send and receive information over a wireless infrastructure.

`119 Patent, 9:45-50

A transceiver is a device comprising both a transmitter and a receiver which are combined
and share common circuitry or a single housing.

33

‘119 Patent: The Solution
1. A first message is transmitted to each user device.

INFRASTRUCTURE

See `119 Patent, 5:27-29

34

‘119 Patent: The Solution
2. The first message is received by each user device;
the status of the message is “unread” on all devices.

INFRASTRUCTURE

Unread
See `119 Patent, 5:29-30

Unread
35

‘119 Patent: The Solution
3. User reads first message on first device; status of the
message changes to “read” on first device

INFRASTRUCTURE

Read
See `119 Patent, 5:40-45

Unread
36

‘119 Patent: The Solution
4. The first device sends a second message
indicative of changed status.

INFRASTRUCTURE

Read
See `119 Patent, 5:40-45

Unread
37

‘119 Patent: The Solution
4. The first device sends a second message
indicative of changed status.

 Figure 3 illustrates one embodiment of a
second message indicative of the changed
status:

38

‘119 Patent: The Solution
4. The first device sends a second message
indicative of changed status.

 As illustrated, this second message contains 4 fields: address, message
number, status change, and origin.
1.
2.
3.

4.

Address Field
MSG No. Field

- used to selectively identify the portable devices;
- used to identify the message whose status is
being updated;
Status Change Field – “for indicating the status change” of the
updated message; and
Origin Field
- identifies the portable device sending the
second message.
`119 Patent, 5:56-65

39

‘119 Patent: The Solution
4. The first device sends a second message
indicative of changed status.

 The Status Change field contains only three 3 bits.
 A bit (aka a “binary digit”) is the smallest unit of information that a
computer can read.
 A bit can have only two possible values: either a “0” or a “1”

40

‘119 Patent: The Solution
4. The first device sends a second message
indicative of changed status.

“These three bits indicate the
corresponding status of the identified
message.”
‘119 Patent, 6:5-6 (emphasis added).

41

‘119 Patent: The Solution
4. The first device sends a second message
indicative of changed status.

INFRASTRUCTURE

Read
See `119 Patent, 5:40-45

Unread
42

‘119 Patent: The Solution
5. The infrastructure received the second message and
transmits a third message indicative of the second status

INFRASTRUCTURE

Read
See `119 Patent, 6:18-29

Unread
43

‘119 Patent: The Solution
6. The other transceiver receives the third
message changes the status of the first message

INFRASTRUCTURE

Read
See `119 Patent, 6:18-29

Read
44

‘119 Patent: The Solution

 Although this invention synchronizes multiple
devices without user intervention, one or
more delays may occur throughout the
process.

‘119 Patent, 6:10-14

45

The ‘119 Patent
II. Apple’s Infringing Products:
iPhones, iPads, and MobileMe

46

Apple’s Infringing Devices
 iPhones, iPads, and MobileMe work together
to synchronize message status among
multiple devices.

47

The ‘119 Patent

III. Motorola devices embodying
the claimed invention

48

Motorola Embodiments
 All of Motorola's mobile devices using the
Android operating system embody the
claimed inventions.
 Including the Atrix, Bravo, Charm, Citrus, Cliq,
Cliq XT, Cliq 2, Defy, Devour, Droid, Droid 2, Droid 2
Global, Droid X, Droid Pro, BackFlip, Flipout,
Flipside, i1, and Xoom.

49

U.S. Patent No. 5,710,987

Motorola Patent
50

U.S. Patent No. 5,710,987

51

‘987 Patent: Overview of the Invention

 The inventions
disclosed by the ‘987
patent address
external antennas
concealing and/or
integrating with
a device

‘987 Patent, Abstract

52

Prior Art - U.S. Patent No. 5,408,699
 Prior art put the antenna in the interior of the device

53

‘987 Patent: Overview

`987 Patent, 2:36-40, 2:50-58

54

‘987 Patent: Overview

Antenna

Volume
Control
Contacts
Volume
Buttons
‘987 Patent, FIG 2

55

‘987 Patent: Overview
 The terminals (201 and 202)
are the portions of the overall
antenna that are connected to
the receiver

‘987 Patent, FIG 2

56

‘987 Patent: Overview
 The antenna (212) is a
continuous piece of metal
 Both Figure 2 and Figure 3
show terminals as part of
antenna

FIG. 2

57

‘987 Patent: Overview
 Antenna located inside the device housing to connect to the receiver circuitry and
the remainder of the antenna wraps around the volume buttons
 A portion of the antenna is inside the housing of the device when the device is
assembled
Antenna

Volume
Control
Contacts

Volume
Buttons

Rendering of Assembled Device, ‘987 Patent, FIG 2

58

‘987 Patent: Accused Products

 Apple iPhone 4

59

‘987 Patent

 Earlier Apple products had visually similar
metal bands
iPhone 3GS

Metal
band

60

‘987 Patent: Accused Products

 Apple iPhone 4

Antenna

Antenna

61

U.S. Patent No. 6,008,737

Motorola Patent
62

U.S. Patent No. 6,008,737

63

‘737 Patent: Overview of the Invention
 The teaches a system and method of controlling the utilization of a
hardware or software process installed on a portable communication
device

INFRASTRUCTURE

Fixed Portion
64

‘737 Patent: Background
 Advances in technology allowed mobile devices to perform
sophisticated tasks, such as email, data processing, and
banking and financial transactions
 This method was designed with technological advancements in
mind

'737 Patent, Col. 1:22-27
65

‘737 Patent: Background
The invention of the ‘737 patent can be incorporated into ANY transceiver – i.e.,
any device that can send and receive information over a wireless infrastructure.

`737 Patent, Abstract

A transceiver is a device comprising both a transmitter and a
receiver which are combined and share common circuitry or a single
housing.

66

’737 Patent: The Prior Art Problem

 Advanced functionality on mobile
devices would be offered at a
premium.
 Need to ensure that only authorized
users could use this premium
functionality of mobile devices.

`737 Patent, 1:27-44

67

’737 Patent: The Prior Art Problem

In prior art devices, registration has been
accomplished by mailing a signed certificate
with a purchase receipt of a software application
or hardware module. This form of registration,
however, does not prevent an unscrupulous user
from using pirated software applications and/or
unauthorized hardware modules.
`737 Patent, 1:27-44

68

‘737 Patent: Prior Art Problem
 Existing authorization systems, such as mail-in
registration, were slow, inconvenient and
ineffective.

 No effective solution for authenticating a user of a
mobile device over a wireless network.

69

The ‘737 Patent Technology
 The ‘737 patent teaches a mobile device containing
hardware and/or software that can request
authorization from a central database and that contains
hardware and/or software that can allow utilization after
receiving authorization.

 Two elements:
1. An element that generates an external request for
authorization; and
2. An element that allows utilization.
70

The ‘737 Patent Technology
Element 1: An External Authorization Request

`737 Patent 15:20-22

 In this embodiment, the external authentication request is encrypted,
meaning it is unreadable to anyone except those possessing special
knowledge (often referred to as a “key”).
 This ensures that when your portable device sends a message to the
central database, or vice-versa, only the intended recipient can read the
message.
71

The ‘737 Patent Technology
Element 1: An External Authorization Request
The authorization request must contain at least one of:
1. An address identifying the portable communication device;
2. A software name; and
3. A size of the software

72

The ‘737 Patent Technology
Element 1: An External Authorization Request
 This request is sent to a central database that contains a
list of authorized users / devices:

The database of portable device records 216 contains, as
a minimum, a list of process records 220 for each portable
communication device 122. To access the list of process
records 220 of a portable communication device 122, a
portable device address 218 corresponding to the address
of a portable communication device 122 is used to search
the database of portable device records 216 . . . .
‘737 patent at 3:39-57
73

The ‘737 Patent Technology
Element 1: An External Authorization Request

 If the central database determines that a user/device
is authorized, it transmits an authorization message
back to the requesting mobile device.

74

The ‘737 Patent Technology

Authorized User

?


INFRASTRUCTURE

?


Central Database
75

The ‘737 Patent Technology
Element 1: An External Authorization Request

 If the central database determines that a user/device
is not authorized, it transmits an denial message
back to the requesting mobile device.

76

The ‘737 Patent Technology

Unauthorized User

?


INFRASTRUCTURE

?


Central Database
77

The ‘737 Patent Technology
Element 2: Usage Allowance

 Upon receiving a authorization message, the mobile
device authorizes usage of the software or media
file.

78

The ‘737 Patent
II. Apple’s Infringing Products:
iPhones, iPads, Laptops, and Apple TV







Apple iPhone 3G
Apple iPhone 3GS
Apple iPhone 4G
Apple iPad / iPad with 3G
Apple iPad 2 / iPad 2 with 3G
Apple iPod Touch









Apple MacBook
Apple MacBook Pro
Apple MacBook Air
Apple iMac
Apple Mac Mini
Apple Mac Pro
Apple TV

79

The ‘737 Patent

III. Motorola devices embodying
the claimed invention

80

Motorola Embodiments
 All of Motorola's mobile devices using the
Android Marketplace.
 Including the Atrix, Bravo, Charm, Citrus, Cliq,
Cliq XT, Cliq 2, Defy, Devour, Droid, Droid 2, Droid 2
Global, Droid X, Droid Pro, BackFlip, Flipout,
Flipside, i1, and Xoom.

81